2
The Problem: PCBs Still
Prevalent in
U.S. Schools
Health Effects of PCBs
3
The Solution: Lighting
Retrofits Remove Hazard
and Improve
Energy Efficiency
Should Light Ballasts
In Your School
Be Removed?
5
What Postponing a
Lighting Retrofit
Could Mean
6
Funding is Available
To Help Finance
Lighting Retrofits
Lighting Retrofits
Get Results
7
Responding to the
Public's Questions
8
For More Information
United States
Environmental Protection
Agency
Region 9
Pollution Prevention Program
San Francisco, CA 94105
EPA 909B-00-003
May 2001
www.epa.gov/region09
A Guide for School Administrators
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
poly chlorinated biphenyls (PCBs) through fires or leaks.
Removal of PCB-containing light fixtures, when done in
conjunction with lighting upgrades, is an investment that
pays off with long-term benefits to students, school staff, the
community, and the environment.
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The Problem: PCBs Still Prevalent in U.S. Schools
Many schools in the U.S. have light
ballasts containing PCBs. The PCBs
are contained within the light ballasts'
capacitors and in the ballasts' potting material,
which is used for insulation. Until the late 1970s,
PCBs were commonly used as insulators in
electrical equipment because they have high
tolerance to heat, do not burn easily, and are non-
explosive.
PCBs are very stable
chemical compounds that
do not readily break
down. Because of this,
they may remain in the
body, causing long-lasting
toxic effects over many
years (see Health Effects of
PCBs). For this reason, it
is critical to minimize any
potential exposure to
them.
The EPA banned the
manufacture and import
of PCBs to the U.S. in 1979 because of their toxic
effects. They also banned the processing or use of
PCBs, except in totally enclosed equipment.
However, no state or federal regulations
precluded the continued use of the older PCB
ballasts. Therefore, a large number of PCB
ballasts are still in use in U.S. schools.
As long as the PCBs remain in the ballasts and
potting material, they do not pose a health risk or
environmental hazard. However, as they age, the
ballasts degrade, increasing the risk of leaks or
even fires, which would pose a health and
environmental hazard. The hazard can be
worsened by mishandling the incident. Improper
cleanup of a ballast leak at a school in Oregon in
1999 potentially exposed school staff and
maintenance workers to PCBs (see What
Postponing a Lighting Retrofit Could Mean, page 5).
The EPA developed this booklet and its
companion piece, for school maintenance
personnel, to ensure that school personnel are
aware of the risks posed by PCBs in light ballasts
and informed of the proper and safe way to
handle fires, leaks, and retrofits.
Health Effects of PCBs
T
he 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:
Affects 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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The Solution: Lighting Retrofits Remove Hazard
and Improve Energy Efficiency
The EPA recommends removing PCB-
containing ballasts as part of a complete
lighting retrofit (see Should Light Ballasts in
Your School be Removed?, below). 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. Replacing the older ballasts with newer
lighting technology improves lighting quality,
distributing the light more uniformly and thus
providing a more comfortable and productive
learning environment. The newer lighting
technology also increases energy efficiency which
means cost savings for the school in the long term
(see Lighting Retrofits Get Results - Lower Energy
Costs and Improved Learning Environments, page 6,
detailing how a California school benefitted from
a lighting upgrade).
Lighting retrofits to eliminate PCB-containing
light ballasts should be a component of any
remodeling efforts. It is critical that the lighting
upgrade be planned in sequence with other
remodeling projects such as roofing, seismic
bracing, and indoor air quality improvements. To
ensure that all building code requirements are
met and work is performed cost-effectively, the
EPA recommends having an architect review the
relationship of the lighting retrofit to other
planned building improvements. Due to the
hazardous nature of PCBs, only a qualified
contractor should perform the lighting retrofit.
For information about proper use, storage, and
disposal of PCBs, please contact your state solid
and hazardous waste agency or call USEPA's
information hotline at
(202) 554-1404.
How Should the Old Ballasts and Fluorescent
Tubes be
Safely
Disposed?
Safe
disposal of
the old
ballasts An intact \,auast
and
fluorescent tubes is critical. Because the ballasts
contain PCBs and the fluorescent tubes contain
mercury, the waste ballasts and tubes from a
lighting retrofit should be handled as hazardous
waste.
