OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

November 3, 1986

MEMORANDUM FOR REGIONAL ADMINISTRATORS

 

 

THRU: JOHN B. MILES
Director
Directorate of Field Operations
 
FROM: EDWARD J. BAIER
Director
Directorate of Technical Support
 
SUBJECT: Information on Polychlorobiphenyls (PCB's) in Ceiling Tiles

 


On October 11, 1985, the Public Employees Occupational Safety and Health (PEOSH) Project of the New Jersey Department of Health (DOH) was informed by a hazardous waste cleanup contractor, O.H. Materials, of the presence of PCBs (Arochlor 1254) at Burlington County College, Pemberton, New Jersey.

This hazardous waste cleanup contractor was hired by Burlington County College to decontaminate one wing of a large multi-purpose building. The A wing of the Parker Center building had been contaminated with mercury, nitrobenzene and pyridine after a fire occurred in the chemical storage vault on August 25, 1985. During chemical characterization of the fire-contaminated debris, gas chromatographic-mass spectrographic analysis revealed PCB levels of 750 ppm. Further sampling by the contractor revealed PCB levels of 2000 ppm in lubricating grease from an air handling unit. PCB levels were not limited to the A wing but were found in the air, on surfaces and in bulk samples of grease and ceiling tiles of the building (B, C and D wings).

The New Jersey Department of Health continued sampling through January 1986, including side by side sampling with O.H. Materials and the National Institute for Occupational Safety and Health (NIOSH) was requested by the New Jersey Health Department to help determine the source and further assess the extent of contamination and the effectiveness of cleanup in the B, C and D wings. OSHA was also contacted.

Numerous samples were taken showing the presence of PCBs. Testing results are attached for your information.

Meetings were held with representatives from Armstrong World Industries, Inc., the manufacturer of the ceiling tiles, on March 24, and April 1, 1986. Information obtained from Armstrong indicates that Arochlor 1254 was added to a prime coating formulation used in three types of ceiling tiles, Travertone Sanserra, Santaglio and Embossed Design, manufactured at Beaver Falls, Pennsylvania approximately between 1969-1970. It was later determined from Armstron that only the Travertone Sanserra tiles were sold. These tiles were determined to be a possible source of the PCBs in the building; however, OSHA has not verified this.

It would be useful if your staff members are made aware of this information; however, identification of these ceiling tiles on sight by CSHO's is not readily possible because there is no clear physical difference between the ceiling tiles in question and other types without PCBs presently in place. We will keep you informed of any future information we may receive which is pertinent to this matter.