The Problem: PCBs StillPrevalent inU.S. Schools

Health Effects of PCBs

The Solution: LightingRetrofits Remove Hazardand ImproveEnergy Efficiency

Should Light BallastsIn Your SchoolBe Removed?

What Postponing aLighting RetrofitCould Mean

Funding is AvailableTo Help FinanceLighting Retrofits

Lighting RetrofitsGet Results

Responding to thePublic’s Questions

For More Information

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he U.S. Environmental Protection Agency (EPA)recommends removal of all pre-1979 fluorescent lightballasts in schools to prevent accidental exposure of

students, teachers, and other school personnel to highly toxicpolychlorinated biphenyls (PCBs) through fires or leaks.Removal of PCB-containing light fixtures, when done inconjunction with lighting upgrades, is an investment thatpays off with long-term benefits to students, school staff, thecommunity, and the environment.

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A Guide for School Administrators

United StatesEnvironmental ProtectionAgency

Region 9Pollution Prevention ProgramSan Francisco, CA 94105

EPA 909B-00-003May 2001www.epa.gov/region09

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Removing PCBs fromLight Fixtures:Protecting Students from Hidden Dangers

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any schools in the U.S. have lightballasts containing PCBs. The PCBsare 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 inelectrical equipment because they have hightolerance to heat, do not burn easily, and are non-explosive.

PCBs are very stablechemical compounds thatdo not readily breakdown. Because of this,they may remain in thebody, causing long-lastingtoxic effects over manyyears (see Health Effects ofPCBs). For this reason, itis critical to minimize anypotential exposure tothem.

The EPA banned themanufacture and import

The Problem: PCBs Still Prevalent in U.S. Schoolsof PCBs to the U.S. in 1979 because of their toxiceffects. They also banned the processing or use ofPCBs, except in totally enclosed equipment.However, no state or federal regulationsprecluded the continued use of the older PCBballasts. Therefore, a large number of PCBballasts are still in use in U.S. schools.

As long as the PCBs remain in the ballasts andpotting material, they do not pose a health risk orenvironmental hazard. However, as they age, theballasts degrade, increasing the risk of leaks oreven fires, which would pose a health andenvironmental hazard. The hazard can beworsened by mishandling the incident. Impropercleanup of a ballast leak at a school in Oregon in1999 potentially exposed school staff andmaintenance workers to PCBs (see WhatPostponing a Lighting Retrofit Could Mean, page 5).The EPA developed this booklet and itscompanion piece, for school maintenancepersonnel, to ensure that school personnel areaware of the risks posed by PCBs in light ballastsand informed of the proper and safe way tohandle fires, leaks, and retrofits.

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 breathingcontaminated air or touching PCB oil or PCB-contaminated materials after a ballast leak or fire. Noinformation is available on the short-term effects of PCBs in humans. However, long-term effectscan occur at any time after exposure and may last for months or years. They include:

l Affects to the nervous and reproductive system, immune system suppression;l Hormone disruption;l Respiratory tract symptoms;l Gastrointestinal effects;l Mild liver effects; andl 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 throughtheir pregnant or nursing mothers.

Health Effects of PCBs

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f these statements apply to your school, then the answer is most likely yes, your lightballasts probably contain PCBs and should be removed. PCB-free light ballasts manufacturedafter 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 tobe used in fluorescent lights after 1979 if 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 yourschool has PCB-containing ballasts, conduct a visual inspection of a representative number of lightfixtures (not just the tubes). See the companion booklet, A Guide for School Maintenance Personnel,for full instructions on identifying PCB ballasts.

he EPA recommends removing PCB- containing ballasts as part of a complete lighting retrofit (see Should Light Ballasts inYour School be Removed?, below). A completelighting retrofit includes removing old fluorescenttubes as well as ballasts, and replacing the entirelighting fixture with newer, more energy-efficientfixtures. Replacing the older ballasts with newerlighting technology improves lighting quality,distributing the light more uniformly and thusproviding a more comfortable and productivelearning environment. The newer lightingtechnology also increases energy efficiency whichmeans cost savings for the school in the long term(see Lighting Retrofits Get Results – Lower EnergyCosts and Improved Learning Environments, page 6,detailing how a California school benefitted froma lighting upgrade).

