PCB UPDATE: EPA Releases More Information on PCB in Caulk Remediation

From EPA's website
Steps to Safe Renovation and Abatement of Buildings That Have PCB-Containing Caulk

Overview
In recent years, EPA has learned that caulk containing potentially harmful polychlorinated biphenyls (PCBs) was used in many buildings, including schools, in the 1950s through the 1970s. In general, schools and buildings built after 1978 do not contain PCBs in caulk. On September 25, 2009, EPA announced new guidance for school administrators and building managers with important information about managing PCBs in caulk and tools to help minimize possible exposure. Through EPA's Regional PCB Coordinators, the Agency will also assist communities in identifying potential problems and, if necessary, developing plans for PCB testing and removal. The Agency has prepared a a Fact Sheet and Questions and Answers  on this announcement.

The EPA also announced additional research into this issue. There are several unresolved scientific questions that must be better understood to assess the magnitude of the problem and identify the best long-term solutions. For example, the link between the concentrations of PCBs in caulk and PCBs in the air or dust is not well understood. The Agency is doing research to determine the sources and levels of PCBs in schools and to evaluate different strategies to reduce exposures. The results of this research will be used to provide further guidance to schools and building owners as they develop and implement long-term solutions. Read more about Research on PCBs in Caulk.

EPA has calculated prudent public health levels that maintain PCB exposures below the “reference dose” – the amount of PCB exposure that EPA does not believe will cause harm. Read Public Health Levels for PCBs in Indoor School Air.

Is Your Food Service (HACCP) Program Effective?

Craig A. Calvert, Ph.D., C-CHO
May 24, 2010
Welcome to the June issue of the School Safety Newsletter. The September 2009 issue focused on new regulations concerning the school HAACP (Hazard Analysis and Critical Control Points) program. This newsletter will discuss ways to verify that your food safety program is working. We hope that you find this newsletter useful and look forward to providing you with the quality service and information that has made Fuss & O'Neill EnviroScience successful.
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Once a HACCP or similar program is in place verification that the program is working must be done. In fact, step 6 of a HACCP program is “verification of procedures” – which includes microbial sampling and analysis.
 Sampling will look for three types of contaminants
1. Biological – microbes
2. Chemical – toxic chemicals
3. Physical – metal, wood, etc…
 Microbes that should be tested for and verified that they are at safe levels include:

1. E. Coli O157:H7
2. Listeria monocytogenes
3. Staphylococcus aureus
4. Salmonella

 When sampling for there are a number of places to sample to find the three contaminants such as:
1. Food contact surfaces
a. Pans, plates, utensils, mixers, etc…
2. Non-food contact surfaces
a. Floors, doors, steam tables, etc…
3. Air/atmoshpere
a. Water vapor can carry safe concentrations of microbes from the floor into the food
 Uncontrolled growth or a high concentration of any contaminants could be an indication that your food safety program is not adequately addressing the sanitation procedure in your food safety plan.
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Fuss & O'Neill EnviroScience offers services to sample your food service areas for contaminants. These services are designed to compliment your current food safety program. One of our food safety experts will come to your facility to sample, provide interpretation of the results, and discuss next corrective action steps. Fuss & O'Neill EnviroScience has years of experience providing safety services to schools and is extending this experience into food safety.

For more information and questions on how to sample contact:
Craig A. Calvert, Ph.D., C-CHO
ccalvert@fando.com
(860) 646-2469 x5571

UPDATE: Underground Storage Tank – General Requirements

Adam M. Barbash, P.E., CHMM & Craig A. Calvert, Ph.D., C-CHO
April 30, 2010
Welcome to the May issue of the School Safety Newsletter. Underground storage tanks (USTs) play a role in our day-to-day lives by storing the fuel that we use to power our automobiles, heat our schools, and power generators in the event of an emergency. Since USTs are out of sight, we sometimes take for granted their presence and neglect the maintenance and compliance obligations associated with their operation and ownership. Below we have provided some basic information on the maintenance of fuel oil USTs and the compliance obligations associated with their ownership. We hope that you find this newsletter useful, and as always, we look forward to providing you with the quality service and information that has made Fuss & O’Neill successful.
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Most USTs at schools are fuel oil tanks used for heating. Other USTs have additional compliance obligations.
Fuel Oil UST Operation and Maintenance Requirements
• Steel tank systems must have a means of corrosion protection:
o Fiberglass tanks may be exempt; however, piping systems may still be regulated
o Passive or active cathodic protection with monitoring, or an approved isolation method
o Corrosion protection must be tested on an annual basis
Fuel Oil UST Operation and Maintenance Recommendations
• Tank systems should maintain spill and overfill protection in good condition
o Common spill protection devices are spill buckets
o Overfill protection devices include shutoff valves, whistler valves, and automatic gauges
• Release prevention devices and methods should be used on tank systems. Including:
o Interstitial space monitoring; Manual or Automatic tank gauging; Tank tightness testing
UST Closure/Life Expectancy
• All USTs have a life expectancy based on the manufacturer’s warranty and compliance history.
• When tank systems approach their life expectancy they must be:
o Closed in accordance with the applicable regulations which, for fuel oil USTs, must include failure determinations in both the preceding year of the end of the warranty period and 2 years of the warranty period.
o Confirmatory soil sampling for fuel oil USTs used for heating purposes is recommended.
o Removed and replaced
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Fuss & O'Neill offers UST compliance auditing, UST removal and replacement, and environmental sampling and remediation services to meet your facility needs. Non-compliance with UST regulations can result in enforcement and/or costly environmental remediation. Fuss & O’Neill has years of experience with providing schools with UST compliance evaluations, design and installation services, and release response measures and is offering these services to help you establish and/or increase your regulatory compliance.

For additional assistance and information, please contact:
Adam Barbash, P.E., CHMM
abarbash@fando.com
(860) 646-2469 x5534

We look forward to the opportunity to help you in your mission to provide the safest possible food to your students.

For previous newsletters visit: http://www.fando.com/News_&_ Resources/School_Safety_Newsletters/