PCBs in Dental Office X-ray
PCB Information and Reference
Fact Sheet
U.S. Environmental Protection Agency
PCBs in Dental X-ray Machines
When dental offices replace old X-ray machines, they
may discover that the machines contain, or may contain,
PCBs. This fact sheet is intended to help answer
questions regarding how to comply with EPA regulations
for PCBs.
Where are the PCBs in X-ray Machines?
X-ray machines manufactured before July 2, 1979, may
contain PCB dielectric fluids at varying concentrations in
the transformers and capacitors located in the machine,
including the tube head. In order to determine whether
the machine contains PCBs, EPA recommends
contacting the X-ray machine manufacturer. For
disposal, it is recommended to contact an X-ray machine
service company which may handle disposal of the
equipment. The X-ray machine owner can also check the
EPA website for PCB commercial storage and disposal
facilities ("https://go.usa.gov/xf9u6). The owner should
also check with state environmental agencies for
information on the disposal of the X-ray components of
the machine.
Additional Information:
Tetter from Don R. Clay, Director, Office of Toxic
Substances, to Ms. Joanne Westcott, November 8, 1984.
Biphenyls (PCBs)
PCBs were domestically
manufactured from 1929 until
fabrication was banned in 1979 by
the Toxic Substances Control Act
(TSCA), with some products and
processes excluded from the ban
by regulation. PCBs were used
extensively as coolants in
hydraulic systems and as dielectric
fluids in electrical equipment as
well as many other applications.
However, PCBs may still be
present in products and materials
produced before 1979 (including
oil used in motors and hydraulic
systems) or in excluded
manufacturing processes, as
defined in 40 CFR 761.3, and can
still be released into the
environment, where they do not
readily break down.
PCBs have been identified as
probable human carcinogens and
cause a variety of non-cancer
health effects as well.2
1 The recommendations in this document do not impose legally binding requirements and will not be implemented
as binding in practice. They do not impose any obligations on private parties nor are they intended to direct the
activities of any other federal, state or local agency or to limit the exercise of their legal authority.

U. S. Environmental Protection Agency	July 2020
How are X-ray Machines Regulated in the PCB Regulations?
Regulations for Non-leaking PCB Components in an X-ray Machine:
Transformers in the X-ray machines are regulated depending on the PCB concentration in the
oil. If the PCB concentration is less than 50 ppm, it is a non-PCB Transformer and is not
regulated for storage or disposal under the TSCA PCB regulations (see 40 CFR 761.2(a)(1) and
the definition of non-PCB Transformer at 40 CFR 761.3). For oil with PCB concentrations
greater than or equal to 50 ppm, the transformer and/or the oil must be disposed of in
accordance with 40 CFR 761.60(a) and (b). A transformer with a PCB concentration between
50 and 500 ppm is regulated as PCB Contaminated Equipment under 40 CFR 761.60(b)(4). If
the PCB concentration is over 500 ppm, it is regulated for disposal as a PCB Transformer and
must be disposed of at an EPA approved TSCA PCB incinerator or an EPA approved TSCA
chemical waste landfill in accordance with 40 CFR 761.60(b)(1).3
If X-ray machines have been serviced by an X-ray machine service provider, the original PCB
concentration in the oil may have changed. The owner may have the transformer oil tested. See
40 CFR 761.2(b)(1). Instead of testing, the owner may assume the PCB concentration is > 500
parts per million (ppm), in which case the transformer is a PCB Transformer. If a non-leaking
PCB transformer has less than three pounds of fluid, it can be assumed to have less than 50 ppm
PCBs and is therefore a non-PCB Transformer. Also, PCB concentration assumptions can be
made based on the transformer manufacturing date in accordance with 40 CFR 761.2(a)(2) or
Capacitors in X-ray machines manufactured before July 2, 1979 whose PCB concentration is
not established, or whose date of manufacture is unknown, must be assumed to contain PCB
concentrations >500 ppm. See 40 CFR 761.2(a)(4). These and other PCB Capacitors generally
must be disposed at an EPA approved TSCA PCB incinerator (see 40 CFR 761.60(b) and the
definition of PCB Capacitor at 40 CFR 761.3). Leaking capacitors must be disposed of in
accordance with 40 CFR 761.60(b)(6) which requires disposal at an EPA approved TSCA PCB
incinerator if the PCB concentration is over 500 ppm. If the capacitor meets the definition of a
small capacitor as defined in 40 CFR 761.3 under " Capacitor, (1) Small capacitor" and is not
leaking, it may be disposed as municipal solid waste (see 40 CFR 761.60(b)(2)(ii)). A capacitor
marked at the time of manufacture with the statement "No PCBs" in accordance with 40 CFR
761.40(g) may be assumed not to contain PCBs. See 40 CFR 761.2(a)(4).
The tube head: Dental offices should take note that the tube head may also contain a PCB
Capacitor. The owner may assume the capacitor contains > 500 ppm PCBs, in which case the
whole tube head must be disposed at an EPA approved TSCA PCB incinerator (see 40 CFR
761.60(b)(2)(iii)(A)). The glass portion of the tube head is under a vacuum and should not be
broken. If the capacitor can be removed without breaking the glass, the owner can determine if
the capacitor is a PCB Capacitor and make a disposal determination (see paragraph above and
40 CFR 761.2(a)(4)).
3 The PCB regulations can be found at 40 CFR Part 761, online at https://www.ecfr.gov/cgi-bin/text-
idx?tpl=/ecfrbrowse/Title40/40cfr761 main 02.tpl

