Three Steps to Managing PCB Risk
In the past 30 years, management of polychlorinated biphenyls (PCBs) has ranked among the top concerns of U.S. manufacturers and regulators. Though regulatory guidance is clear on what to do with known sources of PCBs, companies are not likely to test for the toxics unless they are believed to exist on the company's premises.
PCBs have surfaced on plant properties in recent years through a surprising source-paint on industrial equipment. Concentrations of PCBs that far exceed EPA limitations have been found in industrial paints and occur on many types of common industrial equipment, from furnaces and hydraulic equipment to lathes and presses. Other potential sources of PCBs include oil reservoirs and sumps.
PCBs are more prevalent than many plant managers realize, and strategies must be established for managing the risk.
Talk to the Regulators
U.S. EPA Toxic Substances Control Act (TSCA) division representatives provide guidance on identifying and managing equipment suspected to contain PCBs. By gaining a good understanding of the myriad regulations that must be followed, managing PCBs will seem manageable. The U.S. EPA has a very informative website with links to many other sites at http://www.epa.gov/pcb.
OSHA is responsible for the health and safety of workers who may be exposed to PCBs in the workplace, or in connection with their jobs. OSHA's regulations covering PCB exposure set a maximum exposure limit and include provisions for respirators, protective clothing, exposure monitoring, hygiene facilities and practices, warning signs, labeling, record keeping and medical exams. These requirements can be found in OSHA's General Industry standards (29 CFR 1910) or at http://www.osha.gov.
Understand the Risks
By understanding the risks associated with PCBs, unnecessary hazards can be prevented. Like asbestos, PCBs can become a greater hazard if removed incorrectly, which is the primary concern when addressing painted surfaces.
PCBs were added to plasticzers in paint for good reasons: they helped the paint become resistant to heat, weather and chemical exposure; therefore, safely removing the paint is a challenge. Sandblasting creates dust that must be contained in an enclosure, and personnel must be protected from inhalation and exposure to their skin. Using chemical-based paint strippers can alleviate the potential for dust, but they must be controlled so the spent product and paint waste does not impact the environment.
Educate those who may be working on or near a suspected piece of equipment. Unless exposed through ingestion or inhalation, the risk of adverse health effects can be minimal and by understanding the hazards involved, workers can take the necessary precautions to prevent exposure. Often times, a piece of equipment can be put back into operation or sold for reuse once proper decontamination procedures are completed.
Collect Representative Samples
EPA guidelines for sampling nonporous surfaces are specific, but the main objective is to collect samples that represent the equipment's true characteristics. Initially, samples should be collected in a biased manner, from the places that are most likely to be hot. Oil reservoirs, paint and grease that have accumulated over the years should be the first line of sampling.
For the best advice on how to sample and what to do with the data, contact your local U.S. EPA office. These representatives are responsible for approving sampling and analysis plans and can give direction on proper ways to characterize the equipment. For more details on how to develop sampling and analysis strategies, log onto http://www.epa.gov/pcb and search the regulations for 40 CFR Part 761. Note that some states treat PCBs like hazardous waste. Therefore, you also should confirm any proposed management plans with your state EPA office. The Impact is Real
A recent article by M.L. Lyke of the Seattle Post-Intelligencer indicates that high concentrations of PCBs have been detected in the blubber of killer whales in the Pacific Northwest. These popular whales are now considered to be among the most contaminated marine mammals in the world.
Scientists also have noted tumors, skeletal abnormalities, disease and reproductive problems in contaminated beluga whales on Canada's St. Lawrence estuary, which drains the heavily industrialized Great Lakes, and the Northwest killer whales are four to five times more polluted than those belugas.
An estimated 24-million lb of PCBs still are unaccounted for, and it's time for industrialized nations to do the right thing¿ind them.