2
Introduction
Stepl: Identifying PCB
Ballasts
4
Step 2: Act Immediately
if Ballasts are Leaking
or if there is a Fire
Accidental Exposure and
What to Do
5
Health Effects of PCBs
7
Step 3: Avoid Problems
- Make a Lighting
Retrofit Part of Your
Modernization Plan
10
Resources for School
Retrofits
Conclusion
United States
Environmental Protection
Agency
Region 9
Pollution Prevention Program
San Francisco, CA 94105
EPA 909B-00-002
May 2001
www.epa.gov/region09
A Guide for School Maintenance Personnel
Removing PCBs from
Light Fixtures:
Protecting Students from Hidden Dangers
The U.S. Environmental Protection Agency (EPA)
recommends removal of all pre-1979 fluorescent light
ballasts in schools to prevent accidental exposure of
students, teachers, and other school personnel to highly toxic
polychlorinated biphenyls (PCBs) through fires or leaks. This
guide provides step-by-step instructions for identifying,
properly managing, and ultimately replacing PCB-containing
light ballasts in your school.
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Introduction
Until the late 1970s, PCBs were
commonly used in small
capacitors and in the potting
material used as insulation in fluorescent
light ballasts because of their low electrical
conductivity. The Toxic Substances
Control Act (TSCA), enacted in 1976,
banned the production of PCBs in the U.S.
in 1978.
However, the continued use of
PCB-containing items, such as
fluorescent light ballasts, manu-
factured before the ban was not
prohibited. That is why PCBs in
light ballasts manufactured before
1978 are a potential problem for
many schools in the U.S. today.
As the ballasts age, they can
break down and pose a potential
health and environmental hazard
due to increasing risk of leaks or
even fires. To remove this poten-
tial hazard and increase energy
efficiency, the U.S. Environmental Protec-
tion Agency (EPA), recommends a com-
plete lighting retrofit — removal and
replacement of all potentially PCB-con-
taining fluorescent light fixtures — for all
affected schools. A complete lighting
retrofit is the best option because:
• It removes the hazard posed by PCBs in
small capacitors and potting material in
the fluorescent light fixture;
• The older fluorescent tubes used with
PCB-containing (magnetic) capacitors
typically do not work with the new
electronic capacitors;
• The newer fluorescent tubes contain less
mercury, also a toxic substance,
than the older tubes;
• The newer fluorescent tubes and
capacitors increase energy efficiency and
lead to long-term savings; and
• The new fluorescent tubes produce
better quality light and contribute to a
better and safer learning environment
for students and teachers.
Lighting retrofits should be conducted as
part of overall school modernization
efforts to ensure safety and cost-effective-
ness.
This guide provides step-by-step instruc-
tions for identifying, properly managing,
and ultimately replacing PCB-containing
light ballasts in your school.
Step 1: Identifying PCB Ballasts
An intact ballast.
Figure 1 (right) can help you
determine whether there may be
PCBs in your school. If you deter-
mine that your lights might have PCBs,
you should conduct a visual inspection.
The ballasts are
contained within
the light fixture.
Because you may
need to remove
the fixtures to
view the ballasts,
select a represen-
tative number of
ballasts throughout the school to inspect
first. Inspection may also be accomplished
by removing a portion of the fixture, such
as the metal panel covering the ballast.
Expand your inspection if you find PCB
ballasts. To prevent possible exposure if
leaking ballasts are discovered, wear
protective clothing, including chemically
resistant gloves, boots, and disposable
overalls. Make sure the survey is per-
formed in a well-ventilated area to reduce
the potential for breathing in fumes. Be
sure to keep a record of the areas (e.g.,
classroom 101) and location of the lights
surveyed.
PCBs are found only in magnetic ballasts.
If your ballasts are electronic, they are
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PCB-free. Electronic ballasts should be clearly marked as electronic. After July 1,1979,
magnetic ballasts manufactured without PCBs in their capacitors or potting material
required the state-
ment "No PCBs."
Even if the ballasts
in your sample are
magnetic ballasts
labeled "No PCBs," a
lighting retrofit is
recommended / \ YES ^ff ffB ^^. YES
Figure 1: How to Identify PCB-containing Ballasts
because of the
educational and
energy saving
benefits.
