1

2

4

5

7

Removing PCBs fromLight Fixtures:Protecting Students from Hidden Dangers

A Guide for School Maintenance Personnel

United StatesEnvironmental ProtectionAgency

Region 9Pollution Prevention ProgramSan Francisco, CA 94105

EPA 909B-00-002May 2001www.epa.gov/region09

10

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. Thisguide provides step-by-step instructions for identifying,properly managing, and ultimately replacing PCB-containinglight ballasts in your school.

T

Introduction

Step 1: Identifying PCBBallasts

Step 2: Act Immediatelyif Ballasts are Leakingor if there is a Fire

Accidental Exposure and

Health Effects of PCBs

Step 3: Avoid Problems- Make a LightingRetrofit Part of YourModernization Plan

Resources for SchoolRetrofits

Conclusion

What to Do

2

Until the late 1970s, PCBs werecommonly used in smallcapacitors and in the potting

material used as insulation in fluorescentlight ballasts because of their low electricalconductivity. The Toxic SubstancesControl Act (TSCA), enacted in 1976,banned the production of PCBs in the U.S.

in 1978.

However, the continued use ofPCB-containing items, such asfluorescent light ballasts, manu-factured before the ban was notprohibited. That is why PCBs inlight ballasts manufactured before1978 are a potential problem formany schools in the U.S. today.As the ballasts age, they canbreak down and pose a potentialhealth and environmental hazarddue to increasing risk of leaks oreven fires. To remove this poten-tial hazard and increase energy

efficiency, the U.S. Environmental Protec-tion Agency (EPA), recommends a com-plete lighting retrofit — removal andreplacement of all potentially PCB-con-taining fluorescent light fixtures — for allaffected schools. A complete lightingretrofit is the best option because:

Introduction• It removes the hazard posed by PCBs in

small capacitors and potting material inthe fluorescent light fixture;

• The older fluorescent tubes used withPCB-containing (magnetic) capacitorstypically do not work with the newelectronic capacitors;

• The newer fluorescent tubes contain lessmercury, also a toxic substance,than the older tubes;

• The newer fluorescent tubes andcapacitors increase energy efficiency andlead to long-term savings; and

• The new fluorescent tubes producebetter quality light and contribute to abetter and safer learning environmentfor students and teachers.

Lighting retrofits should be conducted aspart of overall school modernizationefforts to ensure safety and cost-effective-ness.

This guide provides step-by-step instruc-tions for identifying, properly managing,and ultimately replacing PCB-containinglight ballasts in your school.

F igure 1 (right) can help youdetermine whether there may bePCBs in your school. If you deter-

mine that your lights might have PCBs,you should conduct a visual inspection.

The ballasts arecontained withinthe light fixture.Because you mayneed to removethe fixtures toview the ballasts,select a represen-tative number of

ballasts throughout the school to inspectfirst. Inspection may also be accomplished

Step 1: Identifying PCB Ballasts

An intact ballast.

by removing a portion of the fixture, suchas the metal panel covering the ballast.Expand your inspection if you find PCBballasts. To prevent possible exposure ifleaking ballasts are discovered, wearprotective clothing, including chemicallyresistant gloves, boots, and disposableoveralls. Make sure the survey is per-formed in a well-ventilated area to reducethe potential for breathing in fumes. Besure to keep a record of the areas (e.g.,classroom 101) and location of the lightssurveyed.

PCBs are found only in magnetic ballasts.If your ballasts are electronic, they are

3

PCB-free. Electronic ballasts should be clearly marked as electronic. After July 1, 1979,magnetic ballasts manufactured without PCBs in their capacitors or potting materialrequired the state-ment “No PCBs.”Even if the ballastsin your sample aremagnetic ballastslabeled “No PCBs,” alighting retrofit isrecommendedbecause of theeducational andenergy savingbenefits.

If the magneticballasts do not havethe statement “NoPCBs,” you have twooptions:

1. Assume thatthe ballastscontain PCBsand considerperforming alighting retrofit,OR

2. Contact themanufacturerto determinewhether theballasts containPCBs.

If the manufactureris not sure whetherthe ballasts containPCBs, assume thatthey do and considerretrofitting. If themanufacturer doesknow whether theballasts containPCBs, document theconversation withthe manufacturer.Then, if the ballastscontain PCBs, EPArecommends acomplete lightingretrofit.

