Ambiguity Surrounds the Detection of PCBs
- By Craig Sasse
- Aug 22, 2011
In July 2011, polychlorinated biphenyls (PCBs) were detected at Westport Middle School in Westport, Mass. An inspection determined that PCBs from caulk used around the window had leaked into adjoining masonry. Now, the town may need to spend more than $100,000 to remediate the school. This is one instance in a series of similar horror stories, in which PCBs are detected in building materials. Behind this concern lies a deeper concern regarding ambiguity surrounding the need for detecting PCBs and the costs of mitigation and management.
PCBs are a class of inorganic compounds that were banned from production in the United States by Congress in 1979. Prior to the ban and to awareness of its toxicity, PCBs were widely used in building materials for its beneficial characteristics, such as durability, low flammability and electrical insulating capability. In the 1950s through the 1970s, PCBs were used in various commercial building products like caulking, glazing, adhesives, sealers and florescent light ballasts. Recently, there has been heightened regulatory involvement and awareness of potential exposures to PCBs from these sources in schools. Many of these buildings and materials are getting older and require appropriate management, such as characterization and disposal. The process of characterization may identify the presence of PCBs.
The Current Situation
In September 2009, the Environmental Protection Agency (EPA) provided guidance for reducing potential risks associated with PCB-containing building materials in schools. The guidance documents used round-about verbiage, such as may and should, rather than must. The EPA does refer to PCBs as a serious issue, but also states that its presence in buildings and schools should not be cause for alarm. The irony in this is that, rather than directing a clear path, people are left confused and unsure of their steps to safety.
This lack of transparency applies to the dangers of PCBs as well as the prescribed exposure-reducing steps:
1. Use vacuums with HEPA filters. This solution leaves a lot of questions, such as where should the vacuum be dumped afterward – and is it safe to reuse? Do janitorial personnel need specific training and is there a risk of PCBs being released into the air? Conscientious facility staffs struggle with these questions and record-keeping, resulting in weak implementation.
2. Clean frequently to reduce dust. Wash surfaces, window sills, walls, and objects often in rooms known to have PCB-containing caulk. Building owners and schools are again left to wonder who is responsible for this process and – if it is within the custodian’s role – whether they should receive additional training. Schools want to keep employees safe and safely dispose of the contaminated material, but the solutions are not immediately clear.
3. If school administrators and building owners are concerned about potential PCBs in the caulk, they should consider testing to determine if PCBs are present in the air. There are additional sources of potential exposure that go far beyond caulking. Light ballasts, adhesives, mastics and other materials can be the sources of elevated PCB levels in air. PCB-testing for caulking is left to the discretion of individual administrators. Furthermore, the word should make the guidance a suggestion rather than a mandate.
Ambiguity Drivers
You might find yourself asking: Why does the ruling on PCBs still remain ambiguous in 2011?
First of all, the Toxic Substances Control Act (TSCA) is the driving force around today’s actions surrounding PCBs. TSCA was established 35 years ago in 1976. In April of 2010, the EPA discussed and proposed changes to the Toxic Substances Control Act (TSCA), but these changes are not proposed to be published in the federal registry until 2013. Although there is a defined concentration ppm cut-off at which PCB-containing materials is regulated, the ppm status of a building cannot be determined until testing occurs, and testing is not mandated by the EPA for every building that was manufactured between 1950 and 1970.
Although everyone desires clean, safe schools and a safe working environment, there are a lot of powerful political interests in conflict when it comes to measures regarding PCBs. School administrators and facilities managers have tight budgets in today’s economy, and they must balance their shortage of money against priorities and health concerns. Parents and guardians do not want their children in a school with even a slight trace of PCBs; child safety is their ultimate concern, and money is not an obstacle for them. So, if all schools were tested, who would pay to remediate those schools that were found to contain PCBs over the current concentration limit of 50 ppm? Would tax dollars be enough to cover the costs?
Decision makers in organizations are without substantive guidance, sensible regulations, and consistent implementation when it comes to PCBs. When conscientious school and facility personnel begin to analyze the regulations, cost and where the two lead, there is often a pause in committing to expensive actions. The unresolved questions raised above, coupled with outdated TSCA regulations originating over 30 years ago, and a lack of understanding the potential health risks, all contribute to this ambiguity. There are two ways to answer questions raised by the EPA's regulations on a short-term and long-term level.
Short-term solution
A more rational approach is needed moving forward. One choice is to initiate a risk-based management program for suspect PCB-containing materials in a building.
Steps to action:
1. Determine the pedigree of the building. If the building was built or renovated between the 1950s and 1970s, then PCB-containing materials may be present, and the building itself is retained for further characterization;
2. Inspect potentially PCB-containing materials and inventory;
3. If any building material appears to be failing (i.e. a leaking ballast), remove it; and
4. Begin budgeting and prioritizing the elimination of potentially PCB-containing materials.
The results of this process are a reduction in overall risk and the development of a process to manage the disturbance and disposal of suspect materials. The program leads to awareness, reduces exposures, improves compliance, limits liability, introduces strategic planning and avoids many costly renovation surprises.
Long-term solution
There are many competing interests and legislatures that will need to cooperate to manage the issue. A process by which potentially PCB-containing materials are identified and risk reduced is needed.
Elements of the long-term fix should include elimination or reduction of exposures. Such measures include encapsulation, the modification of building ventilation, and localized remediation. Additionally, it is necessary to develop a schedule for conducting periodic inspection. Elements of this inspection include monitoring (i.e. collecting an air sample), and maintenance (fixing scratched, broken materials, and keeping the ventilation system optimized).
Many of the short-term fixes are institutionalized until materials are ultimately removed. This process is analogous to TSCA’s regulations for asbestos management