The problem is that EPA has known forever that the old paints, caulks, plastics, gaskets, roofing felts, and a hundred other building materi als were just as likely to contain PCBs as the were likely to contain lead.   Yet for the last 30 years, all that old abated lead stuff has no t been tested for anything but lead.  And most of this lead waste wa s exempted from regs and could go into ordinary landfill.

I know because I read the paint and coatings journals regularly in the 1970 s when the industry was still using them and screaming against the regulati ons that would ban them.  And I watched as they cynically substitute d the polybrominated biphenyls for PCBs until the incident in Michig an when PBBs got into the food chain.  That human experiment proved the PBBs provoked the same kind of acne and hair loss that PCBs did.  ; Lord knows what it did to them chronically.

And now the paint and plastics industries are still using the polybromin ated biphenyl ethers, although some are on the Prop 65 list, some are banned in the EU, and the rest need study.  So I am conc erned about an even bigger problem.

But I digress.  Back to PCBs.  In 1999 EPA published in the F R a huge list of PCB sources in older buildings with some rough information on the percentages in the products, and a discussion about actually doin g something about them.  Many of the early polymer paints, for exa mple, contained 10-30% PCBs! 

And that's about when EPA wrote the publications about removing ballasts.&n bsp; While that nice EPA publication that Rod Toreki referenced has a Dec ember 2010 "update" on it, most of it was written much before that and it has been sitting around absorbing lead dust and PCBs of it's own.

I think EPA just didn't want to deal with this.  Every day they igno red it was one more days-worth of lead/PCB waste that would be in the trash that they wouldn't have to consider or regulate.  But anyone who kn ows how to read could easily find out that the PCBs were in many materials in older buildings including schools in amounts that could be hazardous to occupants--and that regulation was needed.

Whew, I feel a lot better now, thanks.

Monona

In a message dated 1/10/2011 4:40:38 PM Eastern Standard Time, don.long**At_Symbol_Here**W GINT.COM writes:

Gotta start somewhere.

Anybody remember asbestos?? Removal of that has created an entire industry.

Don A. Long
STS, CAIH
Southwest Research Institute Laboratory
Pine Bluff Chemical Agent Disposal Facility
PO Box 20130
White Hall, AR  71612
870-541-4930