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PCBs in Building Materials: Is My Project at Risk?
Jeff Hamel, PE, LSP
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I have not heard of PCBs in building materials. What materials are we talking about?

The main use of PCBs in building materials is as a plasticizer. They are found predominantly in paints, specialty coatings, caulking, sealants, and other materials, as well. PCBs were added to these materials for durability, resistance to degradation, low flammability, and as a softener/plasticizer for application. 
According to U.S. EPA reports, as much as 115 million pounds of PCBs were used by industry in plasticizer applications from the 1930s to the 1970s. By the early 1970s, the use of PCBs in plasticizer applications was drastically reduced, and by the late 1970s, the manufacture of PCBs in the United States was banned by the EPA. 

Why should I be concerned about PCBs in building materials?

There are three major concerns associated with PCBs in building materials:

  • health and safety issues;
  • it is a regulated material requiring proper management and disposal; and
  • impacts from releases to other building materials.

EPA considers high levels of PCBs to be a probable human carcinogen, and studies have revealed negative effects on immune, reproductive, and nervous system health.  They can be absorbed by inhalation or skin contact.  Therefore, receptors potentially at risk, depending on PCB concentrations, the type of building material and its location, and exposure frequencies, include workers involved in demolition or renovation without proper personal protective equipment or building occupants.

If the material is at a regulated concentration, proper management and disposal are required by Federal regulations.  Of particular importance is the fact that some of these materials have been shown to leach and impact adjacent building materials, such as concrete or bricks, which are then also subject to proper clean-up and disposal.  Many of these adjacent materials are important to the structural integrity of the building and their remediation is not a straightforward process.

The main statute regulating PCBs is the Toxic Substance Control Act (TSCA), but state and local regulations also need to be followed.  Federal disposal regulations, codified under 40 CFR 761, establish the prohibitions of and requirements for the use, disposal, storage, and marking of PCBs.

What can be done if I encounter PCBs in building materials?

If you have a project that involves the renovation or demolition of a building, knowledge upfront about the presence of PCBs in materials that will be disrupted and/or disposed should be gathered.  This approach is similar to that taken for asbestos and lead-based paint.  Testing for PCBs in building materials as part of the planning process is relatively inexpensive when compared to the potential impacts that late discovery can cause to a project.

Depending on the PCB concentration in the material, there are real project implications with regard to schedule and costs, including characterization, remedial plan submittals, Agency approvals, specialty abatement, worker training, and higher disposal costs.  Being forearmed with a plan and having a thorough understanding of the regulations and their applicability to the project in the early phases, will allow for proper scheduling, budgeting, and risk management.