Skip to main content

New Pre-Demolition PCB Regulations in the Bay Area

Sampling and abatement compliance requirements

As a property owner or developer, being complaint with local rules and regulations is of the utmost importance when you are altering your property, most especially if you are going to demolish the entire building.

If you are demolishing a building in the San Francisco Bay Area * and/or your building constructed or remodeled between January 1, 1950 and December 31, 1980 you are likely to be affected by the new Polychlorinated Biphenyl (PCB) pre-demolition regulations spearheaded by the Bay Area Stormwater Management Agencies Association (BASMAA) that became effective on July 1, 2019.  These regulations were immediately adopted and enforceable by local counties and cities in the bay area.  These regulations require sampling for high priority PCB-containing building materials that when identified must have a protocol for abatement during demolition and a permit must be obtained to conduct this work.   Currently, the BASMAA regulatory guidelines are being enforced by the following governmental bodies, including, but not limited to:

  • Alameda County
  • Contra Costa County
  • San Mateo County
  • Santa Clara County
  • City of Vallejo
  • City of Fairfield
  • Suisun City

*Exempt buildings include those that are wood frame and single-family residential homes

Why are PCBs a problem?  What is this regulation trying to prevent?

Polychlorinated biphenyls (PCBs) are a class of chemical congeners where Chlorine atoms are substituted for hydrogen on the biphenyl structure.  PCBs have previously been used in building materials and other applications due to their chemical stability, low flammability and electrical properties.  However, it is these properties that lead PCBs to be environmentally persistent when released in an uncontrolled way into the environment.  Once in the environment, PCBs can contaminate and be absorbed into the food chain and potentially ingested by humans.  The new BASMAA guidelines attempt to prevent or reduce stormwater runoff of PCB residues into the San Francisco Bay from building demolitions and bioaccumulation in edible fish.

So why are PCBs a problem? Based on animal studies, the USEPA and Department of Health and Human Services consider PCBs to be a probable human carcinogen.  Additionally, certain PCBs are classified by the International Agency for Research on Cancer (IARC) in 2013 as a Group 1 Carcinogen (i.e., carcinogenic to humans) based on an increased risk of melanoma in humans.  The other health effects from exposure and doses of PCBs are outlined by the Agency for Toxic Substances and Disease Registry. PCBs have been recognized as toxic to humans and the environment and have been regulated by the Toxic Substances Control Act since 1976 and manufacturing them has been banned since 1979.

How do I comply with the BASMAA guidelines?

In order to get a building demolition permit, an applicant must conduct a “PCBs in Priority Building Materials Screening Assessment” which includes a determination of the guidelines applicability to the structure, the results of a sampling survey including priority building material PCB concentration and the approximate amount of materials containing equal to or greater than 50 ppm of PCBs.  If PCBs are present in concentrations above the threshold criteria in one or more of the materials sampled, you must comply with all related applicable federal and state laws which may include regulator notification and additional sampling and abatement of PCB priority building materials as well as removal, handling, and transport of PCBs-contaminated materials, PCBs-contaminated liquids and PCBs Waste.  A copy of the BAASMA guidelines is provided at basmaa.org

Where am I most likely to find PCB containing materials in my structure?

Priority building materials as defined by the BAASMA guidelines include:

  • Caulking
  • Thermal/Fiberglass Insulation
  • Adhesives/Mastics
  • Rubber Window Gaskets

Sampling of suspect priority building materials is required as those material wastes would be considered regulated if the concentration exceeds the established threshold criteria of 50 parts per million (ppm). Additionally, some of these PCB bulk product waste materials are able to leech PCBs into substrates in contact with the priority building materials which may require further sampling and removal under EPA/CCR Title 22 regulations.

Who do I need to help me comply?

It is important to consider hiring e a knowledgeable health, safety and environmental (HSE) consultant to comply with all applicable laws and regulations regarding building demolition as it relates to not only PCBs, but other regulated materials such as asbestos, lead and other regulated contaminants.   A knowledgeable HSE consultant will be able to develop and conduct a sampling plan according the BAASMA and other applicable sampling requirements as well as help develop documentation as part of the demolition and associated permitting process(es).  They can also collaborate with regulators to ensure that sampling protocols and procedures areconducted in accordance with federal, state, and local oversight agency requirements. Finally, should abatement be necessary, an HSE consultant can coordinate and develop management plans for regulated PCB removal and disposal that should include project oversight and verification and surface area/ work area air sampling to ensure PCB contamination is not spread.