PCBs: The New Asbestos?

Just as asbestos became a pariah in the building industry in the 1980s, PCBs have become so now. The U.S. Environmental Protection Agency has imposed strict and lengthy regulations on the management, clean up and disposal of PCBs (polychlorinated biphenyls), compounds that are man-made organic chemicals and were widely used from the 1930s until they were banned in the late '70s.

Still, those in the construction industry are not always clear on proper management of materials containing PCBs. But failure to comply with PCB regulations can lead to devastating losses in time and money, leaving project managers scrambling to learn the ABCs of PCBs quickly.

The popularity of these compounds, labeled a likely carcinogen by health officials, stemmed from useful properties such as non-flammability and electrical insulation. PCBs were used in the production of hundreds of products such as fluorescent light ballasts, paints, caulking, mastic and other adhesives, plastics, rubber, and more. Buildings that were constructed or renovated between the '30s and '70s are likely to contain building materials containing PCBs.

Before the danger was known, PCBs entered the environment simply by their manufacture and general use. But today, improper disposal, product leaks, and the burning of debris containing PCBs all continue to contribute to the levels found in the air, water and soil. Once in the environment, PCBs may remain for long periods of time and have been known to travel long distances, as they do not readily break down. PCBs can enter the human body through skin contact, the air, drinking water and most commonly through consumption of certain foods such as fish, poultry and red meat. PCB exposure at high levels has been linked to a variety of serious health issues, ranging from damage to the immune, reproductive, neurological, endocrine systems, and liver and cause cancer.

In 1976 the TSCA (Toxic Substance Control Act) banned the manufacturing, processing, and distribution of PCBs. However, it did not limit the use of products already manufactured. Now, decades later, as buildings from this PCB era are demolished and renovated, building owners and construction companies are faced with the problem of cleaning up and disposing of PCB debris.

The TSCA took effect in 1979, authorizing the EPA to regulate and control PCBs (and other toxic substances). The current PCB regulations can be found in the Code of Federal Regulations (CFR) at 40 CFR 761. (To learn more, visit www.epa.gov/pcb/.) For those in the construction industry, staying on top of the regulations is essential as one misstep can have serious financial consequences. The EPA has designated regional PCB coordinators for each area of the country who can answer questions. Construction firms can also turn to environmental laboratories and remediation firms that know the ins and outs of PCB regulations. A qualified remediation firm will know whether PCB testing is required or if the area would be best left intact, per federal regulations. A certified laboratory will know which PCB extraction and analysis methods are accepted by the EPA.

In many cases, it is not required by law to test for PCBs. Many companies know that if they don't test, then they will not be regulated, and this of course is an attractive option, as following PCB regulations will almost always add time and cost to a project. If a company does decide to test, and the results come back positive for high levels of PCBs, they will have to follow all federal regulations for proper PCB clean up and disposal. This can make a simple window replacement job turn into major renovation.
However, the companies that choose not to test for PCBs should be aware that if a waste disposal site finds PCB contamination in the company's waste, the company is responsible for all associated costs and liability. There have been cases of companies having to go back and dig PCB waste out of a landfill for proper disposal at a hazardous waste facility.

Compliance may be tedious, but non-compliance could be devastating, not only to a project or business, but also to the environment. It will certainly be an issue construction companies and building owners will be contending with for years to come.

Guy Sylvester is CEO of Absolute Resource Associates and Jean Gennaro is director of marketing for the environmental services firm in Portsmouth. For more information, call 603-436-2001 or visit www.absoluteresourceassociates.com.