MARCH 2011

PCBs in caulk: a looming issue for the construction and demolition industry

Polychlorinated biphenyls (PCBs) contained in building materials, particularly caulk, are rapidly becoming a large issue for the demolition and construction industry, and for society as a whole. At the same time, environmental remediation of PCBs presents C&D contractors with a widening stream of new revenue opportunities.

John Lloyd, owner of Lloyd’s Construction Services of Savage, Minnesota, is also chairman of the environmental committee of the National Demolition Association. Lloyd said, “If there’s scientific data that proves that PCBs in caulk are harmful to the environment and getting into our waterways, we have to deal with it. Many firms belonging to the Association do environmental remediation. If it is proven harmful we will be there to service that need and do it properly, but we do not want to see unnecessary regulation that raises costs for building owners and eventually for the consumer.”

Beginning in the 1980s, national attention on PCB clean up focused on mammoth superfund sites like the Hudson River and other rivers and lakes around the country that were contaminated by manufacturing plants that dumped PCBs into waterways. The nation’s largest superfund site, the Hudson River, is taking decades and billions of dollars to remove contaminated sludge from 200 miles of river bottom.

Banned by the United States Environmental Protection Agency (EPA) in 1979, PCBs are perhaps the most pernicious of all man-made materials, extremely dangerous to the health of man and beast, non-soluble, non-biodegradable, difficult to identify and recover and costly to destroy by chemical, thermal or biochemical processes. The alternative disposal is a Subtitle C landfill that accepts hazardous waste such as PCBs with levels exceeding 50 parts-per-million (ppm) and not above 1,000 ppm, which is also expensive.

Now the next generation of PCB remediation is beginning to emerge for homes and workplaces, but especially for school buildings due to growing health concerns, expanding regulations and liability issues. The costs for this stage of the clean up could prove to be astronomical.

If regulators force school districts to perform immediate PCB remediation for caulking, it could cause widespread bankruptcies. Last December, the EPA urged New York City schools to replace light fixtures containing PCBs. New York officials estimated it would cost more than $1 billion to remove and replace lighting fixtures in approximately 800 buildings across the city. They don’t have the money. This does not even address PCBs widely found at hazardous levels in caulk and other materials, all in a school district hard-pressed to provide basic educational services.

Lab analysis of caulk samples can reveal whether they contain hazardous levels of PCBs.

The issue is aggravated by another factor. Buildings containing PCB caulking, including many schools constructed during the 1950s and through the late 1970s are beginning to reach end of life. As they are scheduled for demolition or renovations, more people are calling for PCB testing. Suspect sites are also being reported to regulators by concerned citizens, parents of school children and environmental activists.

One such individual is George Weymouth, a 66 year-old retired union bricklayer-waterproofer who has been investigating PCBs in caulking, working with Harvard University’s School of Public Health. Through 32 years of job-related experience, Weymouth is a caulking expert who surreptitiously takes caulk samples from schools and industrial buildings and has them tested. “I’ve been in so many schools I feel I have something to do with the health of the children throughout the country and I’m proud to have been on the forefront of this issue for my union.”

In the late 1990s, Weymouth was sent by his union to be trained as a construction safety and health specialist. He worked with the Center for Construction Safety and Health Research and Training, formerly the Center to Protect Workers’ Rights. There Weymouth teamed with other trained journeymen and industrial hygiene researchers to measure respirable silica exposure generated from construction tasks like masonry work and abrasive blasting. This work contributed to efforts by his union to develop contract language that would require employers to use water or local exhaust ventilation when cutting or grinding masonry.

A few years after retirement, Weymouth began working with Dr. Robert Herrick, a senior lecturer at Harvard’s School of Public Health, and began to take samples of caulk in Massachusetts and New York City schools and industrial buildings. Over the past few years he has acquired and tested caulk samples from approximately 150 buildings. “One sample was a piece of caulk that fell out of a window and was lying on the ground. We had it analyzed and it was off the charts with PCBs, in the range of 90,000 ppm. I have taken samples ranging from 60,000 to 240,000 ppm. I’m on the road now and for every six samples I take, four are hot.”

PCBs have a range of toxicity and vary in consistency from thin, light-colored liquids to yellow or black waxy solids. Due to their non-flammability, chemical stability, high boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications.

For a scientific overview of PCB caulking, we spoke with Ann Casey, technical services manager at NEA-Pace Analytical Service. NEA-Pace operates a state-of-the-art 15,000 sq. ft. laboratory in Schenectady, New York that is home to some of the most advanced PCB analysis in the world. “PCBs were pretty much used in everything. Everyone always points to transformers and capacitors. Fifty percent of Monsanto products did go to that, but where did the other 50 percent go? That’s the part people miss. They are in caulk, floor tile, ceiling tile, paints, wire, ballasts and in gymnasium floors because of the varnishes and oils.”

In 2006, primary school districts began to find PCB in caulk. Since the mid-1990s the New York State dormitory authority that oversees the state university system has been looking at caulk “It greatly concerned people to find a piece of caulk that has 250,000 ppm or 25 percent of its weight PCBs. That’s huge. You have to start worrying about how much contact people are having with PCBs and if it’s getting into the air and the soil around the buildings,” said Casey. (For soil, the clean up standard in New York State is 1 ppm PCB).