Wasbuilding

built before1979?

Has acomplete

lighting retrofitbeen performed

since1979?

Ballastsprobably donot contain

PCBs

Perform visual survey of a representativesample of ballasts throughout the school

Areballasts

electronic orinclude statement

“No PCBs?”

Ballastsdo notcontainPCBs

YES YES

NO NO

YES

NOOption 1 Option 2

Callmanufacturer to

determine ifballasts contain

PCBs

AssumeballastscontainPCBs

Doesmanufacturer

know?

Documentconversation

and labelballast

YES

NO

Do ballastscontainPCBs?

Perform acompletelightingretrofit

NO

YES

Figure 1: How to Identify PCB-containing Ballasts

RecommendedPrecautionaryMeasure

4

Notify the appropriate local andstate authorities.

Engage a contractor to manage thedecontamination and prevent furtherleaking. If a school has PCB-containingballasts and is not planining a lightingretrofit, school administration shouldconsider setting up a contract now tofacilitate the decontamination processshould it become necessary. Otherwise,the area of the leak could be off-limitsfor several months instead of justseveral weeks because of paperworkre-quirements.

Leaks typically take two forms: a clear toyellow, oily liquid, the PCB oil itself, or atar-like substance, the liquefied pottingmaterial. Of the two, the oil containsmuch higher levels of PCBs, sometimes100%, and is therefore more dangerousthan the potting material.

Step 2: Act Immediately if Ballasts areLeaking or if there is a Fire

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

To prevent accidental exposure of workers cleaning up the leak, be sure to observe the following safetyprecautions: wear protective clothing, including chemically resistant gloves and boots, and disposableoveralls; ensure that the area of the leak is well ventilated to minimize the potential for breathing infumes; use a respirator if proper ventilation of the area is not possible or not advised due to potentialexposure.

Some of the warning signs of exposure include irritation of the eyes, nose, and throat, and an acne-likeskin rash, called chloracne. Below are some tips to follow if accidental exposure occurs:

Eye Contact - immediately flush with large amounts of water for at least 15 minutes, occasionallylifting upper and lower lids.

Skin Contact - remove contaminated clothing and immediately wash contaminated skin with largeamounts of soap and water. Contaminated clothing must be disposed as PCB-contaminated waste.

Breathing - remove the person from the area and take to the emergency room. Begin rescue breathingif breathing has stopped and CPR if heart action has stopped.

Please note that any skin contact may constitute overexposure. For your safety, consult a doctor assoon as possible after skin contact.

Accidental Exposure and What to Do

Leaking Ballasts - What to Do: Evacuate the area (e.g., classroom, hallway) immediately to prevent any acciden-tal exposure through touching or breath-ing in fumes from the leak. Do not closeoff the area of the leak by shutting doorsand windows as this may create a hazard-ous situation for personnel responding tothe leak. It is important to keep students

and staff as far awayfrom the leak as practi-cable (approximately100 feet minimum) tominimize potentialexposure.

Call 911 andinform them that the

leaking ballast may contain PCBs. 911personnel will send the appropriate localemergency response team to respond tothe leak.

✓

✓

✓

✓

5

Ballast Fires - What to Do Immediately call the Fire Depart-ment, and indicate potentially hazardousmaterials are present. Evacuate the area.

Turn off electricity to the affectedarea.

Notify the appropriate local andstate authorities.

Engage a contractor to manage thedecontamination.

PCB-containing ballast fires are especiallydangerous because burning PCBs produceother highly toxic substances such asdioxins and furans. It is best to allow thetrained professionals in the Fire Depart-ment to respond to the fire. Any person-nel expected to respond to fires must betrained and equipped in accordance withfederal regulation 29 CFR 1910 156.

General Cleanup and DecontaminationProcedures After a Leak or FireThe cleanup and decontamination proce-dures for a leak are outlined below. Dueto the hazards associated with PCBs, anexperienced contractor should be retained.

Suggested responsibilities include:

• Cleaning up the leak and decontaminat-ing the area, including testing and re-testing as necessary.

