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.