PCB-Containing Building Material Management

The PCB‑Containing Building Material Management Program applies to Penn State employees, students, contractors, and visitors who work in or occupy University buildings that may contain polychlorinated biphenyls (PCBs) in building materials.

PCBs were widely used in construction materials prior to the 1979 EPA ban, and many University buildings constructed during that period may contain PCB‑containing components such as:

• Caulks and joint sealants
• Glazing compounds and window systems
• Adhesives and other elastic building materials

Penn State’s policy is management in place, meaning PCB‑containing materials are left undisturbed and are only handled or removed when they are:

• Damaged or deteriorated, or
• Affected by renovation, maintenance, or demolition activities

The program exists to protect building occupants, workers, and the environment and to ensure compliance with applicable EPA, PA DEP, and OSHA regulations governing PCB‑containing building materials.

General Requirements

• PCB‑containing building materials must not be disturbed unless approved and coordinated through Environmental Health and Safety (EHS).
• Work on suspected or known PCB‑containing materials may only be performed:
  • During approved renovation, maintenance, or demolition projects, and
  • By qualified and pre‑approved contractors or personnel coordinated through EHS.

Responsibilities of Safety Officers, Facility Coordinators, Managers, and Supervisors

• Ensure employees do not disturb PCB‑containing or suspect materials during routine activities
• Promptly address reports of damaged or deteriorated building materials
• Contact EHS before any renovation, maintenance, or demolition that could impact PCB‑containing materials
• Coordinate inspections, surveys, or assessments as required

Responsibilities of Employees, Students, and Contractors, All building occupants and workers must:

• Not disturb caulks, sealants, or other suspect materials
• Report damaged or deteriorated building materials to supervisors or maintenance contacts
• Follow EHS guidance and project controls when working in affected areas

EHS Program Oversight Environmental Health and Safety provides or coordinates:

• Inspections, surveys, and hazard assessments
• Contractor and consultant pre‑qualification
• Project planning, specifications, and oversight
• PCB sampling, data management, and waste flow coordination

PCB‑containing materials are managed in accordance with Toxic Substances Control Act (TSCA) requirements and applicable state and federal regulations.

• PCB Program Document
• Appendix A - Suspect PCB List
• Appendix B - PCB Disturbance and Emergency Response Procedure
• Appendix C - EHS Contractor Pre-Qualification Requirements
• Appendix D - OPP Contractor Pre-Qualification Requirements on the OPP website
• Appendix E - PCB Waste Flow Chart

Access Documents on SharePoint

EHS provides or coordinates the following services or components of the program:

• Inspections, surveys and hazard assessments (Contact: Steve Rohrbach [primary] or Brett Eddinger [backup]).
• Contractor project design, cost estimating, specification / bid document preparation, planning (Contact: Steve Rohrbach [primary] or Brett Eddinger [backup]).
• Contractor prequalification, in conjunction with OPP (Contact: Steve Rohrbach).
• Consultant prequalification (Contact: Steve Rohrbach/Brett Eddinger).
• Project and sample data management (Contact: Steve Rohrbach/Brett Eddinger )

Other website resources:

• U.S. Environmental Protection Agency (EPA) – PCBs in Building Materials Federal guidance on managing PCBs in older buildings
• Pennsylvania Department of Environmental Protection (PA DEP) - State environmental compliance requirements
• Occupational Safety and Health Administration (OSHA) - Worker safety requirements related to PCBs