The Toxic Substances Control Act (TSCA)
regulates how PCBs, including ballasts that
contain PCBs, should be disposed. All ballasts
containing PCBs must be packaged in a PCB-
approved container, marked properly, and
shipped by an authorized PCB transporter. All
leaking PCB-containing ballasts must be destroyed
through high temperature incineration. TSCA
allows several disposal options for non-leaking
ballasts, including disposal in a hazardous waste
landfill or recycling. However, many states have
Should Light Ballasts in Your School Be Removed?
your school was built before 1979.
your school has not had a complete lighting retrofit since 1979.
If these statements apply to your school, then the answer is most likely yes, your light
ballasts probably contain PCBs and should be removed. PCB-free light ballasts manufactured
after 1979 are required to have the statement "No PCBs." Any building built before that time is
likely to have PCB-containing ballasts if it has not recently undergone a complete lighting retrofit
(all light fixtures in the school were upgraded). Also, PCB-containing light ballasts were allowed to
be used in fluorescent lights after 1979 z/the ballasts had been manufactured before the 1979 ban.
Thus, schools built after 1979 that have not undergone a complete lighting retrofit could have PCB-
containing light ballasts in their fluorescent light fixtures as well. To determine whether your
school has PCB-containing ballasts, conduct a visual inspection of a representative number of light
fixtures (not just the tubes). See the companion booklet, A Guide for School Maintenance Personnel,
for full instructions on identifying PCB ballasts.
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Table 1: Possible Methods for Disposal of Intact
PCB-Containing Light Ballasts1
Method
Approximate
Cost
Advantages
Disadvantages
High-Temperature
Incineration
$8.00 per ballast
(four pounds)
PCBs completely
destroyed, removing
future liability
High cost
Municipal,
Hazardous or
Chemical Waste
Landfill
$0.50 per ballast
(four pounds)
Low cost
PCBs may seep
from landfill;
long-term liability
Recycling of
Metals, High-
Temperature
Incineration of
PCBs
$3.50 per ballast
(four pounds)
PCBs completely
destroyed; metals
recycled
Must ensure
recycling facility is
permitted; long-term
liability
Disposal of PCB-containing ballasts is regulated federally under the
Toxic Substances Control Act.
Table 2: Possible Methods for Disposal of
Fluorescent Tubes2
Method
Approximate
Cost
Advantages
Disadvantages
Hazardous Waste
Landfill
$0.50 per 4-foot tube
Minimal cost
Mercury may leak from the
landfill; metals and glass are
wasted; long-term liability
Recycling
$0.60 per 4-foot tube
Minimal cost; mercury is
recovered, metals and
glass are recycled
Must ensure recycling
facility is permitted;
long-term liability
2Disposal of mercury-containing fluorescent lamps is regulated
federally under the Resource Conservation and Recovery Act.
developed special regulations for disposing of
non-leaking PCB ballasts that are more stringent
than TSCA. It is critical to contact the appropriate
state solid and hazardous waste agency and follow
their regulations and requirements when disposing of
non-leaking PCB-containing ballasts.
When considering disposal options, factors that
should be considered in determining the best
option include cost, long-term environmental
impacts, and long-term liability. Table 1 outlines
three of the disposal options for non-leaking
PCB-containing ballasts, the approximate costs,
and the advantages and disadvantages.
The costs of incinerating the ballasts are
highest, while disposing of ballasts in a
hazardous waste landfill is the lowest cost
option. Recycling costs approximately
$3.50 per ballast, and benefits the
environment by recovering metals and
reducing the volume of waste requiring
burial or incineration.
Disposal of mercury-containing fluorescent
lamps is regulated under the federal
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,
the EPA recommends assuming that all
fluorescent lamps contain mercury and
handling them as hazardous waste. As
with PCB-containing ballasts, it is critical to
check with state solid and hazardous waste
agencies to ensure the lamps are handled
appropriately. As with PCBs, states have
adopted stricter disposal requirements
than Federal regulations. Also, some states
have added mercury-containing
fluorescent lamps to their universal waste
rule, which allows streamlined storage,
handling, and transportation requirements
for specific types of waste. Contact your
state or local hazardous waste program for
information on proper disposal of
fluorescent tubes.
Table 2 shows the two most common methods of
disposing of mercury-containing fluorescent
lamps, recycling or burying in a hazardous waste
landfill. Although more costly, recycling recovers
the mercury and removes it from the waste
stream, and allows the glass and metal to be
recycled. In contrast, disposal in a hazardous
waste landfill results in the possibility that
mercury may leak from the landfill and the lost
opportunity to recover the mercury, glass, and
metal.
