Posted on Wed, Sep 30, 2009 @ 08:44 AM
By Sean Reagan, Corporate Director of Higher Education
Long awaited guidance from EPA Headquarters on the issue of PCB-laden building caulking material provides us with a great deal to digest. Although the EPA states that the presence of PCBs should not be cause for alarm -effectively managing this complex issue is cause for alarm for many school administrators and facility managers. Here's a first pass on the highlights of this guidance:
1. EPA was careful to not use "must" or "shall" language and maintained "may" and "should" language in this guidance. Testing (caulk sampling or indoor air) is still not required however, indoor air testing in schools is strongly recommended to determine if their is an immediate exposure risk to children in schools.
2. EPA acknowledges the growing amounts of evidence of the presence of levels of PCBs in caulk used in older buildings (1950-1978) - generally not concerned YET about newer buildings (but this may still be a problem).
3. IMMEDIATE MITIGATION STEPS - The released guidance are steps building owners and school administrators should take to minimize potential exposure. Immediate steps include cleaning air ducts, improving ventilation, clean frequently-reduce dust, wash children's hands frequently, among a few other common sense steps.
4. INDOOR AIR TESTING - Beyond immediate steps, EPA recommends testing to determine if PCB levels in the air exceed EPA's suggested public health levels. If testing reveals PCB levels above these levels, schools should be especially vigilant in implementing and monitoring practices to minimize exposures. If a second test after immediate steps taken do not lower indoor levels - schools should (not required) take steps to remove peeling caulk. In short - it is believed that if you fail the second air test you will be remediating the PCB Caulk and contact building materials under the direction of the Regional PCB Coordinator.
5. PCB INDOOR AIR THRESHOLDS - EPA published Public Health Levels of PCBs in School Indoor Air (ng/m3) - indoor air concentrations below these levels are believed to keep total exposure below EPA reference dose (in other words - "safe").
6. ADDITIONAL RESEARCH - EPA states that they need more time to complete research on questions related to the magnitude of unresolved scientific questions such as the link between the concentrations of PCBs in caulk and PCBs in the air or dust. More to come on this......some schools may be recruited to participate in these studies to include methods to mitigate exposures to PCB caulk including encapsulation of the caulking as well as contact material (wood, brick, concrete).
7. SCHOOLS and CONTRACTORS INFO KIT - Guidance contains useful communication and information tools for school administrators, teachers students as well as contractor who may come in contact with caulking.
Posted on Mon, Sep 14, 2009 @ 01:40 PM
By Kevin Poulin, Account Manager
A potentially significant environmental health and safety concern was brought to the public’s attention this past week in the Boston Sunday Globe. The article written by Beth Daley confirms what many environmental officials have suspected for years, that high levels of PCBs (Polychlorinated biphenyls) are present in many older New England schools. The high levels of PCBs used in the caulking applied to various parts of these buildings are now in a deteriorating condition. Tests have shown PCBs are finding their way into the soils around these buildings in concentrations above the regulatory limit through the weathering process and actual physical pieces falling off of these structures. Some tests are now being conducted to verify if this material is potentially becoming an airborne hazard inside these structures.
PCBs were used primarily in office buildings and schools during the 1960s and 1970s, but were banned in the late 1970s when extensive researched exposed that they may cause cancer. Unfortunately, there are no regulations in place that require schools to test for PCBs. If a school does test for PCBs and the results come back above the regulatory limit of 50 parts per million, the school is required to address the problem. Although the schools can choose not to test for PCBs, they may be jeopardizing the health and safety of their students and faculty.
EPA has mandated remediation projects at several New England Universities. At least two others have done abatement projects on their own. However, the majority of schools are waiting until further guidance or regulations are put in place.
Many of these institutions are struggling with the decision to address this issue from an ethical, and health/safety point of view. If a school decides to test for PCBs in building components and results demonstrate their presence, the costs associated with the solution can be overwhelming. The only EPA-approved abatement methods include the removal of the infrastructure that has come in contact with the PCB-laden material. This has caused abatement projects in individual buildings to cost millions.
These institutions are one of New England’s most valuable resources, which directly and indirectly make up a huge part of our local economy. Many schools are already struggling in this down economy. On the other side of the equation is the already enormous cost for students and their families who are attending these institutions. We cannot afford to place any more stress on these resources that help define the New England area in so many ways. On the other hand, the colleges and universities along with EPA, need to find a practical solution to look beyond the money and realize that their first priority should be the people who work, live, and attend school there. Perhaps they should look to the lessons learned from the last evil spirit called asbestos.
Triumvirate Environmental has been actively engaged on this issue for the past 5 years with policy/strategy development, testing programs, project/remediation management, as well as developing innovative, cost-saving remedial approaches. Contact us today for information or assistance on this issue.
