Blog by Ed Stuber, Portfolio Lead Industrial Hygiene SGS North America
PCB cleanup activities such as excavation, grading, stockpiling, and material transport can generate inhalable particulate matter (PM10). Because polychlorinated biphenyls (PCBs) readily adhere to dust particles, these operations create a dual exposure risk that must be carefully managed under TSCA.
- Inhalable PM10 is associated with asthma, cardiovascular effects, and respiratory disease.
- Particle-bound PCBs, are recognized as probable carcinogens linked to immune, reproductive, and neurological impacts.
This combination makes real-time dust monitoring a critical component of safe and compliant PCB remediation projects.
EPA Expectations for Real-Time PM10 Monitoring
In response to these risks, EPA’s TSCA PCB Dust Guidance outlines expectations for Real-Time PM10 Monitoring. Effective monitoring during PCB remediation requires more than simply measuring particulate concentrations. EPA emphasizes on robust data collection, defensible sampling practices, and proactive mitigation when dust levels rise.
At SGS, we can help support you with our SmartSense solution, with remote sample initiation and automated monitoring capabilities.
EPA TSCA Guidance Highlights
EPA guidance for fugitive dust control at PCB cleanup sites emphasizes a structured, real-time monitoring approach designed to protect workers and the environment, focusing on defensible data and rapid response when dust levels rise.
Key Expectations Include:
- Upwind and downwind PM10 monitoring
- High-resolution data collection (e.g., 1-minute logging intervals)
- Evaluation using a 120-minute rolling average
- Defined trigger levels with corresponding response actions
- Comprehensive documentation to support TSCA compliance and oversight
Applying Monitoring in the Field
Integrated monitoring systems are commonly deployed across a range of remediation and construction activities, including:
- Excavation and grading
- Trenching and earth-moving
- Stockpiling operations
- Truck loading, unloading, and haul routes
- Pavement removal
- Disturbed surface areas
- Sediment and shoreline work
- Landfill capping and construction-related remediation
Automated Real-Time Site Contribution Monitoring
EPA’s TSCA framework uses PM10 as a practical real-time surrogate for PCB-containing dust, as airborne PCBs cannot currently be measured with direct-reading instruments.
SmartSense can set a trigger level of PM10 and collect a sample for lab analysis via NIOSH 5503 when that trigger concentration is met. Samples are collected for laboratory analysis and then can be analyzed for PCBs. This entire process is done remotely with no human intervention.
The lab results can help with:
- Background (ambient) dust levels
- Site-generated particulate contributions
- Proximity to action or trigger thresholds
- When additional dust controls may be required
Why It Matters
By moving beyond static PM10 measurements to real-time, site-specific evaluation, cleanup teams can:
- Make faster, data-driven decisions
- Demonstrate regulatory compliance with TSCA requirements
- Reduce risk of off-site PCB migration
- Improve transparency with regulators and stakeholders
How SmartSense Can Help
SmartSense delivers real-time monitoring, defensible data, and the rapid response needed to meet EPA’s TSCA PCB dust monitoring expectations while helping protect worker health and safety.
SmartSense systems are easy to install and are unobtrusive to site operations. With SmartSense, you get access to real-time data connected to the cloud, and get advanced intelligence for critical decisions to respond quickly when conditions change.
Choose SGS
Strengthen your TSCA PCB dust monitoring program with SmartSense. Contact us today to learn how our monitoring solutions can help support compliance, improve decision-making, and protect workers and surrounding communities.