Determine PCB testing and disposal obligations for caulk and light ballasts before demolition under 40 CFR 761

Steps

1. Screen for PCB risk based on building age: caulk applied roughly 1950-1979 may contain PCBs (EPA guidance cites concentrations up to ~40%), and fluorescent light ballasts manufactured through 1979 may contain PCBs in their small capacitors
2. Before demolition, sample representative caulk and other suspect sealants/coatings and have them tested for PCB concentration
3. If tested material is at or above 50 ppm PCBs, manage and dispose of it as 'PCB bulk product waste' under 40 CFR 761.62, which generally requires disposal in an EPA-approved chemical waste landfill or permitted hazardous waste landfill
4. For fluorescent ballasts: an intact, non-leaking ballast containing PCBs only in the small capacitor may be handled/disposed of under 761.60(b)(2)(ii); a ballast with PCBs in the potting material is instead regulated as PCB bulk product waste under 761.62 — inspect for leakage before selecting a disposal path
5. Reference EPA's 'PCBs in Building Materials' guidance (epa.gov/pcbs) alongside the Part 761 regulatory text, since the regulation alone does not walk through the practical building-materials sampling workflow