PCBs in Light Ballasts—Handle with Care

In its publication titled “Proper Maintenance, Removal, and Disposal of PCB-Containing Fluorescent Light Ballasts,” the U.S. Environmental Protection Agency (EPA) discusses best practices for inspecting and removing ballasts facilitywide. Although the directive is intended to help schools address removal of ballasts containing PCBs, it offers some commonsense steps for everyone with the same need.

To begin, the EPA recommends that inspectors “wear protective clothing, including chemically resistant gloves, boots, and disposable overalls. Make sure the survey is performed in a well-ventilated area, or provide supplemental ventilation or respiratory protection if necessary to reduce the potential for breathing in fumes.” You should also be prepared to carefully record your inspection of each area, including the exact location and status of the light ballasts inspected.

In addition to EPA’s recommendations, the Occupational Safety and Health Administration (OSHA) notes that although there are always concerns that airborne PCB contamination will result from a leak, physical contact with the liquid chemical may produce more acute symptoms based on permissible exposure limits (PELs), and required precautions must be taken.“Both of the PELs for (PCBs) have skin designations; therefore, protection must be provided to prevent potential absorption in the body as a result of skin contact.” For example, OSHA states, “Where leaks are likely to exist, 29 CFR 1910.1000(a)(4) requires employers to prevent worker exposure through the use of gloves, other appropriate personal protective equipment, engineering controls, or work practices.

Forget expensive calls to lawyers and consultants. With Enviro.BLR.com, you get instant access, 24/7. Try it out today and get an the 2013 EHS Salary Guide, absolutely free. Download Now.

OSHA further indicates that glove materials must provide a protective barrier that does not allow PCBs to migrate through to the skin in 24 hours and include “Neoprene (chloroprene latex), polyvinyl alcohol, FEP Teflon, and Viton fluorocarbon rubber,”  but not natural rubber latex and polyethylene materials that allow PCBs to permeate within 1 hour. The entire directive is available at https://www.osha.gov/dts/hib/hib_data/hib19921218.html.

To conduct the initial inspection, you may remove the entire fixture or the portion of the fixture covering the ballast to allow for a clear view of the ballast and any signs of leaks or rupture. In the event that a leaking ballast is found, inspection of that type of ballast should be expanded. As noted yesterday, all ballasts manufactured between 1979 and 1998 were labeled “No PCBs,” so if you see that label, you can safely assume that ballast does not contain PCBs. If there is no label, you can either assume that ballast contains PCBs or you can attempt to contact the manufacturer for confirmation that the unit does or does not contain PCBs.

Need an answer fast? Relax. Our editors guarantee a personalized response to your questions within 3 business days. Take a free trial of Enviro.BLR.com® and see what everyone is talking about. For a limited time, also receive a free 2013 EHS Salary Guide. Download Now

Testing Positive

If you find PCBs leaking from any ballast, you are automatically required by federal law to ensure the ballast is immediately removed and disposed of according to the Toxic Substances Control Act (TSCA).
Detailed cleanup and decontamination procedures for a PCB leak from a ballast are outlined on EPA‘s PCB laws and regulations page at http://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/guidance.htm.  However, the EPA recommends contracting a professional services firm with the experience and credentials to conduct the cleanup and disposal process because of the toxicity of PCBs and the complexity of associated decontamination. In the interim, any spaces associated with the leak should be cleared of people and should remain uninhabited until the cleanup is complete. It is also important to note that ballasts containing PCBs that are not leaking but are removed from use must be disposed of according to the PCB regulations at 40 CFR 761.50(b)(2).

Ultimately, any generator of PCB-containing ballast wastes, whether it is a school or other facility, is responsible under federal law for ensuring the proper disposal of PCB waste. Other responsibilities may include employee notification under OSHA’s Hazard Communication Standard 29 CFR 1910.1200 and recordkeeping requirements, depending on generator status and additional state regulations.

Under TSCA, the EPA is not authorized to delegate implementation authority to the states, although states may have their own more stringent rules. The federal program is operated by EPA’s Office of Solid Waste and Emergency Response (OSWER), and more information can be found at http://www2.epa.gov/aboutepa/about-office-solid-waste-and-emergency-response-oswer.