Mercury-containing fluorescent lamps are never
incinerated due to the potential for mercury
release into the environment.
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What Postponing a Lighting Retrofit Could Mean
As PCB-containing light ballasts age, the
chance that they will leak or catch fire
increases. This risk is compounded by
the fact that there is virtually no way to detect
whether ballasts are leaking or about to catch fire
by simply looking at a light fixture. One school
in Oregon found this out the hard way when a
light ballast leaked PCB-containing oil over
books, desks, and other school equipment. After
the EPA become aware of this incident, they
examined other light ballasts in the school and
found more leaking ballasts potentially exposing
students and staff to PCBs.
During the inspection, the EPA also learned that
the school district was in the process of
remodeling and upgrading light fixtures district-
wide. Unaware that the old fixtures contained
PCBs, the district had been taking them to
another local school to be dismantled. The EPA
discovered that the old fixtures were not being
handled properly and that the leaking PCB
ballasts were actually being stored on the school's
playground. In addition, the workers handling
the leaking ballasts were not trained in the proper
handling of hazardous materials. Lack of
awareness of the problem and mishandling of
the response needlessly exposed students, staff,
and maintenance workers to PCBs. The school
district has spent more than $250,000 to clean up
spilled PCBs, and is facing possible monetary
penalties for improper storage and handling of
PCB wastes.
Although a lighting retrofit might seem like a
low educational priority in some schools when
compared with new computers and classrooms,
school administrators should take into account
the Oregon example and what they might
unexpectedly have to deal with if a ballast leaks
or catches fire:
Effects on Student and Staff Health
A ballast leak or fire could happen at any time,
without warning. If it happens in a busy
classroom in the middle of the day, a school could
be looking at long-term health impacts on many
students and staff. Even a small, isolated leak
may pose health issues for the staff or students
who discover it. And once the leak or fire has
been cleaned up and decontaminated, the school
has to convince students, parents, staff, and local
media that it is safe to return. Students and staff
who have experienced a ballast leak or fire
firsthand may be very reluctant to return to
classrooms where such an incident may happen
again.
Effects on Quality of Education
The affected area, classroom, hallway, cafeteria,
or auditorium will be off-limits during cleanup
and decontamination. It may take several weeks
before the area can be declared "clean" for use
again. The school will need to find appropriate
temporary quarters for students and staff; many
school programs and functions may be
disrupted.
Response and Replacement Costs
Significant costs will be incurred to cover,
at a minimum:
Hiring
properly
trained and
qualified
cleanup
personnel;
Cleanup and
decontamina-
tion of
contaminated equipment and surfaces;
This ballast sparked afire at a Southern
California school in 1999.
Analytical testing of contaminated equipment
and surfaces for PCBs as well as the more toxic
furans, produced when PCBs burn;
Compliance with environmental regulations
for disposal of contaminated equipment and
cleanup materials;
Retesting of equipment and surfaces to ensure
that they are free of PCBs and furans; and
Replacement of leaking or burned fixtures and
any contaminated materials, such as desks.
Postponing a lighting retrofit and betting on the
structural integrity of old ballasts is a dangerous
gamble with serious health and educational
impacts for your students and staff and serious
cost impacts for your budget.
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Funding to Help Finance
Lighting Retrofits is Available
In most states, there are several agencies The program offers assistance through
with funding available to support energy workshops and information resources that
efficiency projects such as lighting retrofits, can be accessed from the Internet. These
Both public utilities and private energy include:
companies may offer such programs. Programs T. . . TT -, ^ -,
i j , i i . u i. ° * Lighting Upgrade Technologies
may include technical assistance, rebates, or & & *- & &
other funding assistance to support lighting Financing Your Upgrades
upgrade projects. Contact your local energy
provider or state energy commission for more * New Building Design Guidance
information. « Service and Product Providers
The EPA's Energy Star program supports These manuals are available on the Internet
schools, businesses and organizations planning at www.energystar.gov.
to install energy-efficient lighting technologies.
Lighting Retrofits Get ResultsLower Energy Costs and
Improved Learning Environments
In 1997, the Bass Lake School District in Oakhurst, California, performed a lighting retrofit
with the help of a loan program from the California Energy Commission. As a result, the
schools reported a 9.25 percent decrease in energy costs in 1997, despite adding two new
permanent buildings, and a further 2 percent decrease in 1998. But most importantly, the schools
noted the "vastly improved learning environment provided by the new lighting system."