If the magnetic
ballasts do not have
the statement "No
PCBs," you have two
options:
1. Assume that
the ballasts
contain PCBs
and consider
performing a
lighting retrofit,
OR
2. Contact the
manufacturer
to determine
whether the
ballasts contain
PCBs.
If the manufacturer
is not sure whether
the ballasts contain
PCBs, assume that
they do and consider
retrofitting. If the
manufacturer does
know whether the
ballasts contain
PCBs, document the
conversation with
the manufacturer.
Then, if the ballasts
contain PCBs, EPA
recommends a
complete lighting
retrofit.
Has a
complete
NO
been performed,
NO
Ballasts
probably do
not contain
PCBs
Perform visual survey of a representative
sample of ballasts throughout the school
• Recommended
• Precautionary
• Measure
Option 1
Are
ballasts •
electronic or
include statement
"No PCBs?" . "
NO
YES
Ballasts
do not
contain
PCBs
Option 2
Call
manufacturer to
determine if
ballasts contain
PCBs
I
Assume
ballasts
contain
PCBs
Perform a
complete
lighting
retrofit
Document
conversation
and label
ballast
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Step 2: Act Immediately if Ballasts are
Leaking or if there is a Fire
Leaking Ballasts -What to Do:
I^Tf Evacuate the area (e.g., classroom, hall
way) immediately to prevent any acciden-
tal exposure through touching or breath-
ing in fumes from the leak. Do not close
off the area of the leak by shutting doors
and windows as this may create a hazard-
ous situation for personnel responding to
the leak. It is important to keep students
and staff as far away
from the leak as practi-
cable (approximately
100 feet minimum) to
minimize potential
exposure.
This ballast sparked a fire at a school in Southern
California in 1999.
Call 911 and
inform them that the
leaking ballast may contain PCBs. 911
personnel will send the appropriate local
emergency response team to respond to
the leak.
Notify the appropriate local and
state authorities.
Engage a contractor to manage the
decontamination and prevent further
leaking. If a school has PCB-containing
ballasts and is not planining a lighting
retrofit, school administration should
consider setting up a contract now to
facilitate the decontamination process
should it become necessary. Otherwise,
the area of the leak could be off-limits
for several months instead of just
several weeks because of paperwork re-
quirements.
Leaks typically take two forms: a clear to
yellow, oily liquid, the PCB oil itself, or a
tar-like substance, the liquefied potting
material. Of the two, the oil contains
much higher levels of PCBs, sometimes
100%, and is therefore more dangerous
than the potting material.
Accidental Exposure and What to Do
To prevent accidental exposure of workers cleaning up the leak, be sure to observe the following safety
precautions: wear protective clothing, including chemically resistant gloves and boots, and disposable
overalls; ensure that the area of the leak is well ventilated to minimize the potential for breathing in
fumes; use a respirator if proper ventilation of the area is not possible or not advised due to potential
exposure.
Some of the warning signs of exposure include irritation of the eyes, nose, and throat, and an acne-like
skin rash, called chloracne. Below are some tips to follow if accidental exposure occurs:
Eye Contact - immediately flush with large amounts of water for at least 15 minutes, occasionally
lifting upper and lower lids.
Skin Contact - remove contaminated clothing and immediately wash contaminated skin with large
amounts of soap and water. Contaminated clothing must be disposed as PCB-contaminated waste.
Breathing - remove the person from the area and take to the emergency room. Begin rescue breathing
if breathing has stopped and CPR if heart action has stopped.
Please note that any skin contact may constitute overexposure. For your safety, consult a doctor as
soon as possible after skin contact.
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Ballast Fires -What to Do
H Immediately call the Fire Depart-
ment, and indicate potentially hazardous
materials are present. Evacuate the area.
Turn off electricity to the affected
area.
Notify the appropriate local and
state authorities.
Engage a contractor to manage the
dec ontamination.
PCB-containing ballast fires are especially
dangerous because burning PCBs produce
other highly toxic substances such as
dioxins and furans. It is best to allow the
trained professionals in the Fire Depart-
ment to respond to the fire. Any person-
nel expected to respond to fires must be
trained and equipped in accordance with
federal regulation 29 CFR 1910 156.
General Cleanup and Decontamination
Procedures After a Leak or Fire
The cleanup and decontamination proce-
dures for a leak are outlined below. Due
to the hazards associated with PCBs, an
experienced contractor should be retained.