• Providing appropriate storage andshipping containers for waste materials.

• Marking, labeling, and preparing thedrums containing the waste materialfrom the cleanup for storage, removal,transportation, and disposal.

• Preparing manifests and other relateddocumentation for the removal, trans-portation, storage, and disposal of PCBwastes and ensuring submittal to appro-priate authorities.

• Notifying the appropriate federal, state,and local authorities.

• Handling any federal, state, and localreporting and record keepingrequirements.

• Transporting the drum containing theleaking ballasts to a high-temperatureincinerator, the only approved disposal

The EPA has classified all PCBs as probable human carcinogens (cancer-causingsubstances). Evidence suggests a possible association between PCB exposure and livercancer. 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 throughbreathing contaminated air or touching PCB oil or PCB-contaminated materials after aballast leak or fire. No information is available on the short-term effects of PCBs inhumans. However, long-term effects can occur at any time after exposure and may lastfor months or years. They include: effects 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 aschloracne, skin rashes, and eye irritation. Infants of mothers exposed to PCBs canexperience developmental effects impairing movement, visual recognition memory, andshort term memory. PCBs may also be passed onto infants through their pregnant ornursing mothers.

Health Effects of PCBs

✓

✓

✓

✓

6

method for leaking ballasts, and decon-taminating the associated cleanupwastes prior to transportation to a PCBdisposal facility or a RCRA Subtitle C(hazardous waste) landfill permitted toaccept PCB waste.

• Ensuring disposal of the wastes inaccordance with federal and state regula-tions.

The procedures for cleaning up anddecontaminating a fire are essentially the

same as a leak.However, after afire, the areamust be testednot only forPCBs, but forfurans as well.

Management and Disposal of Wastesfrom Ballast Leaks or FiresFederal law requires that leaking PCB-containing ballasts and any PCB-contami-nated materials must be incinerated at anEPA-approved high-temperature incinera-tor. For a list of approved facilities, pleasecall the TSCA information hotline at(202) 554-1404, or refer to the PCB web siteat www.epa.gov/pcb. Schools should beaware that, as a generator of PCB-contain-ing ballast wastes, they could be liable inany subsequent Superfund cleanup for anyimproper disposal or release to theenvironment.

Table 1, to the left, outlines the packing,labeling, storing, transportation, reporting,and disposal requirements for disposing ofthe waste streams resulting from cleanup ofPCB-containing ballast leaks or fires.

As a generator of PCB (or hazardous)waste, you need to prepare a UniformHazardous Waste Manifest, available fromthe incinerator that will be receiving thewaste. Please note that if the EPA previ-ously has not issued a hazardous wastegenerator identification number to theschool, the school must obtain one by fillingout and submitting EPA form 8700-12before disposing of any PCB-containingwaste.

DisposalMethod

Table 1: Packing and Disposal of Leaking, PCB-ContainingBallasts and PCB-Containing Wastes1

Manifests andReporting

Packing andLabeling

Storage

USEPA-approved high-temperature incinerator

• Place ballasts in containers that comply with EPA andDept. of Transportation regulations. Call the TSCAhotline at 202-554-1404 for information.

• All containers must have label indicating PCBwaste.

• Label the containers as hazardous waste according toDepartment of Transportation regulations.

Uniform Hazardous Waste Manifest required

1Disposal of PCB-containing ballasts and PCB-containing wastes areregulated federally under the Toxic Substances Control Act (TSCA).

Transportation

Permit required if storing over 270 days

Registered hauler required

Toxic Substances Control ActHotline

202-554-1404

7

Planning for a RetrofitLighting retrofits can improve classroomquality, save money and energy, andreduce worry and liability. Replacing theolder ballasts with newer lighting ballasts,reflectors, an d tubes improves lightingquality, distributing the light more uni-formly and thus providing a more com-fortable and productive learning environ-ment. The newer lighting technology alsoincreases energy efficiency which meanssavings for the school in the long term.Replacing PCB-containing ballasts nowwill prevent a potentially costly cleanuplater.