Lighting retrofits to eliminate PCB-containinglight ballasts should be a component of anyremodeling efforts. It is critical that the lightingupgrade be planned in sequence with otherremodeling projects such as roofing, seismicbracing, and indoor air quality improvements. Toensure that all building code requirements aremet and work is performed cost-effectively, theEPA recommends having an architect review therelationship of the lighting retrofit to otherplanned building improvements. Due to thehazardous nature of PCBs, only a qualifiedcontractor should perform the lighting retrofit.

The Solution: Lighting Retrofits Remove Hazardand Improve Energy Efficiency

For information about proper use, storage, anddisposal of PCBs, please contact your state solidand hazardous waste agency or call USEPA’sinformation hotline at(202) 554-1404.

How Should the Old Ballasts and FluorescentTubes beSafelyDisposed?

Safedisposal ofthe oldballastsandfluorescent tubes is critical. Because the ballastscontain PCBs and the fluorescent tubes containmercury, the waste ballasts and tubes from alighting retrofit should be handled as hazardouswaste.

The Toxic Substances Control Act (TSCA)regulates how PCBs, including ballasts thatcontain PCBs, should be disposed. All ballastscontaining PCBs must be packaged in a PCB-approved container, marked properly, andshipped by an authorized PCB transporter. Allleaking PCB-containing ballasts must be destroyedthrough high temperature incineration. TSCAallows several disposal options for non-leakingballasts, including disposal in a hazardous wastelandfill 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.

An intact ballast.

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developed special regulations for disposing ofnon-leaking PCB ballasts that are more stringentthan TSCA. It is critical to contact the appropriatestate solid and hazardous waste agency and followtheir regulations and requirements when disposing ofnon-leaking PCB-containing ballasts.

When considering disposal options, factors thatshould be considered in determining the bestoption include cost, long-term environmentalimpacts, and long-term liability. Table 1 outlinesthree of the disposal options for non-leakingPCB-containing ballasts, the approximate costs,

and the advantages and disadvantages.The costs of incinerating the ballasts arehighest, while disposing of ballasts in ahazardous waste landfill is the lowest costoption. Recycling costs approximately$3.50 per ballast, and benefits theenvironment by recovering metals andreducing the volume of waste requiringburial or incineration.

Disposal of mercury-containing fluorescentlamps is regulated under the federalResource Conservation and Recovery Act(RCRA). Because of the high cost of testinga fluorescent lamp for mercury(approximately $140 per lamp) and thelikelihood that the lamp will fail the test,the EPA recommends assuming that allfluorescent lamps contain mercury andhandling them as hazardous waste. Aswith PCB-containing ballasts, it is critical tocheck with state solid and hazardous wasteagencies to ensure the lamps are handledappropriately. As with PCBs, states haveadopted stricter disposal requirementsthan Federal regulations. Also, some stateshave added mercury-containingfluorescent lamps to their universal wasterule, which allows streamlined storage,handling, and transportation requirementsfor specific types of waste. Contact yourstate or local hazardous waste program forinformation on proper disposal offluorescent tubes.

Table 2 shows the two most common methods ofdisposing of mercury-containing fluorescentlamps, recycling or burying in a hazardous wastelandfill. Although more costly, recycling recoversthe mercury and removes it from the wastestream, and allows the glass and metal to berecycled. In contrast, disposal in a hazardouswaste landfill results in the possibility thatmercury may leak from the landfill and the lostopportunity to recover the mercury, glass, andmetal.

Mercury-containing fluorescent lamps are neverincinerated due to the potential for mercuryrelease into the environment.

2Disposal of mercury-containing fluorescent lamps is regulatedfederally under the Resource Conservation and Recovery Act.

Table 2: Possible Methods for Disposal of Fluorescent Tubes2

Method Hazardous WasteLandfill

Recycling

$0.50 per 4-foot tube $0.60 per 4-foot tube

Minimal costMinimal cost; mercury isrecovered, metals and

glass are recycled

Mercury may leak from thelandfill; metals and glass are

wasted; long-term liability

Must ensure recyclingfacility is permitted;long-term liability

ApproximateCost

Advantages

Disadvantages

1Disposal of PCB-containing ballasts is regulated federally under theToxic Substances Control Act.

