Healthy Indoors Magazine
Issue link: https://hi.healthyindoors.com/i/1216998
have become friable or are subjected to sanding, grinding, cutting or abrading." "Response 6: The stringency of the rule was not increased with the November 20, 1990 revi- sion. The new terms of Category I and II non-friable ACM were added to the rule for clarification that non-friable ACM does not always remain in a non-friable condition." Representative samples of caulking materials from buildings prior to renovation or demolition work should be tested to determine whether the caulk contains asbestos and/or PCBs. The good news for the building inspector is that the time period for the use of both asbestos and PCBs largely overlap, therefore buildings that were built or reno- vated between 1950 and 1980 are the primary years of use that should be considered suspect. For sampling, it is also beneficial that one sample may be collected for both asbestos and PCB analysis. Two sep- arate discreet samples may be collected if desired, how- ever this is not necessary. A sufficient sample size should be collected to ensure the laboratory has enough material to perform both analyses. Take care to ensure that only the caulk is included in the final sample and no other adja- cent materials, such as wood or concrete are collected that may skew the sample analysis results. Physically remove a portion of the caulk material to be tested and place in a Ziploc™ bag or 2 oz. glass jar. Collect at least 10 grams or approximately a 4 inch bead of the caulk material. In most locations and scenarios, Asbestos Containing Material (ACM) is defined as material that contains >1% asbestos of any of the 6 regulated asbestos mineral types (Chrysotile, Amosite, Crocidolite, Anthophyllite, Actinolite and Tremolite). Caulk containing PCBs at levels > 50 ppm is not au- thorized for use under the PCB regulations and must be U.S. EPA. PCBs are currently prohibited from being used in caulk and other commodities (U.S. EPA, 40 CFR 761). How- ever, prior to 1979, PCBs were present in some caulking ma- terials used in the construction of schools and other buildings. Studies have shown that concentrations of PCBs can exceed 1% (10,000 ppm) by weight in some caulk materials. If caulk contains asbestos, the asbestos fibers can be released as the caulk ages. With time, sun exposure and weathering, the material can dry out, break down and be- come brittle and friable. Asbestos fibers can also be re- leased if the caulk is subjected to demolition and renova- tion activities such as scraping, drilling, and sanding and attempts to remove it. If caulk contains PCBs, the PCBs may be released into the air through off-gassing. This may occur when the caulk is intact and undisturbed or if it is deteriorating as described previously. PCBs in the air originating from caulk can then be absorbed into other building materials, creating second- ary sources which can then re-emit PCBs into the air. PCBs in manufactured materials such as caulk may also move di- rectly into adjoining materials, particularly porous materials such as wood, concrete, and other types of masonry. A January 4, 1993 US EPA Clarification letter addressed how EPA's asbestos NESHAP regulation applies to window caulk, glazing compounds, wiring and other similar mate- rials in response to questions submitted to the EPA about whether caulk needs to be removed prior to demolition or renovation activities. EPA responded in that letter as fol- lows; "Response 5: To the extent that window putty con- taining asbestos is a pliable asbestos-containing sealant or mastic that is in good condition, (and therefore, a Category I ACM), it is not required to be removed prior to demolition. However, window putties will become regulated ACM if they Healthy Indoors | 23 Examples of Caulk against building components