What's in the Caulking?

Picture this: you have been planning long overdue, extensive repairs and renovations that will transform an aging campus building into a modern, comfortable classroom building or dormitory. You have laid out plans to replace windows and repair masonry, and you have the summer to finish the project. Then you get a call from your campus environmental department: Do you know if the caulking on this building contains PCBs? Suddenly a shadow of uncertainty falls over your plans.

Recent media attention and public awareness have brought polychlorinated biphenyls, or PCBs, into the spotlight, focusing on their regulatory status and potential risks to human health. PCBs were often used in the manufacture of certain building materials, such as caulking, from the 1950s through the 1970s. Many colleges and universities own buildings constructed or renovated during this period, and many of these buildings may be on your list of facilities scheduled for repairs, renovations, or demolition. PCBs have been found in caulking at concentrations in the hundreds of thousands of parts per million, which is on the order of 10 percent or more of the total volume. If PCBs should be discovered once a project is underway, it can mean delays in schedule, added costs, and potentially damaging publicity.

How can you account for the potential presence of PCBs in caulking? Whether you are replacing a broken window or are planning a major renovation, you should know when PCBs could be a concern and be prepared to implement a series of proactive steps in the early phases of planning a project.

Where Do PCBs Turn Up?
PCBs were used in the production of some types of caulking from the 1950s through the 1970s for added strength and flexibility. Typical caulked joints can include exterior joints around window frames, between precast concrete panels or cast in-place slabs, joints where a vertical building face terminates at a paved ground surface, or joints between two different construction materials such as a brick wall abutting a concrete column or a metal panel. In addition to the typical expansion joint or window locations, the use of caulking or sealants is not uncommon in roof construction, interim masonry repairs, and certain interior locations such as windows, doors, or elevator shafts.

If a building has been constructed or renovated using PCB-containing caulking, PCB impacts may not be limited to the caulking itself. Through natural mechanisms such as weathering, leaching, or deterioration, PCBs may be found in the materials adjacent to the caulking, including concrete, brick, or metal surfaces. PCBs have also been known to impact the ground surfaces surrounding a building, including soils or paved areas. At interior locations, PCBs can impact surfaces and indoor air.

Should I Be Concerned?

The first question you are likely to ask is, “If I have PCBs at my building, should I be concerned?” The short answer is, yes. The concern is threefold: the health and safety of building occupants and workers; potential project impacts due to required PCB abatement (schedule, costs, etc.); and, regulatory and enforcement implications.

Potential risks to human health via direct contact, ingestion, or inhalation can include damage to the immune, reproductive, nervous, and endocrine systems, typically after prolonged exposure to high concentrations of PCBs. If a renovation or repair project will involve the disturbance of PCB-containing caulking, consideration must be given not only to protecting the health of the personnel completing the work, but also to protecting the health of building occupants, employees, visitors, and passers-by. Will the work require a remediation contractor to set up work zone enclosures and use respiratory protection? Can the building continue to be occupied during the work? Do any outdoor areas need to be placed off-limits until PCB-impacted ground surfaces can be remediated? These are just some of the questions to think about if a project involves PCBs.

In addition to the human health and project impact aspect, another concern is compliance with Environmental Protection Agency (EPA) and state regulations. PCBs are regulated under 40 CFR Part 761: PCBs Manufacturing, Processing, Distribution in Commerce, and Use Prohibitions. The continued use of caulking containing PCBs at concentrations greater than or equal to 50 parts per million is prohibited by 40 CFR 761, and the unauthorized use of caulking at these concentrations is regulated by the Toxic Substances Control Act. Depending on the PCB concentration, a material can also be designated as a state hazardous waste, and certain materials such as soil can also be regulated under a state remediation program. If PCB caulking and/or adjacent impacted materials are removed from a building (i.e., turned into waste), improper management or disposal of the waste could potentially result in EPA and/or state enforcement actions or other penalties.

What to Do About PCBs
A series of proactive steps can be taken to prepare for the possibility that a campus building could be subject to work that may disturb caulking materials, whether the work is scheduled in advance or is completed as an emergency repair.

Take Stock. Inventory your properties, compile a list of original construction dates and the dates of any renovations, and create a priority list that can be compared to future facility plans, keeping in mind that a residence hall or childcare facility may warrant a higher ranking than a building used for office space. Note that while PCBs were most commonly used in caulking manufactured between the 1950s and the 1970s, this does not eliminate the possibility that PCB caulking may have been used in older buildings if repair or renovation work was completed during the era of PCB caulking use. It is less likely that any building constructed after 1980 would contain PCB caulking.

Conduct Visual Assessments. Do any buildings retained from your property inventory have caulking that appears to be deteriorated or shows any other signs that it may be due for replacement soon? PCB caulking manufactured half a century ago can often still be intact and appear to be in very good condition; however, in some cases, caulking in very poor condition may be brittle, peeling, or missing from the joint entirely. While this assessment step cannot be used as an indicator of whether PCBs are present, it can be a useful project prioritization tool.

Know the Regulations. If you don’t have someone on staff that is familiar with the PCB regulations, consider bringing in an expert who can help you understand the implications of finding PCBs and how they may impact your project. This person can also help you determine if and when it may be appropriate to collect samples for laboratory analysis. If you’re looking to learn the basics or to read up on the latest guidance, go to the EPA Website on PCBs in caulking, which includes background information, testing recommendations, and several fact sheets.

Plan Ahead. What are your campus renovation or demolition plans in the next few years? Are any of these buildings considered suspect for PCBs based on your assessments? If so, make other parties involved in the project planning process aware of this possibility as early as possible. If the scope of work involving caulking disturbance is small in comparison to the total project scope, increased costs may be negligible in the event that PCB remediation work is required. If the scope of work is heavily dependent on caulking removal (if window replacements or waterproofing needs are driving the project, for example), it may be prudent to consider potential impacts to the project’s schedule and budget if PCBs are in fact present in the caulking.

Have an Emergency Plan. If you need to complete an emergency repair project that will involve caulking disturbance and you are unsure if the caulking contains PCBs, have a plan prepared to handle these situations. For example, a qualified contractor or trained personnel could conduct the project and manage all materials as though PCBs were present. Be sure to adequately characterize the material before it is sent off-site for disposal, and talk to your campus environmental department about the next steps to take if PCBs are found.

PCBs can derail even the most well-planned building repair or renovation project. If provisions are not made to properly address this issue, colleges and universities can face unexpected delays, increased project costs, and potentially negative publicity. By taking a proactive approach and following the steps above, you can stay ahead of the situation and bring your projects to a successful conclusion.

Amy Wallace is an environmental engineer for Woodard & Curran in Andover, MA, specializing in remedial design and implementation, with a particular focus on the investigation and remediation of PCBs in building materials. For more information visit www.woodardcurran.com.