C O N T R A C T O R S

Handling PCBs in Caulk 

During Renovation

EPA-747-F-09-004
T

his brochure is meant to provide contractors, 

parents, teachers, and school administrators a 

general overview of the practices a contractor 

should consider when conducting the renovation of a building that has polychlorinated biphenyl 

(PCB)-containing caulk. PCBs were not added to caulk 

after 1978. Therefore, in general, schools built after 1978 

do not contain PCBs in caulk.

Contractors play an important role in protecting public health by helping prevent exposure to toxic PCBs. 

Ordinary renovation and maintenance activities involving 

the removal of PCB-containing caulk and the surrounding contaminated substrate (brick, masonry, cinder block, 

wood, etc.) can create dust that contains PCBs which 

can expose children and adults. PCBs have been demonstrated to cause a variety of adverse health effects, including cancer in animals. PCBs have also been shown 

to cause a number of serious non-cancer health effects in 

animals, including effects on the immune system, reproductive system, nervous system, endocrine system, and 

other health effects.

Consider Testing the Air in Buildings Built Between 

1950 and 1978 to Determine Whether Your School or 

Building May Have PCBs

If school administrators and building owners are concerned about exposure to PCBs and wish to 

supplement the steps recommended in this 

brochure, 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 

and buildings should be especially vigilant in implementing and monitoring practices 

to minimize exposures. 

If PCBs are found in the air, 

EPA will assist in developing 

a plan to reduce exposure and 

manage the caulk. Caulk that is peeling or deteriorating 

may be tested to determine its PCB content. Your EPA 

regional PCB coordinator can direct you to a PCB testing 

lab.

Take Site-Specific Protective Measures

• Be in compliance with occupational protection regulations for contractors. (http://www.osha.gov/OshDoc/

data_General_Facts/ppe-factsheet.pdf).

• Protect building occupants and 

passersby by containing the 

work area to prevent

PCB-containing caulk dust 

from getting into the 

 surrounding environment.

• Determine disposal options 

based on concentration and type 

of material.

• Use replacement caulk/sealant that is free of environmental hazards.

A pilot renovation project may be warranted to verify 

whether the renovation goals can be met. It will allow you 

to compare methods, tools, and protective measures to 

get specific information about their effectiveness and cost.

Before Starting the Job, Consider the Types of Tools 

and Machinery for Removing Caulk

• Manual tools are recommended for soft flexible caulk: 

 Advantages: no dust and no heat. 

 Disadvantages: labor intensive and slow.

• Electric tools are recommended for hardened/brittle 

caulk: 

 Advantages: faster, less labor intensive.

 Disadvantages: generate heat (which can volatilize the 

 PCBs) and dust, requiring added protective measures. 

 Also must consider the potential abrasive effects on 

 sensitive adjoining structures (e.g., wood and metal).

Notify Interested Parties and Plan for Emergencies

• Communicate the goals, type, and length of projects 

and specific behavior rules to the affected groups (PTA, 

school principal, etc.).

• Have an emergency contact list (hospitals, police, etc.).

• Ensure workers are properly trained.

• Prevent unauthorized persons from entering the site.

Take General Protective Measures 

• Ensure workers are properly trained.

• Choose the method that minimizes the amount of dust 

generated.

• Choose methods that protect workers, building users, 

passersby, and the surroundings of the restoration 

project. 

• Use proper containers to hold removed caulk.

• Use gloves and skin protection.

• Use eye goggles.

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• Do not smoke, drink, or eat in the work area.

• Wash hands prior to breaks.

• In dusty work areas, have showers available and 

 separate changing areas so that dust on clothing is not 

 brought home.

• If working with solvents, provide respirators.

Interior Areas

• Cover work areas with plastic.

• Use signs to keep residents and pets out of the work 

 area.

• Remove furniture and belongings, or cover them securely 

 with heavy plastic sheeting.

• Use heavy plastic sheeting to cover floors and other fixed 

 surfaces like large appliances in the work area.

• Improve ventilation and add exhaust fans. Close and seal

 the ventilation system in the work area and, if necessary,

 turn off forced-air heating and air-conditioning systems.

• Regularly clean the work area with an industrial HEPA 

vacuum and by wet mopping.

• Properly dispose of personal protective equipment and 

cleaning material.

Exterior Areas

• Mark off the work areas to keep non-workers away.

• Cover the ground.

• Enclose scaffolding. 

• Cover the ground and plants with heavy plastic sheeting. 

• Close windows and doors near the work area. 

• Move or cover play areas near the work area. 

Leave the Work Area Clean

On a daily basis you should:

• Put trash and debris in heavy-duty plastic bags. 

• Wrap waste building components, such as windows 

and doors, in heavy plastic 

sheeting and tape shut. 

• Ensure that everything, 

including tools, equipment, 

and even workers, is free of 

dust and debris before leaving the work area. 

• HEPA vacuum the work 

area. 

• Remember, you do not 

want to bring PCB dust home 

and expose your family. 

• Remind residents to stay out of the work area. When the 

job is complete, you should also:

 - Remove the plastic sheeting carefully, mist with water, 

 fold dirty side in, tape shut, and dispose of it. 

- HEPA vacuum all surfaces, including walls. 

 - Wash the work area with a gen-

 eral purpose cleaner. 

 - Check your work

 carefully for dust 

 because haz-

 ardous amounts 

 may be min- 

 ute and

 not eas- 

 ily visible. If 

 you see any dust 

 or debris, then 

 reclean the area. 

