On November 16 2012 the Environmental Protection Agency (EPA) posted the PCB Bulk Product Waste Reinterpretation on the website. The reinterpretation addresses the regulatory status of building debris that has been in contact with non-liquid polychlorinated biphenyls (PCBs), such as PCB-containing caulk and paint. The reinterpretation was published in the context of increased awareness of the presence of PCB-containing caulk, sealants, paint and other materials in public and commercial buildings that were constructed between World War II and the mid-1970s. The EPA asserts that the presence of PCB-containing material in or on a building is an “unauthorized use” of PCBs.
This Sidley Update was republished by ILO in its Trade & Customs Newsletter.