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According to the U.S. Environmental Protection Agency (EPA), “PCBs are man-made organic chemicals used in paints, industrial equipment, plastics, and cooling oil for electrical transformers. More than 1.5 billion pounds of PCBs were manufactured in the United States before the EPA banned the production of this chemical class in 1977, and many PCB-containing materials are still in use today.” It is important to note that the processing and use of PCBs in ballasts and other equipment (except in totally enclosed equipment) was not halted until 1979.
PCBs are known to cause cancer in animals, are a suspected human carcinogen, and can also adversely affect liver function as well as the nervous, immune, and endocrine systems. In the environment, PCBs are considered a persistent organic pollutant and were the impetus for Congress enacting TSCA in 1976.
Aside from the presence of PCBs, the primary problem with the old ballasts is that all of the pre-1979 devices have now exceeded their intended life span and may degrade and leak PCBs or even ignite, causing contamination and fire. According to the EPA, “Depending on the number of operating hours, the typical life expectancy of a magnetic fluorescent light ballast is between 10 and 15 years. The failure rate prior to the end of the useful life of ballasts is about 10 percent. After this typical life expectancy, ballast failure rates increase significantly.”
In addition, those tasked with lighting replacement can be exposed simply by handling a ballast with a tiny leak and may inadvertently spread the contamination through the air and via clothing, equipment, or building surfaces without realizing they are doing so, unless they have the appropriate knowledge beforehand. When this happens, a simple lighting replacement can quickly become a hazardous waste operation requiring professional cleanup, as well as the loss of production in all contaminated work areas for the duration and costly medical testing, surveillance, and treatment of anyone exposed.
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Visual Clues to Ballast Fatigue
So how do you know if your ballasts do or do not contain PCBs? That much is fairly simple because from 1979 until 1998, all ballasts manufactured without PCBs were required to be labeled “No PCBs.” If there is no label, you must assume the ballast contains PCBs. This is not to say all ballasts installed after 1979 were PCB-free, however, because ballasts that were manufactured before that year were still installed afterward, so it is best to check the ballasts themselves rather than rely on old maintenance records.
When assessing ballasts for leaks, the EPA recommends looking for two things: the liquid PCB oil that is clear to yellow in color and the “potting compound, a black, tar-like substance that encapsulates the internal electrical components.” A single ballast can contain as much as an ounce and a half of PCBs in the capacitor and lesser amounts in the potting compound. If you inspect a sampling of ballasts and find that some are leaking and others are not, the EPA highly recommends replacing all of them immediately, because it is not possible to visually determine when a ballast is going to rupture or begin leaking.
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Replacement vs. Remediation
In the event a leak or fire does occur, significant health problems can result, and even if no human is impacted, the EPA notes that “every release of PCBs from the ballast constitutes an unauthorized disposal of PCBs.”
In general, minimum costs resulting from a ballast leak could include:
- Relocation of staff from the affected area into temporary quarters during cleanup and decontamination;
- Hiring properly trained and qualified cleanup personnel;
- Cleanup and decontamination of contaminated equipment and surfaces;
- Analytical testing of contaminated equipment and surfaces for PCBs;
- Compliance with environmental regulations for proper storage and disposal of contaminated equipment and cleanup materials;
- Retesting of equipment and surfaces to ensure that they are free of PCBs and other contaminants; and
- Replacement of leaking or burned fixtures and any other contaminated materials.
Tomorrow we will look at basic steps for assessing and removing ballasts containing PCBs.