Posted on Fri, Sep 11, 2009 @ 03:24 PM
By Sean Reagan, National Director, Education
This is not the first, nor will it be the last instance, where a hazardous substance is discovered ubiquitously in building materials of schools, colleges and universities.
Approximately 25 years ago, the Asbestos Hazardous Emergency Response Act (AHERA) set forth funding and EPA regulations to address the potential hazards of asbestos containing building materials in our schools systems. Asbestos was used in the manufacture of floor tile, insulation, wallboard and other commonly used building materials. AHERA requires all private and public non-profit elementary and secondary schools to inspect their schools for asbestos containing building materials (ACBM), develop a plan to manage the asbestos in each school building, notify parents and staff regarding the management plan availability, provide asbestos awareness training to school maintenance and custodial workers, and implement timely actions (repair, encapsulation, enclosure, removal) to deal with asbestos that was friable and presented a potential hazard to building occupants.
This approach replaced the hysteria at the time that said ALL asbestos containing materials must be removed from schools. While a significant portion of the asbestos in the buildings required removal - non-friable, intact asbestos managed properly does not pose a risk to building occupants. This common sense approach resulted in cleaner, safer schools and gave school owners/operators an avenue to address the problem.
While this PCB in building material issue is relatively new, presently, an approach to mitigate the actual risks associated with PCBs in building caulking - short of a very expensive and time consuming removal of the caulking and associated contact materials- does not exist.
From a policy standpoint, the EPA should quickly develop interim measures that can be taken by these schools to mitigate the immediate risks and end the paralysis that exists about testing and remediating this problem.
Posted on Fri, Sep 11, 2009 @ 03:20 PM
By Jason Atwood, Field Services Manager
What are PCBs?
PCBs, or Polychlorinated Biphenyls, are a group of toxic, man-made chemicals produced by the chlorination of Biphenyl. They range from light, oily fluids to heavy, greasy or waxy textures. From 1929-1979 PCBs were manufactured in the United States; they were used often in high-voltage electrical transformers because they conducted heat well while being fire-resistant and great insulators. However, in 1979 the EPA banned the manufacture of PCBs because they were discovered to be highly toxic and a potent carcinogen. Today, any hazardous waste that contains more than 50 parts per million of PCBs are subject to regulation under the Toxic Substances Control Act.
Why are PCBs Dangerous?
PCBs can be detrimental to human health. Scientists have found PCBs to cause cancer in animals, and to adversely affect the immune system, reproductive system, endocrine system, and nervous system. PCBs can be absorbed by inhalation or skin contact. This is not the worst of it though. Scientists are most concerned with PCBs' ability to bio-accumulate, or buildup contaminants in an organism's tissues (as is the case with mercury and other heavy metals).
Where can be PCBs Found?
Since PCBs allow for flexibility and pliability, they were used widely as an additive to caulking materials in the decades during which they were produced. As a result, PCBs are commonly encountered in the window caulking and/or mansonry expansion joint caulking of older buildings. Compounding the problem is that as the caulking deteriorates over years of weathering, the PCB compounds leach into adjacent non-PCB containing materials cuasing wide spread cross contamination. As the caulk ages and weathers (appears brittle, cracked, or peeled), it becomes increasingly dangerous because it is releases an increased amount of PCBs. Exposure may occur when the impacted caulking comes into contact with brick, concrete, wood, or any other porous material that surround the joints. If the caulking is on the exterior of a building, PCBs may also leach and penetrate the surrounding soil.
How do I manage PCBs if they are encountered?
Firstly, if your office or school was built prior to 1979 and you believe it may have PCB impacted caulking, you can have the materials of concern analyzed and tested by a environmental consulting company - Triumvirate can assist in guiding you through this process. If the lab analytical results demonstrate that PCBs are present, exposure to the areas of concern should be limited.. Usually, PCB poses the largest concern for buildings during renovation or construction as testing of the material is required prior to disruption or removal of suspect material. Triumvirate has a broad base of experience with management techniques should contamination be encountered. Frequently, the most effective means of remediation include removal of the impacted caulking by appropriately trained personnel through manual techniques and licensed off site disposal. Other options including decontamination of non-porous surfaces, encapsulation of contaminated areas that cannot be removed, and excavation and off site disposal of soil that may have been affected by leaching of the impacted material. . The process of testing, planning, and implementation can be daunting given the complexity of the issue, however relying on the knowledge and expertise of an industry professional can make this process far less formidable!.
For more information about PCBs go to www.epa.gov/pcb, call EPA's Toxic Substances Control Act Hotline: 202-554-1404, or email me at jatwood@triumvirate.com.