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$23,000 PCB Storage Penalty for Lamp Recycler Under TSCA

Posted on 6/9/2016 by Roger Marks

According to a US EPA press release, a lamp recycler in Windsor, CT will pay $23,000 to settle allegations personnel mishandled PCB-containing light ballasts. PCBs—polychlorinated biphenyls—are  known carcinogens subject to specific handling and management rules under the Toxic Substances Control Act (TSCA).

Specific violations uncovered by an EPA inspection include:
  • Storing more light ballasts than permitted
  • Failure to mark ballasts with out-of-service dates
  • Failure to put in place secondary containment to mitigate the risk of a release
Manufacture of PCBs has been banned in the US since 1976, but some old fluorescent lighting ballasts (FLBs) may still contain PCBs. EPA has provided some guidance on this subject on a dedicated PCB page to help EHS professionals determine whether a piece of equipment can be reasonable expected to contain PCBs:  

  • FLBs manufactured before July 1, 1979 may contain PCBs
  • FLBs manufactured between July 1, 1979 and July 1, 1998 that do not contain PCBs must be labeled "No PCBs"
  • If an FLB is not labeled "No PCBs," it is best to assume it contains PCBs unless it is known to be manufactured after 1979
  • FLBs manufactured after 1998 are not required to be labeled

PCB containing lighting ballastTSCA Reform Passes Congress

A long-awaited major overhaul of TSCA was recently approved by both houses of US Congress. Once signed by the President, the revisions—dubbed the Frank R. Lautenberg Chemical Safety in the 21st Century Act for the longtime New Jersey Senator for whom chemical reform was a major career goal—will become law. Now we wait for US EPA to author, propose, and finalize the implementing regulations. Check out the changes to TSCA here.

Understand Your TSCA Responsibilities

The 2016 period for chemical manufacturers, importers, and processors to submit Chemical Data Reporting (CDR) data officially kicked off on June 1. Be confident you know what to report, when, and how to submit the information to US EPA. The TSCA Regulations Online Course will help identify the chemical management and reporting requirements that apply to your site, including the unique  management standards for PCBs.

Tags: EPA, fines and penalties, TSCA

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