Suggested responsibilities include:
• Cleaning up the leak and decontaminat-
ing the area, including testing and re-
testing as necessary.
• Providing appropriate storage and
shipping containers for waste materials.
• Marking, labeling, and preparing the
drums containing the waste material
from the cleanup for storage, removal,
transportation, and disposal.
• Preparing manifests and other related
documentation for the removal, trans-
portation, storage, and disposal of PCB
wastes and ensuring submittal to appro-
priate authorities.
• Notifying the appropriate federal, state,
and local authorities.
• Handling any federal, state, and local
reporting and record keeping
requirements.
• Transporting the drum containing the
leaking ballasts to a high-temperature
incinerator, the only approved disposal
Health Effects of PCBs
The EPA has classified all PCBs as probable human carcinogens (cancer-causing
substances). Evidence suggests a possible association between PCB exposure and liver
cancer. PCBs also have significant ecological and human health effects other than cancer.
The most likely way that staff may become exposed to PCBs from light ballasts is through
breathing contaminated air or touching PCB oil or PCB-contaminated materials after a
ballast leak or fire. No information is available on the short-term effects of PCBs in
humans. However, long-term effects can occur at any time after exposure and may last
for months or years. They include: effects to the nervous and reproductive system,
immune system suppression; hormone disruption; respiratory tract symptoms;
gastrointestinal effects; mild liver effects; and effects on the skin and eyes such as
chloracne, skin rashes, and eye irritation. Infants of mothers exposed to PCBs can
experience developmental effects impairing movement, visual recognition memory, and
short term memory. PCBs may also be passed onto infants through their pregnant or
nursing mothers.
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method for leaking ballasts, and decon-
taminating the associated cleanup
wastes prior to transportation to a PCB
disposal facility or a RCRA Subtitle C
(hazardous waste) landfill permitted to
accept PCB waste.
• Ensuring disposal of the wastes in
accordance with federal and state regula-
tions.
The procedures for cleaning up and
decontaminating a fire are essentially the
same as a leak.
However, after a
fire, the area
must be tested
not only for
PCBs, but for
furans as well.
Table 1: Packing and Disposal of Leaking, PCB-Containing
Ballasts and PCB-Containing Wastes1
Disposal
Method
Packing and
Labeling
Manifests and
Reporting
Storage
Transportation
USEPA-approved high-temperature incinerator
• Place ballasts in containers that comply with EPA and
Dept. of Transportation regulations. Call the TSCA
hotline at 202-554-1404 for information.
• All containers must have label indicating PCB
waste.
• Label the containers as hazardous waste according to
Department of Transportation regulations.
Uniform Hazardous Waste Manifest required
Permit required if storing over 270 days
Registered hauler required
Management and Disposal of Wastes
from Ballast Leaks or Fires
Federal law requires that leaking PCB-
containing ballasts and any PCB-contami-
nated materials must be incinerated at an
EPA-approved high-temperature incinera-
tor. For a list of approved facilities, please
call the TSCA information hotline at
(202) 554-1404, or refer to the PCB web site
at www.epa.gov/pcb. Schools should be
aware that, as a generator of PCB-contain-
ing ballast wastes, they could be liable in
any subsequent Superfund cleanup for any
improper disposal or release to the
environment.
Table 1, to the left, outlines the packing,
labeling, storing, transportation, reporting,
and disposal requirements for disposing of
the waste streams resulting from cleanup of
PCB-containing ballast leaks or fires.
As a generator of PCB (or hazardous)
waste, you need to prepare a Uniform
Hazardous Waste Manifest, available from
the incinerator that will be receiving the
waste. Please note that if the EPA previ-
ously has not issued a hazardous waste
generator identification number to the
school, the school must obtain one by filling
out and submitting EPA form 8700-12
before disposing of any PCB-containing
waste.
Toxic Substances Control Act
Hotline
202-554-1404
Disposal of PCB-containing ballasts and PCB-containing wastes are
regulated federally under the Toxic Substances Control Act (TSCA).
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Step 3: Avoid Problems - Make a Lighting
Retrofit Part of Your Modernization Plan
Planning for a Retrofit
Lighting retrofits can improve classroom
quality, save money and energy, and
reduce worry and liability. Replacing the
older ballasts with newer lighting ballasts,
reflectors, an d tubes improves lighting
quality, distributing the light more uni-
formly and thus providing a more com-
fortable and productive learning environ-
ment. The newer lighting technology also
increases energy efficiency which means
savings for the school in the long term.