U. S. Environmental Protection Agency	July 2020
How are X-Ray Machines Regulated in the PCB Regulations?
Regulations for Leaking PCB Components in an X-ray Machine
If any PCB-containing electrical component with a PCB concentration over 500 ppm is leaking
oil, the entire X-ray machine must be disposed at an approved PCB incineration facility (see 40
CFR 761.60(b)(6). It may be stored for disposal for up to 30 days if it is stored in a container in
a temporary storage area in accordance with 40 CFR 761.65(c)(1), or up to one year if stored in
a fully compliant PCB storage area as described under 40 CFR 761.65(b)(1). An extension to
the 1-year storage limitation can be granted under 40 CFR 761.65(a). The leaking component(s)
should be removed from the machine and handled and stored as described under 40 CFR
Under 40 CFR 761.50(b)(2), PCB items that are no longer intact and non-leaking are regulated
for disposal as PCB bulk-product waste under § 761.62(a) or (c).
Is the X-ray Machine Subject to PCB Storage Requirements Before it
is Disposed?
Yes, the X-ray machine is subject to PCB storage requirements. The X-ray machine generally
must be disposed within one year from the date of removal from service for disposal (see 40
CFR 761.65(a)). The machine may be stored for disposal during this time, but after 30 days of
temporary storage, the machine must be stored in a fully compliant PCB storage area as
described in 40 CFR 761.65(b)(1). The temporary storage requirements can be found under 40
CFR 761.65(c)(1). The machine containing PCB components, or non-leaking PCB components
if they have been removed from the machine, may be stored under temporary storage rules for
up to 30 days from when the machine was removed from service. Leaking PCB components
may also be placed in temporary storage, but these components must be removed from the
machine and placed in a non-leaking PCB container with sorbent material. See 40 CFR
761.65(c)(l)(ii). The container should be labeled with the date of removal from service (40 CFR
761.65(c)(1)). If PCB components are leaking but not removed from the machine, the entire
machine should be placed inside a containment structure.
Manifesting and EPA ID Numbers
Dental offices with PCB X-ray machine components designated for disposal are considered PCB
waste generators and must prepare a manifest on EPA Form 8700-22 (40 CFR 761.207). The
manifest form requires an ID number for the generator of the waste, which can be obtained by
submitting the Notification of PCB Activity form to EPA (Form 7710-53), if required. EPA will
issue a unique EPA identification number to the notifier if the notifier does not have one.
Generators who do not own or operate PCB commercial storage facilities subject to the
storage requirements of 40 CFR § 761.65 (b) or (c)(7) do not need to submit the notification
form. Generators exempted from the notification requirements shall use the generic
identification number "40 CFR Part 761" on manifests, unless such generators elect to use a
unique EPA identification number previously assigned to them under RCRA by EPA or a state.
See 40 CFR§ 761.205 and https://www.epa.gov/pcbs/notifications-polvchlorinated-biphenvl-

U. S. Environmental Protection Agency	July 2020
How are X-ray Machines Regulated in the PCB Regulations?
After Non-leaking PCB Components have been Removed, How Does
One Dispose of the Rest of the X-ray Machine?
After any non-leaking PCB components have been removed, the power source should be
removed from the X-ray machine. Housings are generally made of lead, so EPA recommends
contacting your state environmental agency to determine if the housing could be a hazardous
waste before disposal at a landfill. The machine can be disposed as municipal solid waste unless
the state agency has other regulations for the disposal of X-ray equipment. The owner should
contact the state environmental agency for information and the landfill operator to see if it will
accept the machine before shipping for disposal. For the X-ray component of the machine, EPA
does not regulate the radioactive portion of the machine. States typically regulate the
radioactive components and should be contacted for guidance on disposal.
Contact your State and EPA Regional PCB Coordinator
If you have concerns about PCB contamination or need more information, consult your
EPA Regional PCB Coordinator at http://www.epa.gov/pcbs/program-contacts and your
state environmental agency. EPA recommends that you make decisions about appropriate
action after thoughtful consideration of all available information and all legal
EPA Region 1 (CT, MA, ME, NH, RI, VT) Tel: 617-918-1527
EPA Region 2 (NJ, NY, PR, U.S. Virgin Islands) Tel: 212-637-3759
EPA Region 3 (DE, DC, MD, PA, VA, WV) Tel: 215-814-2177
EPA Region 4 (AL, FL, GA, KY, MS, NC, SC, TN) Tel: 404-562-8512
EPA Region 5 (IL, IN, MI, MN, OH, WI) Tel: 312-886-7890
EPA Region 6 (AK, LA, NM, OK, TX) Tel: 214-665-6796
EPA Region 7 (IA, KS, MO, NE) Tel: 913-551-7504
EPA Region 8 (CO, MT, ND, SD, UT, WY) Tel: 303-312-6446
EPA Region 9 (AZ, CA, HI, NY, American Samoa, Guam, Northern Mariana Islands) Tel: 415-
EPA Region 10 (AK, ID, OR, WA) Tel: 206-553-1616