“There are a lot of rules and regulations out there, but it depends on how they are applied. It’s different in every state. The only thing that supersedes everything is the federal Toxic Substance Control Act (TOCA). If it exceeds the 50 ppm rule, it’s considered hazardous waste and you are required by law to treat it as such,” Casey added. This is where it becomes difficult for contractors. You can’t tell by looking at caulk if it’s contaminated. It must be tested.”

What if debris is not tested and it is refused at a landfill because it’s greater than 50 ppm?

“That’s what happened with school districts,” reported Casey. “We’ve had contractors that have done window jobs and then find PCBs well above 50 ppm. They have contaminated the soil around the building and inside the school. Now you have to find out where the PCBs are coming from (caulk, light ballast, paint floor or ceiling tiles) and how far the contamination has spread. That can be costly. I tell contractors to always take samples before starting a job. Some sample indoor air and if the air higher than 100ng/m3, the job changes. Some just test the caulk and wipe samples. If PCBs are greater than 50 ppm in a solid they have to go into what is being called asbestos protocol. Most contractors are heeding the warning, but, unfortunately some are not.”

The cost for a basic caulk analysis at NEA is approximately $75, which includes a report. “We’ve had clients that tested 10 windows in a row that were screaming with PCBs. Then the next four windows had absolutely nothing, and then it goes back to screaming with PCBs. We’ve done thousands of caulk samples. Generally, if there are PCBs it’s usually over 50 ppm. “In paints, we found PCBs up to 700 ppm,” and in air samples it has been well over 1000 ng/m3,” said Casey.

According to the EPA, PCBs have been shown to cause cancer in animals and a number of serious non-cancer health effects on the immune system, reproductive system, nervous system, endocrine system and other negative health effects. At this time, the EPA only goes as far to say that PCBs are potentially cancer-causing and can cause other harmful effects in humans. Numerous independent research studies have demonstrated ill health effects in humans.

“You look at some caulk and it looks brand, spanking new and it was put in 35 years ago.” Casey elaborated: “While it’s still holding its integrity, it has contaminated other materials around the caulking with greater than 50 ppm. We’ve seen that again and again in wallboard, brick, masonry, oils, varnish and in adjacent soil. It’s all contaminated. What we don’t understand as a scientific community, is how the PCBs are moving through the caulk into the surrounding materials and getting into the air. This isn’t like lead or asbestos where it travels on dust particles, it actually goes into a vapor form in indoor areas of classrooms or other buildings being tested. That’s where it starts to become really scary…what it’s generating into the air and what our kids are being exposed to.”

Enterprise Network Resolutions Contracting (ENRC) in Winslow, New Jersey is a toxic substance remediation and waste management company in business for 25 years. Ted Budzynski, CEO, said that ENRC finds PCB levels in caulk below 50 ppm most all of the time, but he related a cautionary tale on the consequences of contamination. “PCB oils are often found in the make-up of concrete and brick. That has become a major issue in New Jersey. What changed the landscape of concrete-masonry waste management in 2007 was the demolition of an old Ford Motor Company plant in Edison, New Jersey. The demolition contractor took down the plant and recycled the concrete and brick into a by-product which was distributed to about 10 to 15 sites around the state. Someone took samples at one site and found it had PCBs, along with other constituents, that exceed New Jersey non-residential cleanup standards (levels less than 50 ppm), which is fairly high when your clean-up level for residential standards at the time was .49 ppm. The responsible party, a site developer, was required to go back and remediate those sites in some fashion. The bigger problem was the contaminated material was mixed with soil that doubled or tripled the original volume from the Ford Plant. Ford and the developer had to foot the bill.”

“Identifying PCBs in caulking is relatively new and just beginning to be regulated. In the past, we rarely tested for it, but we are starting to do so now,” said Mike Casbon, senior construction manager of Environmental Resources Management, Inc. (ERM). ERM is a global provider of environmental, health and safety, risk, and social consulting services. Casbon is also chairman of the health and safety committee of the National Demolition Association.

“We all knew about PCBs in capacitors, transformers and oils, and we have been removing and cleaning that stuff up for years, but some of the new identifications have to do with caulking issues and landfill investigations that have come up. At the Demolition Association, we have been actively talking about the caulking issue for two years,” said Casbon.

“It’s a very tricky subject. A lot of the states run programs and enforce it in different ways. Texas handles it one way, Minnesota another. There’s no clear enforcement policy in the United States. It’s jurisdiction by jurisdiction. The demolition industry is prepared to handle it, but it’s more of an educational issue for customers asking for demolition. We may have to come back to the customer and say there’s PCB caulking and it has to be handled differently and that’s going to increase costs, on some jobs maybe $50 to $100 thousand dollars, which in today’s economy could make or break a project.”

PCBs in caulking were most heavily used in northern states because the compound facilitated application in cold weather. Besides sealing windows and door frames, heavy applications were applied to masonry expansion joints, stairways, and roof soffits. In warmer states, lower levels of toxicity are often found, or none at all. Testing is the only way to tell. Many laboratories do not have the technology to accurately analyze PCBs.

George Weymouth, the secret agent of caulk sampling, summarized the problem from his standpoint – “PCBs in caulking is a dirty little secret, a widely unrecognized source of PCB contamination. People just don’t want to deal with it because of the money involved for proper removal and containment.”

The opposing view is that PCBs in building materials should be handled properly, but with common-sense, patience and regulations that don’t break the bank.

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