Replacing PCB-containing ballasts now
will prevent a potentially costly cleanup
later.
A lighting retrofit ideally should be
performed as part of overall moderniza-
tion efforts such as roofing or seismic
bracing. It is critical to examine the
modernization plan to determine where a
lighting retrofit would best fit into the
overall plan to ensure safe, cost-effective
school upgrades. To ensure that all legal
requirements are met, engage a contractor
to review the relationship of PCB work to
the design of all building systems and the
removal and replacement of PCB-contami-
nated equipment. The architect should
consult with electrical and demolition
engineers to be certain that their work is
coordinated and all building codes are
followed.
An experienced contractor should perform
the lighting retrofit. Suggested responsi-
bilities include:
Disconnecting and removing all
ballasts, incidental PCB-contaminated items,
and fluorescent tubes from the lighting
fixture housings and compartments.
Disconnecting all power to and
de-energizing all electrical equipment to
be retrofitted under the supervision of a
licensed electrician.
Inspecting all fluorescent light fixtures
to determine if each individual ballast
should be assumed to contain PCBs or is
potentially leaking.
Providing the appropriate containers and
packing materials for packaging and storing the
four possible types of waste streams:
1. Intact, non-leaking, PCB-contain-
ing ballasts;
2. Leaking PCB-
containing
ballasts and
cleanup wastes
generated by
handling and
dec ontaminating
areas where
leaking ballasts
were discovered;
3. Ballasts that
contain no PCBs; and
4. Fluorescent tubes.
Maintaining a record for each area (e.g.,
classroom, hallway) where lighting fixtures are
removed including how many leaking vs.
nonleaking PCB-containing ballasts were re-
moved from each area.
|77f Maintaining a record for each drum used to
store PCB-containing ballasts including:
1. The number of ballasts in the drum;
2. The condition of the ballasts -
leaking or non-leaking;
3. The date the first ballasts were
placed in the drum;
4. The destination of the ballasts;
5. The name of the contractor
packing the drum; and
-------
6. The name and address of the
waste generator (e.g., the school's
name).
1771 Packaging and labeling the drums
according to federal, state, and local regu-
lations.
Storing the drums according to fed-
eral, state, and local regulations until a
transporter currently licensed for transpor-
tation of extremely hazardous waste
removes them to the appropriate disposal
facility for each type of waste stream.
ITTf Preparing manifests and other related
documentation for the removal, transpor-
tation, storage, and disposal of PCB
wastes and ensuring submittal to appro-
priate authorities.
Notifying the appro-
priate federal, state, and
local authorities.
|77f Handling any federal,
state, and local record-
keeping or reporting
requirements.
Management and Disposal of Four
Types of Retrofit Wastes
The sections below outline the notification,
packing, reporting, storage, transportation
and disposal requirements for the four
types of wastes resulting from a lighting
retrofit.
It is critical to check with state solid and
hazardous waste agencies to ensure that
wastes are handled properly.
Some states have adopted stricter
requirements than Federal regulations.
Contact your state hazardous waste
program for information on the rules
that apply in your area.
Schools also should be aware that, as a
generator of PCB-containing ballast
wastes, they could be liable under federal
law in any subsequent federal cleanup at a
hazardous or chemical land disposal site,
incinerator, or recycling facility for im-
proper disposal or release to the environ-
ment.
Waste 1: Intact, Non-leaking
PCB-containing Ballasts
Under federal law, the EPA recommends
non-leaking ballasts should be handled,
transported, and disposed of as hazardous
wastes. They can be sent to a chemical
waste landfill, an EPA-approved high-
temperature incinerator, or to an EPA-
approved ballast recycler. If the EPA has
not previously issued a hazardous waste
generator identification number to the
school, the school must obtain one by
filling out and submitting EPA Form 8700-
12 before disposing of any PCB-containing
waste. The storage, labeling, notification,
and transportation requirements vary
depending on the volume of waste. Please
contact the TSCA information hotline, at
(202) 554-1404, for the full requirements
for managing hazardous wastes.
Under TSCA, ballasts with PCB-contain-
ing small capacitors that are intact are
regulated as non-hazardous waste. How-
ever, if the ballasts contain PCBs in the
potting material, the ballasts are regulated
as PCB bulk product waste and must be
sent to an EPA-approved high tempera-
ture incinerator or disposed through other
approved methods as listed in 40 CFR
761.62.