A lighting retrofit ideally should beperformed as part of overall moderniza-tion efforts such as roofing or seismicbracing. It is critical to examine themodernization plan to determine where alighting retrofit would best fit into theoverall plan to ensure safe, cost-effectiveschool upgrades. To ensure that all legalrequirements are met, engage a contractorto review the relationship of PCB work tothe design of all building systems and theremoval and replacement of PCB-contami-nated equipment. The architect shouldconsult with electrical and demolitionengineers to be certain that their work iscoordinated and all building codes arefollowed.

An experienced contractor should performthe lighting retrofit. Suggested responsi-bilities include:

Disconnecting all power to andde-energizing all electrical equipment tobe retrofitted under the supervision of alicensed electrician.

Inspecting all fluorescent light fixturesto determine if each individual ballastshould be assumed to contain PCBs or ispotentially leaking.

Disconnecting and removing allballasts, incidental PCB-contaminated items,and fluorescent tubes from the lightingfixture housings and compartments.

Providing the appropriate containers andpacking materials for packaging and storing thefour possible types of waste streams:

1. Intact, non-leaking, PCB-contain-ing ballasts;

2. Leaking PCB- containing ballasts and

cleanup wastesgenerated byhandling anddecontaminating

areas whereleaking ballastswere discovered;

3. Ballasts that contain no PCBs; and

4. Fluorescent tubes.

Maintaining a record for each area (e.g.,classroom, hallway) where lighting fixtures areremoved including how many leaking vs.nonleaking PCB-containing ballasts were re-moved from each area.

Maintaining a record for each drum used tostore PCB-containing ballasts including:

1. The number of ballasts in the drum;

2. The condition of the ballasts -leaking or non-leaking;

3. The date the first ballasts wereplaced in the drum;

4. The destination of the ballasts;

5. The name of the contractorpacking the drum; and

Step 3: Avoid Problems - Make a LightingRetrofit Part of Your Modernization Plan

✓

✓

✓

✓

✓

✓

8

6. The name and address of thewaste generator (e.g., the school’sname).

Packaging and labeling the drumsaccording to federal, state, and local regu-lations.

Storing the drums according to fed-eral, state, and local regulations until atransporter currently licensed for transpor-tation of extremely hazardous wasteremoves them to the appropriate disposalfacility for each type of waste stream.

Preparing manifests and other relateddocumentation for the removal, transpor-tation, storage, and disposal of PCBwastes and ensuring submittal to appro-priate authorities.

Notifying the appro-priate federal, state, andlocal authorities.

Handling any federal,state, and local record-keeping or reportingrequirements.

Management and Disposal of FourTypes of Retrofit WastesThe sections below outline the notification,packing, reporting, storage, transportationand disposal requirements for the fourtypes of wastes resulting from a lightingretrofit.

It is critical to check with state solid andhazardous waste agencies to ensure thatwastes are handled properly.

Some states have adopted stricterrequirements than Federal regulations.Contact your state hazardous wasteprogram for information on the rulesthat apply in your area.

Schools also should be aware that, as agenerator of PCB-containing ballastwastes, they could be liable under federallaw in any subsequent federal cleanup at ahazardous or chemical land disposal site,incinerator, or recycling facility for im-proper disposal or release to the environ-ment.

Waste 1: Intact, Non-leakingPCB-containing BallastsUnder federal law, the EPA recommendsnon-leaking ballasts should be handled,transported, and disposed of as hazardouswastes. They can be sent to a chemicalwaste landfill, an EPA-approved high-temperature incinerator, or to an EPA-approved ballast recycler. If the EPA hasnot previously issued a hazardous wastegenerator identification number to theschool, the school must obtain one byfilling out and submitting EPA Form 8700-12 before disposing of any PCB-containingwaste. The storage, labeling, notification,and transportation requirements varydepending on the volume of waste. Pleasecontact the TSCA information hotline, at(202) 554-1404, for the full requirementsfor managing hazardous wastes.

Under TSCA, ballasts with PCB-contain-ing small capacitors that are intact areregulated as non-hazardous waste. How-ever, if the ballasts contain PCBs in thepotting material, the ballasts are regulatedas PCB bulk product waste and must besent to an EPA-approved high tempera-ture incinerator or disposed through otherapproved methods as listed in 40 CFR761.62.

