Reducing inadvertently generated
PCBs through pollution prevention
January 2021
Overview
The U.S. Environmental Protection
Agency's (EPA) Pollution Prevention
program supports the development
and implementation of P2 solutions
through grant programs, technical
assistance, and by connecting
researchers, industry experts,
and others to develop innovative
solutions to environmental
challenges. Preventing pollution
at its source means fewer hazards
posed to public health and the
environment. This approach can also
save businesses money.
In EPA Region 10 (WA, OR,
ID, AK), the regional Pollution
Prevention and PCB programs
have collaborated to address
the challenge of iPCBs. The
programs have worked together
to evaluate potential options for
reducing iPCBs in products and
to support state environmental
agencies, EPA's Office for Research
and Development, and industry
experts in developing upstream P2
approaches to reduce the release of
iPCBs into the environment.
What are iPCBs?
Polychlorinated biphenyls (PCBs) are persistent, bioaccumulative, and
toxic (PBT) compounds. Although commercial PCB production was
banned in 1979 under the Toxics Substance Control Act (TSCA), Non-
Aroclor1 PCBs (iPCBs) are generated inadvertently as a byproduct or
impurity resulting from some chemical manufacturing processes. iPCBs
can be generated during a variety of production processes, and they
can contaminate products as well as waste streams. iPCBs have been
identified in certain pigments that are currently manufactured for use
in paints, inks, textiles, paper, cosmetics, leather, and other materials Z3
iPCBs have also been found in effluent discharges, sanitary sewer
systems, surface water bodies, and in humans. iPCB contamination of
water bodies is a non-point source challenge meaning iPCBs come
from many different sources. Water quality standards for PCBs are
set at extremely low concentrations due to their bioaccumulation and
biomagnification in the food chain. Even if iPCBs contribute only a small
amount of contamination at a time, our states and nation can't ensure
clean water without addressing this non-point source of pollution.
Upstream, pollution prevention solutions and viable alternatives to
iPCB-containing products will reduce the generation of iPCBs and help
protect human health and the environment.
Innovative Partnerships to Develop Pollution
Prevention Solutions
In October 2019, the Washington State Department of Ecology used
EPA P2 grant funds to host an iPCB workshop in partnership with EPA
Region 10, Spokane River Regional Toxics Task Force (SRRTTF), the
Color Pigments Manufacturer Association (CMPA), Northwest Green
Chemistry (NGC), the Bullitt Foundation, and industry representatives
to discuss opportunities to reduce iPCBs in inks and pigments and the
downstream products and processes using those inks and pigments.
The workshop helped establish lines of communication between
chemical manufacturers, product manufacturers, purchasers, and end-
of-life managers with the intention of formulating actionable steps to
stimulate innovation and create markets for safer products.4 Workshops
like this one, that work with supply chains to foster communication
and collaboration, are a first step to develop innovative, non-regulatory
pollution prevention approaches to environmental challenges. Since the
October 2019 workshop, participants have continued the conversation
through their participation on working groups facilitated by NGC.
1 PCBs were often sold under the trade name Aroclor
2 America's Children and the Environment, Third Edition, PCB Section, 2015: https://www.epa.gov/
sites/production/files/2015-05/documents/biomonitoring-pcbs.pdf
3 Liu, X. AND M, Mullin. Inadvertent Polychlorinated Biphenyls (PCBs) in Consumer Products, the 2019
ISEE & ISIAQ Joint Conference, Kaunas, Europe, LITHUANIA, August 18 - 22, 2019. https://cfpub.epa.
gov/si/si_public_record_report.cfm?Lab=NRMRL&dirEntryld=346285
4 Inadvertently Produced PCBs in Inks and Pigments Workshop Summary: https://srrttf.org/7page_
id=10745.
For more information on P2 and the EPA's P2 Grants Program, visit www.epa.gov/P2
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Washington State Department of Enterprise PCBs Risk Calculator.
Pollution Prevention Solutions in Action
Washington State's 2014 Revised Code of
Washington5 limits PCBs in state-purchased
products. As a result of this law, the state updated
many of their procurement contracts. For example,
the Washington State Department of Transportation
(WSDOT) updated their road paint master contract
to prohibit the purchase of road paints containing
diarylide pigments and pigment 83, which are
pigments associated with iPCB generation, WSDOT
found that they could procure road paint that
met the required performance standards while
implementing this environmentally preferable
purchasing (EPP) policy. Additionally, Washington
Department of Enterprise Services has created a
PCB Risk Calculator to help procurement and EPP
specialists determine the likelihood that products
may contain iPCBs and to make recommendations
for whether to test the product before buying in bulk.
Continuing P2 efforts
In 2019, Washington State passed the Pollution
Prevention for Healthy People and Puget Sound
Act6, which creates a new way to keep harmful
chemicals out of the environment by authorizing the
Washington State Department of Ecology to restrict
or eliminate toxic chemicals in consumer products
when safer alternatives are available. The Washington
State Department of Ecology is currently evaluating
PCBs in paints and printing inks under this new law.
Additional EPA Contributions to
Pollution Prevention Innovation
• EPA's Office of Research and Development,
with support from the EPA PCB and
Pollution Prevention programs, is conducting
product testing to determine the range of
concentrations of iPCBs within consumer
products, with a special emphasis on children's
products. Future research will evaluate how
iPCBs migrate out of consumer products and
into our environment and bodies.
• The Region 10 regional PCB and Pollution
Prevention programs collaborated with the
EPA Small Business Innovation Research (SBIR)
Grant program to solicit proposals in 2020 for
innovative coloration technologies that do not
result in iPCB generation.7 The SBIR program
provides research and development funding to
small businesses to support commercialization
of innovative technologies that help support
EPA's mission of protecting human health and
the environment,
• The National Toxicology Program is working
with EPA to evaluate the toxicology of PCB-
11, a PCB congener often associated with
inadvertent PCB generation.
5 RCW 39.26.280-290: https://app.leg.wa.gov/rcw/defauIt.aspx?cite=39.26.280#:~:text=RCW%2039.26.,in%20packaging%20containing%20
polychlorinated%20bi phenyls.
6 More information about the Pollution Prevention for Healthy People and Puget Sound Act, Substitute Senate Bill 5135, can be found here: https://ecology.
wa.gov/Waste-Toxics/Reducing-toxic-chemicals/Safer-products.
7 SBIR funding information: https://www.epa.gov/sbir/sbir-funding-opportunities.
For more information on P2 and the EPA's P2 Grants Program, visit www.epa.gov/P2
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