Dive summary:

• A change in how EPA interprets its rules about disposing of building materials contaminated with PCBs from caulk, paint or other materials lifts the burden of treating them as expensive hazardous waste, but it is critical for contractors to take steps in the right order to get that break.
• The caulk or other material has to still be attached to the brick or wood or other material at what EPA calls the time it is "designated for disposal," even if the brick and caulk, for example, get separated later.
• The change is only about materials contaminated by PCB-carrying products that were applied to them, not about anything contaminated if there was a spill of liquid containing PCBs, such as a transformer oil.

From the article:

The final Reinterpretation Guidance is online at http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/caulk/pdf/pcb-bulk-waste-memo102412.pdf.