Waste 2: Leaking PCB-containing Bal-lasts and Cleanup WastesLeaking ballasts that contain PCBs mustbe managed as PCB waste and sent to anEPA-approved high-temperature incinera-tor. Any material that is contaminated byleaking PCBs should also be consideredPCB waste. For proper packing, storage,

✓

✓

✓

✓

✓

9

DisposalMethod

Table 2: Packaging and Disposal of Mercury-ContainingFluorescent Tubes2

Manifests andReporting

Notification

Packing andLabeling

Storage

Notify the National Response Center at 1-800-424-8802

•Pack lamps in cushioning material to prevent breakage

•Place lamps in containers that comply with federal law.Call the RCRA Hotline at 1-800-424-9346

•Label the containers as hazardous waste according toDepartment of Transportation regulations

2Disposal of mercury-containing fluorescent tubes is regulated feder-ally under the Resource Conservation and Recovery Act (RCRA).

Transportation

Permit required if storing over 90 days

Hazardous Waste Landfill Recycling

Uniform Hazardous WasteManifest required

Record waste onbill of lading

Registered hauler required No requirements

transportation, and disposal informationfor leaking ballasts and clean-up wastes,refer to Table 1 on page 6, call the TSCAhotline, or check the EPA website atwww.epa.gov/pcb.

Waste 3: Non-PCB-containing BallastsNon PCB-containing ballasts manufac-tured after 1979 may contain di-2-ethylhexylphthalate (DEHP) which hasbeen classified as a probable humancarcinogen. DEHP was used as a PCBreplacement in fluorescent light ballastsuntil 1991. However, most manufacturersstopped using it in 4-foot fixtures in 1985.Though not required under federal law,the EPA recommends you treat DEHPballasts as hazardous waste to avoidpotential releases to the environment.However, if you are disposing of morethat 100 lbs. of DEHP (the equivalent ofapproximately 1,600 ballasts) in a 24 hourperiod, you must notify the NationalResponse Center at 1-800-424-8802.

Waste 4: Mercury-containingFluorescent TubesDisposal of mercury-containing fluores-cent lamps is federally regulated underthe Resource Conservation and RecoveryAct (RCRA). Because of the high cost oftesting a fluorescent lamp for mercury(approximately $140 per lamp) and thelikelihood that the lamp will fail the test,USEPA recommends assuming that allfluorescent lamps contain mercury andhandling them as hazardous waste. Somestates have added mercury-containingfluorescent lamps to their universal wasterule, which allows streamlined storage,handling, and transportation require-ments for specific types of waste.

Table 2, below, summarizes the generalnotification, packing, labeling,transporting, storage, reporting, anddisposal requirements.

10

Energy Star ProgramThe U.S. Environmental ProtectionAgency’s Energy Star Program supportscorporations and organizations in install-

ing energy-efficientlighting technologies.The program offersassistance through work-shops and informationservices that can beaccessed from theInternet. Theseinclude: LightingUpgrade Technologies;Financing Your Upgrades;

New Building Design Guidance; andService and ProductProviders. These materials are available atwww.energystar.gov. EPA’s Office ofPollution Prevention and Toxics alsooffers lists of approved storage anddisposal facilities through its web page atwww.epa.gov/opptintr/pcb.

State ProgramsMany states provide additional incentivesfor lighting retrofits. Check with your

Resource for School Retrofitsstate energy commission or with yourlocal utility for more information.

Energy ProvidersBoth public utilities and private energycompanies may offer programs to supportenergy efficiency improvements such aslighting upgrades. Programs may includetechnical assistance, rebates, or otherfunding assistance to support lightingupgrade projects. Contact your localenergy provider for moreinformation.

To eliminate the potential hazard posed byPCB-containing light ballasts, USEPArecommends removing PCB-containingballasts as part of a complete lightingretrofit. A complete lighting retrofitincludes removing old fluorescent tubes aswell as ballasts and replacing the entirelighting fixture with newer, more energy efficient fixtures. A complete lighting retrofitnot only eliminates the hazard, but also improves the school’s learning environment,and increases energy efficiency. It’s an investment that pays off with long-lastingreturns to your students, your community, and the environment.

Conclusion