Search

Question of the Week: PCB Waste Management

Posted on 7/12/2011 by James Griffin

Q. We are doing some building maintenance and have removed or replaced a number of our fluorescent lighting fixtures. As a result, we have an assortment of lighting ballasts. I know that polychlorinated biphenyls (PCBs) are regulated under TSCA and not RCRA. Can I presume that our lighting ballasts contain less than 50 ppm PCBs? If not, how do I determine whether the ballasts contain PCBs?
 
A. As you indicated in your question, discarded electrical equipment containing PCBs are subject to the Toxic Substances Control Act (TSCA) regulations at 40 CFR Part 761. If this equipment exhibits the toxicity characteristic only, then it may be excluded from the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations [40 CFR 261.8]. It is important to note that this is a Federal exclusion. Some states have hazardous waste management regulations that are more stringent than the Federal rules and may still regulate them under their RCRA hazardous waste rules. In these cases, the waste would be subject to both TSCA and State hazardous waste management regulations.
 
Under the TSCA rule, you cannot presume that your discarded lighting ballasts have less than 50 ppm PCBs. The PCB regulations do not create any assumptions about the PCB concentrations in fluorescent light ballasts. Fluorescent light ballasts are regulated for disposal under 40 CFR 761 when they contain > 50 ppm PCBs when disposed. Disposal options depend on whether the PCBs are found in an intact and non-leaking PCB small capacitor, a non-intact or leaking PCB small capacitor, or in the potting material [40 CFR 761.50(b)(2)]. 
 
If there is no label indicating that there are no PCBs (ballasts manufactured after July 1, 1979 were required by the EPA to be labeled “No PCBs”), the EPA has recommended two options. First, you could assume that the potting material contains PCBs at 50 ppm or greater and dispose of the ballast as PCB bulk product waste in accordance with 40 CFR 761.62. Alternatively, you could conduct a survey of the manufacturer and type of ballasts in use in the building and develop a random sampling plan for each manufacturer and type of ballast found and analyze the samples for PCBs. However, regardless of the results of the survey, you are responsible for the proper disposal of each ballast. 
 

Tags: EPA, TSCA

Find a Post

Compliance Archives

Lion - Quotes

Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right.

Gregory Thompson

Environmental, Health & Safety Regional Manager

Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!

Stephanie Weathers

SHE Specialist

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly.

Brittany Holm

Lab Supervisor

The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!

Sara Sills

Environmental Specialist

These are the best classes I attend each year. I always take something away and implement improvements at my sites.

Kim Racine

EH&S Manager

My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material.

Robert Roose

Manager, Dangerous Goods Transportation

Download Our Latest Whitepaper

Look beyond the annual "Top 10 List" to see specifics about the most cited OSHA health & safety Standards and the individual regulations that tripped up employers the most last year. 

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.