PCBs In Caulk Making Headlines

Prompted by the Daily News, NYS Education Department tested several city schools for Polychlorinated Biphenyls (PCBs) in caulk and found six of the nine schools tested positive. However, only one of the schools tested positive for PCBs in the air. As we learned at the Professional Abatement Contractors of New York (PACNY) meeting a few months ago, the NYS Education Department was already requiring new projects impacting window caulk in buildings built between 1950 and 1977 to evaluate the caulk and submit a remediation plan for addressing the caulk (http://www.emsc.nysed.gov/facplan/HealthSafety/PCBinCaulkProtocol-070615.html).

According to the Agency for Toxic Substances & Disease Registry (ATSDR), PCBs may reasonably be expected, and probably can cause cancer of the liver or biliary tract. The Environmental Protection Agency (EPA) classifies PCBs as a Group B2 Probable Human Carcinogen and International Agency for Research on Cancer (IARC) classifies PCBs as a Group 2A, probably carcinogenic to humans. Some animal studies showed that animals that ate small amounts of PCBs in food over several weeks or months developed health effects such as: anemia; acne-like skin conditions; and liver, stomach, and thyroid gland injuries. Human studies, in particular women who were exposed to relatively high levels of PCBs in the workplace or ate large amounts of fish contaminated with PCBs, showed these women had babies that weighed slightly less than babies from women who did not have these exposures. The studies also showed babies born to women who ate PCB-contaminated fish had abnormal responses in tests of infant behavior. According to ATSDR, some of these behaviors, such as problems with motor skills and a decrease in short-term memory, lasted for several years. Other studies suggest that the immune system was affected in children born to and nursed by mothers exposed to increased levels of PCBs. There are no reports of structural birth defects caused by exposure to PCBs or of health effects of PCBs in older children. If you wanted to know if you were exposed to PCBs there are blood tests that can be done. However, everyone has some level of PCBs in their body due to environmental exposure.

There are several websites to get information on this issue which is starting to be recognized by schools, government, and the public. EPA's website has a section on PCBs in caulk: http://www.epa.gov/pcb/pubs/caulk.htm#content. Dr. Daniel Lefkowitz was one of the presenters at the PACNY conference and his website would like to see mandatory testing of caulk in schools is: http://www.pcbinschools.org/. Dr. Daniel Lefkowitz found PCB in the caulk at the school his children went to.

EPA's Region 2 is recommending that samples taken of caulk or soil that will be analyzed for PCBs should use a Soxhlet extraction method (an example of this would be EPA method 3540C) using toluene as a solvent. The extraction should then be purified with concentrated sulfuric acid (similar to EPA method 3665A) and purified with florosil (similar to EPA method 3620B). The purified extraction would then be analyzed by gas chromatography with an electron capture detector (similar to EPA method 8082). The results are to be reported in total PCBs in parts per million (ppm). If the results exceed 50 ppm then those materials are regulated.

If you determine you have PCBs in the caulk or soil you should contact EPA's Region 2 coordinator Mr. Jim Hattler (732-906-6817). Mr. Hattler is willing to assist facility owners in developing a plan on the handling of any materials determined to contain PCBs. He has emphasized that these materials may not need to be removed, but would like to ensure that any clean-ups address all materials containing PCBs (caulk, soil, or its migration into other building materials). EPA is currently in an assistance mode on this matter and is currently developing a guidance document to assist facility owners. EPA's website includes a specific section on PCBs (http://www.epa.gov/pcb/).

Remember when taking samples of PCBs you have to protect yourself from both inhalation and dermal exposures. The OSHA Permisible Exposure Limit (PEL) for PCBs is based on chlorodiphenyl 42% or 52 % chlorine (Table Z-1 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9992). The PEL for chlorodiphenyl (42% chlorine) is 1 milligram per cubic meter or chlorodiphenyl (54% chlorine) is 0.5 milligram per cubic meter. Analysis methods for personal air samples are NIOSH 5503 or OSHA PV2088. OSHA recommends that you wear rubber gloves that will not absorb PCBs and consider using goggles or a face shield (if using a full mask air purifying respirator (APR) the goggles or face shield are not needed) and a rubber apron. Avoid personal contamination by not touching your face while wearing gloves. If you get PCBs in your eyes, irrigate your eyes immediately. If you get PCBs on your skin, wash the skin wth soap and water immediately. The recommended respiratory protection would be a full mask APR utilizing a duo cartridge with protection for organic vapors and having P100 filters. For more information on chlorodiphenyl (54% chlorine) you can visit the National Institute for Occupational Safety and Health (NIOSH) Pocket Guide to Chemical Hazards (http://www.cdc.gov/niosh/npg/npgd0126.html).