MethodHigh-Temperature

Incineration

Municipal,Hazardous or

Chemical WasteLandfill

Recycling ofMetals, High-Temperature

Incineration ofPCBs

Table 1: Possible Methods for Disposal of Intact PCB-Containing Light Ballasts1

High costPCBs may seep

from landfill;long-term liability

Must ensurerecycling facility is

permitted; long-termliability

Disadvantages

ApproximateCost

$8.00 per ballast(four pounds)

$0.50 per ballast(four pounds)

$3.50 per ballast(four pounds)

PCBs completelydestroyed, removing

future liabilityLow cost

PCBs completelydestroyed; metals

recycledAdvantages

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As PCB-containing light ballasts age, thechance that they will leak or catch fireincreases. This risk is compounded by

the fact that there is virtually no way to detectwhether ballasts are leaking or about to catch fireby simply looking at a light fixture. One schoolin Oregon found this out the hard way when alight ballast leaked PCB-containing oil overbooks, desks, and other school equipment. Afterthe EPA become aware of this incident, theyexamined other light ballasts in the school andfound more leaking ballasts potentially exposingstudents and staff to PCBs.

During the inspection, the EPA also learned thatthe school district was in the process ofremodeling and upgrading light fixtures district-wide. Unaware that the old fixtures containedPCBs, the district had been taking them toanother local school to be dismantled. The EPAdiscovered that the old fixtures were not beinghandled properly and that the leaking PCBballasts were actually being stored on the school’splayground. In addition, the workers handlingthe leaking ballasts were not trained in the properhandling of hazardous materials. Lack ofawareness of the problem and mishandling ofthe response needlessly exposed students, staff,and maintenance workers to PCBs. The schooldistrict has spent more than $250,000 to clean upspilled PCBs, and is facing possible monetarypenalties for improper storage and handling ofPCB wastes.

Although a lighting retrofit might seem like alow educational priority in some schools whencompared with new computers and classrooms,school administrators should take into accountthe Oregon example and what they mightunexpectedly have to deal with if a ballast leaksor catches fire:

Effects on Student and Staff HealthA ballast leak or fire could happen at any time,without warning. If it happens in a busyclassroom in the middle of the day, a school couldbe looking at long-term health impacts on manystudents and staff. Even a small, isolated leakmay pose health issues for the staff or studentswho discover it. And once the leak or fire hasbeen cleaned up and decontaminated, the school

What Postponing a Lighting Retrofit Could Meanhas to convince students, parents, staff, and localmedia that it is safe to return. Students and staffwho have experienced a ballast leak or firefirsthand may be very reluctant to return toclassrooms where such an incident may happenagain.

Effects on Quality of EducationThe affected area, classroom, hallway, cafeteria,or auditorium will be off-limits during cleanupand decontamination. It may take several weeksbefore the area can be declared “clean” for useagain. The school will need to find appropriatetemporary quarters for students and staff; manyschool programs and functions may bedisrupted.

Response and Replacement CostsSignificant costs will be incurred to cover,at a minimum:

l Hiringproperlytrained andqualifiedcleanuppersonnel;

l Cleanup anddecontamina-tion ofcontaminated equipment and surfaces;

l Analytical testing of contaminated equipmentand surfaces for PCBs as well as the more toxicfurans, produced when PCBs burn;

l Compliance with environmental regulationsfor disposal of contaminated equipment andcleanup materials;

l Retesting of equipment and surfaces to ensurethat they are free of PCBs and furans; and

l Replacement of leaking or burned fixtures andany contaminated materials, such as desks.

Postponing a lighting retrofit and betting on thestructural integrity of old ballasts is a dangerousgamble with serious health and educationalimpacts for your students and staff and seriouscost impacts for your budget.

This ballast sparked a fire at a SouthernCalifornia school in 1999.

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I n most states, there are several agencieswith funding available to support energyefficiency projects such as lighting retrofits.

Both public utilities and private energycompanies may offer such programs. Programsmay include technical assistance, rebates, orother funding assistance to support lightingupgrade projects. Contact your local energyprovider or state energy commission for moreinformation.

The EPA’s Energy Star program supportsschools, businesses and organizations planningto install energy-efficient lighting technologies.

Funding to Help FinanceLighting Retrofits is Available

The program offers assistance throughworkshops and information resources thatcan be accessed from the Internet. Theseinclude:

l Lighting Upgrade Technologies

l Financing Your Upgrades

l New Building Design Guidance

l Service and Product Providers

These manuals are available on the Internetat www.energystar.gov.

