During the last several years, the USEPA has been focusing attention on the potential presence of PCBs in various materials used to construct schools. For example, in September 2009, the USEPA issued guidance about the potential presence of PCBs in the caulk of pre-1978 buildings. In addition, USEPA also announced that it was conducting additional research into the potential for PCBs in caulk to be released to the air, which is ongoing. Recently, USEPA released an on-line guide for School Administrators and Maintenance Workers entitled Proper Maintenance, Removal, and Disposal of PCB-Containing Fluorescent Light Ballasts. This document is available at https://www.epa.gov/epawaste/hazard/tsd/pcbs/pubs/ballasts.htm.
Until the late 1970s, PCBs were used as insulators in electrical equipment. USEPA banned the manufacture of PCBs in the United States in 1977, and then the processing and distribution in commerce of PCBs in 1979, except in totally enclosed equipment as per the Toxic Substances Control Act (TSCA). Use of PCB-containing ballasts was allowed to continue provided that the ballasts had not failed and PCBs were not leaking. USEPA notes that the pre-1979 light ballasts are well past their expected useful life and pose an excess risk due to fires, leakage of PCBs, and breakage.
USEPA states that the purpose of the on-line website is to provide information for school administrators and maintenance personnel about the risks posed by PCBs in light ballasts in schools and “how to properly handle and dispose of these items, and how to properly retrofit the lighting fixtures in your school to remove potential PCB hazards.” USEPA also states that “while intact PCB-containing light ballasts pose no immediate health threat, they are likely to fail over time.”
USEPA’s on-line guide is relatively short, only eight pages long, and is written for the non-scientist. When reviewing the guide it is clear that USEPA’s intent is to encourage schools to remove all older light ballasts containing PCBs whether they are leaking or not, and to assume that they are PCB-containing if there is any question at all as to whether they may contain PCBs. To reinforce their point, USEPA provides several stories of how PCB-containing light ballasts have leaked or caught on fire, thereby exposing students and teachers to PCBs. Finally, USEPA argues that replacing the older light ballasts with new high efficiency, Energy Star lighting that will pay for the retrofit, generally in less than seven years. In general, the USEPA guide provides the following information:
- Background on PCBs and potential health risks.
- Identifying fluorescent light ballasts that may contain PCBs.
- Whether PCB-containing fluorescent light ballasts should be removed.
- How to handle ballasts containing PCBs.
- Risks and potential costs if PCB ballasts are not replaced.
- Dangers to students and teachers from PCB-containing ballasts.
- Cleanup and decontamination as a result of a ballast leak or fire.
- Procedures for replacing ballasts.
- Procedures and regulations for managing PCB cleanup wastes and PCB-containing ballasts.
- Governmental and non-governmental resources to pay for a retrofit.
Finally, after reviewing this guidance if the school administrator or maintenance personnel have not concluded that they must remove all old fluorescent light ballasts from their facilities, USEPA states that “Postponing a lighting retrofit and betting on the structural integrity of old ballasts may result in health and educational impacts for your students and staff and serious cost impacts for your budget.”
This article was authored by Greg Tieman, Acacia Environmental Group LLC. For more information on the author see here.