News from PACNY's Environmental Conference

As we previously discussed, I was attending the 12th Annual PACNY Environmental Conference. It was an excellant conference that brought out some new developments in the Abatement Industry. Mr. Christopher Alonge, PE of the New York State Department of Labor, was one of the presenters that most people were anxious to hear from and as usual he did not disappoint the attendees. What has become standard practice at this event Mr. Alonge gave those present some food for thought. First, Mr. Alonge announced a new Petition for an Asbestos Variance Form (SH 752) and the possible release sometime in 2008 of two new variances; "Mechanical fastening of items/components or systems - penetrating through non-friable ACM - Not considered an Asbestos Project" and "Small & Minor Size Asbestos Disturbance Cleanup Projects - to be used for cleanup of all types asbestos disturbances". This new Variance form should be on the DOL website this month (the form is currently on our discussion board website at (http://groups.google.com/group/fed-forum/web/new-petition-for-an-asbestos-variance-form-sh-752). Mr. Alonge also announced a new guidance document (v2.0) that should be on the website in the next few months that will have 120 new questions/answers added. Mr. Alonge is also in the process of working on a new ICR56 that will incorporate some Fire & Life Safety Issues (because of lessons learned at the Deutsche Bank Building tragedy) some examples include the use of fire retardant sheathing, negative air disconnect switch, and maintaining existing fire protection systems.

Another interesting presenter was Thomas V. Roberts, RA from NYS Education Department. Mr. Roberts informed us that NYSED developed "Protocols for Addressing Polychlorinated Biphenyls (PCBs) in Caulking Materials in School Buildings" in June 2007 (http://www.emsc.nysed.gov/facplan/HealthSafety/PCBinCaulkProtocol-070615.html). This protocol is recommending that any school buildings constructed or renovated between 1950 and 1977 and undergoing current renovation or demolition, be evaluated prior to the renovation work to determine whether they contain caulk that is contaminated with PCBs. NYSED would require a PCB abatement plan be submitted with the renovation or demolition drawings addressing the potential environmental and public health concerns in abateing the caulk. If plans are submitted without the PCB evaluation, the plans will be rejected.

Maureen Cox, NYS DOL Director of Safety & Health, presented that DOL has seen a 12% increase in penalties collection this past year and would like to see Senate Bill 372 known as Successor Legislation, pass. The point of this legislation would be to prevent the owners of an asbestos abatement company from closing their business to avoid fines and then open under a new company to continue to do abatement work. The legislation would also increase the penalties and fines issued under the Industrial Code Rule 56.

PACNY introduced the PACNY Asbestos Proficiency Initiative, the purpose of this initiative is to create a certification that will be administered by PACNY that will establish another level of certification specifically for Project Monitors, Supervisors, and Project Designers. To be able to take the computer based certification exam, which will be offered through Slyvan Learning Centers, the individual must show three years of DOH 2832s. The exam will be given in two parts, part 1 will be a 50 question closed book exam and part 2 will be an open book scenario-based questions. PACNY Proficiency Certification (PPC) will require the accumulation of 20 hours of certification maintenance each year and the taking of a refresher exam also at the Slyvan center.

The conference as always was very interesting and exhibit had the usual suppliers Grayling Industry showing off the New Larger Pop-up Decon meeting NYS DOL requirements, and Cole Stanton from Fiberlock Technologies who discussed the revision to the use of chemical tools to the S520 standard from IICRC. IICRC stands for the The Institute of Inspection, Cleaning, and Restoration Certification which publishes the S520 Standard and Reference Guide for Professional Mold Remediation. The new standard which should be out before the end of 2008, basically says that unique circumstances may arise allowing the consideration of antimicrobial coatings, or biocides.

The event is usually held at Turning Stone Casino and it appears that next year's event will be around the same time, we hope to see you there next year.