I n 1997, the Bass Lake School District in Oakhurst, California, performed a lighting retrofitwith the help of a loan program from the California Energy Commission. As a result, theschools 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 schoolsnoted the “vastly improved learning environment provided by the new lighting system.”Lighting upgrades not only increase energy efficiency and save money, they also provide abetter, safer learning environment.

Although a lighting retrofit may seem to be an expensive undertaking, most retrofits pay forthemselves within a surprisingly short timeframe. For example, one Southern California schoolwith 29 classrooms and 703 students will recoup the costs of their upgrade in under sevenyears. The chart below outlines the upgrade and disposal costs as well as the actual funds savedthrough energy efficiency.

Disposal and Installation CostsDisposal of T12 lamps (580 fixtures x 2 lamps/fixture x $0.50/lamp): $580.00Disposal of ballasts (580 fixtures x 1 ballast/fixture x $3.00/ballast): $1,740.00Installation 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

Lighting Retrofits Get Results—Lower Energy Costs andImproved Learning Environments

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T his section is intended to help yourespond to concerns expressed bystudents, teachers and other school staff,

and parents. It provides some sample questionsthat may be posed and suggested answers.

Is my child in danger from PCBs in lightballasts?As long as the PCBs in the ballasts remain in theballasts or in the fixture, they do not pose anydanger to students. The use of PCBs inmagnetic light ballasts is considered an“enclosed” system. This use was not prohibitedby the EPA’s 1979 ban because, at the time,there was very little likelihood that the PCBswould escape their ballast containers. They area potential danger now because the increasingage of the magnetic ballasts has greatlyincreased the likelihood that they may leak.This is why we are currently fitting a lightingretrofit into our overall modernization plan - toremove this potential danger as soon aspossible.

Currently, students are not endangered byintact, non-leaking ballasts. Only leaking orburning ballasts are a hazard. The only way toprevent this hazard is through a completelighting retrofit which we are planning rightnow.

How will you deal with a leak or fire if ithappens?The EPA has written instructions to help makeschool maintenance personnel become aware ofthese potential problems and how to handlethem. This information will either beincorporated into the school’s EmergencyResponse Plan (if the school has one) or will beused as a supplement to the plan.

Only trained professionals, such as firefighters,can respond to leaks and fires because of thehazardous substance involved. The school’srole will be to evacuate the immediate area ofthe leak and make sure that all students andschool staff maintain a safe distance to preventany possible exposure. If there is a fire, theentire school will be evacuated until the fire hasbeen put out. Whatever area has been affectedwill be off-limits to all but trained professionals

Responding to the Public’s Questionsuntil it has been cleaned up, tested, and certifiedto be “clean” of PCBs or other substances.

What are the health effects of PCBs?The most likely way that students and staff maybe exposed to PCBs from light ballasts isthrough breathing contaminated air or touchingPCB oil or PCB-contaminated materials after aballast leak or fire. As soon as we know of a leakor fire, we will immediately evacuate the area toprevent students and staff from inhaling PCB-laden air or touching the oil.

Short-term effects, which may be noticedimmediately or shortly after exposure to PCBsinclude irritation of the eyes, nose, and throat.Short-termexposure to highlevels of PCBs candamage the liver.

Long-term effectscan occur at anytime afterexposure and maylast for months oryears. Theyinclude a severe,acne-like rash, called chloracne, that may persistfor years; nervous system damage, causingnumbness, weakness, and tingling (“pins andneedles”) in the arms and legs; muscle and jointpain; headaches; loss of appetite; nausea,vomiting, and abdominal pain; liver damage;reproductive effects, including still births andunderweight births; and thyroid glanddisorders.

The EPA has classified PCBs as probable humancarcinogens (cancer-causing substances). PCBexposure may cause liver, skin, and reproduc-tive cancers. PCBs may be passed onto infantsthrough their pregnant or nursing mothers.

What are some of the warning signs ofexposure to PCBs?Warning signs of PCB exposure include irritationof the eyes, nose, and throat. PCB-containing oilshould never be touched — any kind of skincontact constitutes overexposure.

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Notes:For additional information about the use,storage, transportation, and disposal of PCBs,including ballasts containing PCBs, pleasecontact the TSCA information hotline at 202-554-1404, or refer to the EPA’s PCB website atwww.epa.gov/pcb.

For More Information

U.S. Environmental Protection AgencyRegion IX75 Hawthorne StreetSan Francisco, CA 94105