Lighting upgrades not only increase energy efficiency and save money, they also provide a
better, safer learning environment.
Although a lighting retrofit may seem to be an expensive undertaking, most retrofits pay for
themselves within a surprisingly short timeframe. For example, one Southern California school
with 29 classrooms and 703 students will recoup the costs of their upgrade in under seven
years. The chart below outlines the upgrade and disposal costs as well as the actual funds saved
through energy efficiency.
Disposal and Installation Costs
Disposal of T12 lamps (580 fixtures x 2 lamps/fixture x $0.50/lamp): $580.00
Disposal of ballasts (580 fixtures x 1 ballast/fixture x $3.00/ballast): $1,740.00
Installation of 580 fixtures (580 fixtures x $54.00/fixture): $31,320.00
Total: $33,640.00
Energy Savings (one year)
Electricity Demand Savings: $4,304.00
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Responding to the Public's Questions
This section is intended to help you
respond to concerns expressed by
students, teachers and other school staff,
and parents. It provides some sample questions
that may be posed and suggested answers.
Is my child in danger from PCBs in light
ballasts?
As long as the PCBs in the ballasts remain in the
ballasts or in the fixture, they do not pose any
danger to students. The use of PCBs in
magnetic light ballasts is considered an
"enclosed" system. This use was not prohibited
by the EPA's 1979 ban because, at the time,
there was very little likelihood that the PCBs
would escape their ballast containers. They are
a potential danger now because the increasing
age of the magnetic ballasts has greatly
increased the likelihood that they may leak.
This is why we are currently fitting a lighting
retrofit into our overall modernization plan - to
remove this potential danger as soon as
possible.
Currently, students are not endangered by
intact, non-leaking ballasts. Only leaking or
burning ballasts are a hazard. The only way to
prevent this hazard is through a complete
lighting retrofit which we are planning right
now.
How will you deal with a leak or fire if it
happens?
The EPA has written instructions to help make
school maintenance personnel become aware of
these potential problems and how to handle
them. This information will either be
incorporated into the school's Emergency
Response Plan (if the school has one) or will be
used as a supplement to the plan.
Only trained professionals, such as firefighters,
can respond to leaks and fires because of the
hazardous substance involved. The school's
role will be to evacuate the immediate area of
the leak and make sure that all students and
school staff maintain a safe distance to prevent
any possible exposure. If there is a fire, the
entire school will be evacuated until the fire has
been put out. Whatever area has been affected
will be off-limits to all but trained professionals
until it has been cleaned up, tested, and certified
to be "clean" of PCBs or other substances.
What are the health effects of PCBs?
The most likely way that students and staff may
be 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. As soon as we know of a leak
or fire, we will immediately evacuate the area to
prevent students and staff from inhaling PCB-
laden air or touching the oil.
Short-term effects, which may be noticed
immediately or shortly after exposure to PCBs
include irritation of the eyes, nose, and throat.
Short-term
exposure to high
levels of PCBs can
damage the liver.
Long-term effects
can occur at any
time after
exposure and may
last for months or
years. They
include a severe,
acne-like rash, called chloracne, that may persist
for years; nervous system damage, causing
numbness, weakness, and tingling ("pins and
needles") in the arms and legs; muscle and joint
pain; headaches; loss of appetite; nausea,
vomiting, and abdominal pain; liver damage;
reproductive effects, including still births and
underweight births; and thyroid gland
disorders.
The EPA has classified PCBs as probable human
carcinogens (cancer-causing substances). PCB
exposure may cause liver, skin, and reproduc-
tive cancers. PCBs may be passed onto infants
through their pregnant or nursing mothers.
What are some of the warning signs of
exposure to PCBs?
Warning signs of PCB exposure include irritation
of the eyes, nose, and throat. PCB-containing oil
should never be touched any kind of skin
contact constitutes overexposure.
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U.S. Environmental Protection Agency
Region IX
75 Hawthorne Street
San Francisco, CA 94105
For More Information
For additional information about the use,
storage, transportation, and disposal of PCBs,
including ballasts containing PCBs, please
contact the TSCA information hotline at 202-
554-1404, or refer to the EPA's PCB website at
www.epa.gov/pcb.
Notes:
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