Waste 2: Leaking PCB-containing Bal-
lasts and Cleanup Wastes
Leaking ballasts that contain PCBs must
be managed as PCB waste and sent to an
EPA-approved high-temperature incinera-
tor. Any material that is contaminated by
leaking PCBs should also be considered
PCB waste. For proper packing, storage,
-------
transportation, and disposal information
for leaking ballasts and clean-up wastes,
refer to Table 1 on page 6, call the TSCA
hotline, or check the EPA website at
www.epa.gov/pcb.
Waste 3: Non-PCB-containing Ballasts
Non PCB-containing ballasts manufac-
tured after 1979 may contain di-2-
ethylhexylphthalate (DEHP) which has
been classified as a probable human
carcinogen. DEHP was used as a PCB
replacement in fluorescent light ballasts
until 1991. However, most manufacturers
stopped using it in 4-foot fixtures in 1985.
Though not required under federal law,
the EPA recommends you treat DEHP
ballasts as hazardous waste to avoid
potential releases to the environment.
However, if you are disposing of more
that 100 Ibs. of DEHP (the equivalent of
approximately 1,600 ballasts) in a 24 hour
period, you must notify the National
Response Center at 1-800-424-8802.
Waste 4: Mercury-containing
Fluorescent Tubes
Disposal of mercury-containing fluores-
cent lamps is federally regulated under
the Resource Conservation and Recovery
Act (RCRA). Because of the high cost of
testing a fluorescent lamp for mercury
(approximately $140 per lamp) and the
likelihood that the lamp will fail the test,
USEPA recommends assuming that all
fluorescent lamps contain mercury and
handling them as hazardous waste. Some
states have added mercury-containing
fluorescent lamps to their universal waste
rule, which allows streamlined storage,
handling, and transportation require-
ments for specific types of waste.
Table 2, below, summarizes the general
notification, packing, labeling,
transporting, storage, reporting, and
disposal requirements.
Table 2: Packaging and Disposal of Mercury-Containing
Fluorescent Tubes2
Disposal
Method
Notification
Packing and
Labeling
Manifests and
Reporting
Storage
Transportation
Hazardous Waste Landfill
Recycling
Notify the National Response Center at 1-800-424-8802
• Pack lamps in cushioning material to prevent breakage
• Place lamps in containers that comply with federal law.
Call the RCRA Hotline at 1-800-424-9346
• Label the containers as hazardous waste according to
Department of Transportation regulations
Uniform Hazardous Waste
Manifest required
Record waste on
bill of lading
Permit required if storing over 90 days
Registered hauler required
No requirements
2Disposal of mercury-containing fluorescent tubes is regulated feder-
ally under the Resource Conservation and Recovery Act (RCRA).
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Resource for School Retrofits
Energy Star Program
The U.S. Environmental Protection
Agency's Energy Star Program supports
corporations and organizations in install-
ing energy-efficient
lighting technologies.
The program offers
assistance through work-
shops and information
services that can be
accessed from the
Internet. These
include: Lighting
Upgrade Technologies;
Financing Your Upgrades;
New Building Design Guidance; and
Service and Product
Providers. These materials are available at
www.energystar.gov. EPA's Office of
Pollution Prevention and Toxics also
offers lists of approved storage and
disposal facilities through its web page at
www.epa.gov/opptintr/pcl).
State Programs
Many states provide additional incentives
for lighting retrofits. Check with your
state energy commission or with your
local utility for more information.
Energy Providers
Both public utilities and private energy
companies may offer programs to support
energy efficiency improvements such as
lighting upgrades. Programs may include
technical assistance, rebates, or other
funding assistance to support lighting
upgrade projects. Contact your local
energy provider for more
information.
Conclusion
To eliminate the potential hazard posed by
PCB-containing light ballasts, USEPA
recommends removing PCB-containing
ballasts as part of a complete lighting
retrofit. A complete lighting retrofit
includes removing old fluorescent tubes as
well as ballasts and replacing the entire
lighting fixture with newer, more energy efficient fixtures. A complete lighting retrofit
not only eliminates the hazard, but also improves the school's learning environment,
and increases energy efficiency. It's an investment that pays off with long-lasting
returns to your students, your community, and the environment.
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