PCB-containing building materials in a Phase I

A building on the subject property may hold polychlorinated biphenyls (PCBs) in its caulk, paint or fluorescent light ballasts, or such materials have been taken out or the building torn down. The standard sets PCB-containing building materials apart from PCB equipment: the equipment is a site visit item, and the materials are a non-scope consideration (E1527-21, 9.4.18, 13.1.5.12). Whether PCBs from building materials come inside the assessment depends on four things: whether the item is equipment or building material, whether the material is still part of the structure and inside it, whether PCBs have left it for the environment, and what the user has asked for.

What the answer turns on

Equipment or building material. The site visit looks for electrical or hydraulic equipment known or likely to contain PCBs, and the report describes such items, found or not (E1527-21, 9.4, 9.4.18). The same item places fluorescent light ballasts, caulk, paint and other materials that may contain PCBs outside the practice where they are inside the building or structure and part of it, and the non-scope list gives interior ballasts, paint and caulk as its examples (E1527-21, 9.4.18, 13.1.5.12). Equipment is weighed on transformers and equipment that may hold PCBs. For its own purposes the federal PCB rule, 40 CFR part 761, names fluorescent light ballasts and fixtures among its examples of PCB Equipment (40 CFR 761.3); it classifies nothing under the standard.
Still part of the structure and inside it. A note to the site visit item says materials that may contain PCBs and are neither part of the structure nor solely within it may need to be identified (E1527-21, 9.4.18, Note 5). The standard's appendixes are nonmandatory. The legal background appendix describes the federal building materials exclusion as applying only where both hold: the release comes from a product that is part of a structure, and the exposure is within that structure; it names ballasts, paint and caulk among the materials it can reach (E1527-21, X1.1.4.3(2)). The body of the standard does not say how material on a building's exterior is treated. Establish where each material is: inside the building, on its exterior, or no longer part of it.
Whether PCBs have left it for the environment. A recognized environmental condition (REC) needs hazardous substances or petroleum products present or likely present at the subject property owing to a release or likely release to the environment, or present where conditions pose a material threat of one (E1527-21, 3.2.73). For its own disposal rules, the PCB rule calls waste from manufactured products holding PCBs in a non-liquid state, at 50 parts per million (ppm) or more when designated for disposal, PCB bulk product waste, apart from wastes it assigns elsewhere; its examples include caulking, applied dried paints, fluorescent light ballasts with PCBs in the potting material, and non-liquid debris from demolishing structures "manufactured, coated, or serviced with PCBs" (40 CFR 761.3). Waste holding PCBs because of a spill, release or other unauthorized disposal, soil among its examples, it calls PCB remediation waste, at concentrations that depend on date and source (40 CFR 761.3). The site visit looks for stained soil or pavement, stressed vegetation, and ground suggesting buried construction or demolition debris (E1527-21, 9.4.23, 9.4.24, 9.4.25). Establish whether caulk, paint or ballasts were removed or broken up, and where they and any demolition debris went.
What the user has asked for. No assessment of a non-scope consideration is required for all appropriate inquiries as the practice defines them, a service beyond the practice should be agreed before the assessment begins, and the practice includes no sampling of building materials (E1527-21, 1.4, 4.4, 7.4, 13.1.2).

The records that bear on it

Site visit. Inside buildings the site visit covers boiler rooms, maintenance and repair areas, and a sample of occupant spaces chosen as representative; conditions above ceilings or behind walls need not be identified (E1527-21, 9.2.3, 9.2.4.2).
History. Building department records show permission to build, alter or demolish, and are reviewed where the professional judges more review warranted (E1527-21, 3.2.10, 8.3.4.5, 8.3.8).
Documents and interviews. Before the site visit the owner, key site manager and user are asked for site investigation reports and hazardous waste generator notices or reports (E1527-21, 10.8.1). Where PCB bulk product waste is disposed of under the PCB rule's provision for non-hazardous waste landfills that a state permits, licenses or registers, the person disposing of it keeps a written record of its PCB sampling and analysis, or of the notices given, for 3 years from the waste's generation (40 CFR 761.62(b)(5)).

What the federal rule says

The inquiry rule (40 CFR part 312) does not mention PCBs. It has the professional's inquiry include

A visual on-site inspection of the subject property and facilities and improvements on the subject property, including a visual inspection of the areas where hazardous substances may be or may have been used, stored, treated, handled, or disposed.

40 CFR 312.27(a)(1), edition revised as of July 1, 2025

How it is written up

Removed material, debris or stained ground is a finding when the professional judges it may indicate hazardous substances present or likely present at the subject property, and the opinion gives the reasoning for or against each class the finding pertains to (E1527-21, 12.5, 12.6).

Where the professional concludes that PCBs from building materials are present or likely present at the subject property owing to a release into the environment, the opinion gives the grounds: the material, where it went, and the observation or record that shows it. Unless judged a de minimis condition or a historical REC, the REC is listed in the Conclusions, and the professional should give an opinion on additional investigation, if any (E1527-21, 3.2.20, 3.2.39, 12.7, 12.8).

Where the professional concludes the material remains inside the building and part of it, with no release into the environment, it stays a non-scope consideration (E1527-21, 9.4.18, 13.1.5.12). A PCB building materials service the user has engaged is reported only as the terms of engagement specify, and additions to the practice are listed (E1527-21, 12.10, 12.11).

Observation of the interior of a building on the subject property, which the site visit is to cover, may be what cannot be had (E1527-21, 9.2.3). Required information that good faith efforts could not obtain is a data gap, significant if it affects the ability to identify a REC: named in the Findings with the sources consulted, discussed in the Opinions and listed in the Conclusions (E1527-21, 3.2.19, 3.2.78, 12.5.1, 12.6.2, 12.7).

This page is general reference for environmental professionals. It does not classify any property. ASTM E1527-21 is the standard and is not reproduced here; the judgment of the environmental professional on the facts governs.