Dispose of Renovation Waste Materials that Contain 

PCBs in Compliance with the Toxic Substances Control Act (TSCA)

• PCB-containing caulk is considered PCB bulk product

waste if the concentration of PCBs in the caulk is greater 

than or equal to (≥) 50 parts per million (ppm). 

• If PCBs have contaminated either the surrounding building materials or adjacent soil, these materials are considered PCB remediation waste. 

Disposal Options

PCB bulk product waste:

The disposal of PCB bulk product waste is regulated 

under 40 CFR § 761.62 of TSCA. Under this provision, 

PCB bulk product waste must be disposed of in one of two 

ways: disposal in a permitted solid waste landfill or via a 

risk-based disposal approval process. 

Disposal in solid waste landfills. Certain PCB bulk 

product waste, such as PCB-containing caulk, even if the 

concentration of PCBs in the caulk is ≥ 50 ppm, may be 

disposed of in non-hazardous waste landfills permitted by 

states. Disposal under this option does not require you to 

obtain approval from EPA. 

Risk-based option. The risk-based option allows for a 

site-specific, risk-based evaluation of whether PCB bulk 

product waste may be disposed of in a manner other than 

under the performance-based disposal option or the solid 

waste landfill disposal option. Disposal of PCB bulk 

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Office of Pollution Prevention and Toxics

United States Environmental Protection Agency

Washington, D.C. 20460

September 2009

Recycled/Recyclable

Printed with Vegetable Oil-Based Inks on Recycled Paper 

(Minimum 50% Postconsumer) Process Chlorine Free

product waste under this option requires you to obtain 

approval from EPA based on a finding that the disposal will 

not present an unreasonable risk of injury to health or the 

environment.

PCB remediation waste:

The disposal of PCB remediation waste is regulated under 

40 CFR § 761.61 of TSCA. There are three options for 

management of PCB remediation waste: 

Self-implementing cleanup and disposal. The selfimplementing option links cleanup levels with the expected 

occupancy rates of the area or building where the contaminated materials are present. The disposal requirements for 

the self-implementing regulatory option vary based on the 

type of contaminated material and concentration of PCBs in 

the materials, among other things. Cleanup and disposal under this option requires you to notify your EPA Regional PCB 

Coordinator (http://www.epa.gov/osw/hazard/tsd/pcbs/pubs/

coordin.htm). 

Performance-based disposal. The performance-based 

option allows for disposal of the contaminated materials in 

either a TSCA chemical waste landfill or TSCA incinerator, through a TSCA-approved alternate disposal method, 

under the TSCA-regulated decontamination procedures, or 

in a facility with a coordinated approval issued under TSCA. 

Disposal under this option generally does not require you to 

obtain approval from EPA. 

Risk-based cleanup and disposal. The risk-based option 

allows for a site-specific evaluation of whether PCB remediation waste may be cleaned up or disposed of in a manner 

other than the alternatives provided under the self-implementing or the performance-based disposal options. Disposal of PCB remediation waste under this option requires 

you to obtain an approval from EPA based on a finding that 

the disposal will not present an unreasonable risk of injury to 

health or the environment.

Additional Information on EPA’s Website 

(www.epa.gov/pcbsincaulk/)

EPA has developed an informational brochure and fact 

sheets to provide building owners and managers with key 

information on the current best practices for addressing 

PCBs in caulk. You can find these documents at 

http://www.epa.gov/pcbsincaulk/ : 

Preventing Exposure to PCBs in Caulking Material

(http://www.epa.gov/waste/hazard/tsd/pcbs/pubs/caulk/

caulkexposure.htm)

Fact Sheet: Testing for PCBs in Buildings (http://www.epa.

gov/osw/hazard/tsd/pcbs/pubs/caulk/caulktesting.htm)

Fact Sheet: Interim Measures for Reducing Risk and 

Taking Action to Reduce Exposures (http://www.epa.gov/

osw/hazard/tsd/pcbs/pubs/caulk/caulkinterim.htm)

Fact Sheet: Removal and Clean-Up of PCBs in Caulk 

and PCB-Contaminated Soil and Building Materials

(http://www.epa.gov/osw/hazard/tsd/pcbs/pubs/caulk/

caulkremoval.htm)

Fact Sheet: Disposal Options for PCBs in Caulk and PCBContaminated Soil and Building Materials (http://www.epa.

gov/osw/hazard/tsd/pcbs/pubs/caulk/caulkdisposal.htm)

EPA is Helping to Address the Issue of PCBs in Caulk

EPA is conducting research on how the public is exposed 

to PCBs in caulk and on the best approaches for reducing exposure and potential risks associated with PCBs in 

caulk. Where PCBs have been found in the air, soil, or in 

the caulk and other building materials, EPA is committed 

to helping schools and communities enact plans to reduce 

exposure. Please contact your regional PCB coordinator 

at 888-835-5372 for help with assessing contamination 

and exposure and developing cleanup plans.

Where Can I Get More Information?

For more information on how to properly test for and 

address PCBs in caulk, contact the Regional PCB 

Coordinator (http://www.epa.gov/osw/hazard/tsd/pcbs/

pubs/coordin.htm) for your state. For more detailed 

information on renovation and removal, go to http://www.

epa.gov/pcbsincaulk/ or call the PCBs in Caulk Hotline at 

888-835-5372.

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