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PCB Advisory for Schools: How Voluntary Lighting Retrofits Can Address Hidden Dangers California
Environmental
Protection Agency
State of California
The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy
consumption. For a list of simple ways you can reduce demand and cut your energy costs, see our web site at www.dtsc.ca.gov.
DTSC is one of
six Boards and
Departments within
the California
Environmental
Protection Agency.
DTSCs mission is
to restore, protect
and enhance the
environment, to
ensure public health,
environmental
quality and
economic vitality,
by regulating
hazardous waste,
conducting and
overseeing cleanups,
and developing and
promoting pollution
prevention.
Advisory
June 2003
D
EPARTMENT

OF
T
OXIC
S
UBSTANCES
C
ONTROL
PCB Advisory for Schools:
How Voluntary Lighting Retrofits
Can Address Hidden Dangers
Advisory Contents
1. Purpose ................................................................................................ 1
2. PCBs - Historical Use ........................................................................... 2
3. PCB Hazards - Health Concerns ........................................................... 2
4. Laws, Regulations, and Penalties for Mishandling PCB Wastes .............. 3
5. Health and Safety Considerations during PCB Work ............................ 4
6. Management of PCB-Containing Materials .......................................... 5
7. Lighting Retrofit Management ............................................................. 6
8. Emergency Responses for PCB Ballast Leaks or Fire .............................. 8
9. Public Concerns and Complaints .......................................................... 9
Attachment A: Funding Resources for School Lighting Retrofits ...............10
Attachment B: Publications about PCB Retrofits ...................................... 11
Attachment C: Wipe Sampling Plan (Protocols) ....................................... 12
Attachment D: Air Sampling/Monitoring Plan (Protocols) .......................16
1. Purpose
The Department of Toxic Substances Control (DTSC) developed this Advisory
to assist school districts in addressing potential contamination from fluorescent
light ballasts containing polychlorinated biphenyls (PCBs). This Advisory alerts
school districts to the potential hazards from aging PCB ballasts and provides
guidance for identifying, removing, and managing PCB ballasts. The Advisory
also provides information regarding the availability of DTSC oversight for man-
agement of PCB releases and cleanups. Additional funding resources for retrofit
and waste disposal costs are also discussed, such as energy assistance grants and
school modernization bonds.
The California Education Code requires DTSC to oversee environmental assess-
ments for proposed school sites that will receive state funding for acquisition
and/or new construction. These requirements were developed in order to address
concerns raised by parents, teachers, local communities, and the state legislature.
Environmental assessments identify hazardous materials which may pose a health
threat to children and faculty on school properties.
Acknowledgment: Photos were provided by U.S. EPA or obtained from school projects
under DTSCs oversight. 2
Recently, DTSC has been called upon to assist school districts where leaking
light ballasts containing PCBs were found in classrooms, potentially expos-
ing teachers and students to chemical hazards. Although production of PCBs
was banned in the United States by the Toxic Substances Control Act (TSCA)
in 1978, continued use of PCB-containing items was not prohibited. All
light ballasts manufactured through 1978 were magnetic and contained PCBs.
Almost all older fluorescent light fixtures have PCB ballasts. Light fixtures
containing PCB ballasts were distributed until about 1980.
DTSC recommends that school districts survey and inventory all light fix-
tures and begin replacing those identified to contain PCBs in the ballasts.
Postponing a lighting retrofit may increase the risk of a PCB leak or fire,
which could result in serious health and environmental impacts for students
and staff, escalated replacement costs due to the need for emergency cleanups, and possible penalties for violation
of laws. A school that voluntarily retrofits its aging light ballasts might expect to recover its costs within two years
with potential rebates and lower energy costs with the installation of new energy-efficient lighting systems.
2. PCBs Historical Use
PCBs are man-made chemicals commonly used in the past as coolants and lubricants. The use of PCBs as
insulation in electrical equipment was popular because they are very stable chemicals with low water solubility,
high boiling point, low flammability and low electrical conductivity. Prior to 1978, PCBs were often used in the
manufacturer of transformers and capacitors. They are associated with waste oil, caulking compounds, hydraulic
systems, and fluorescent light ballasts.
PCBs were produced in the United States (U.S.) from approximately 1929 to 1977. PCB production was
banned by TSCA in 1978 due to evidence showing that they accumulated in the environment and were linked to
harmful health effects. However, TSCA did not prohibit the use of PCB-containing items manufactured prior to
the 1978 ban. It is estimated that fluorescent light fixtures containing PCB ballasts were available until 1980.
Many of these PCB-ballasts are still working far beyond their intended life; as they age, they become more likely
to leak or drip.
PCBs are found in the form of a clear to yellow, heavy oily liquid or waxy solid. Light
ballasts are the electronic components generally located at the end of fluorescent light
fixtures under a metal overplate. Prior to 1978, ballasts were commonly manufactured
with PCBs in the capacitor oil and in a tar-like substance that surrounds ballast compo-
nents called potting compound. The capacitor and potting compound, encased in metal,
contain about an ounce of nearly pure (90%) PCBs.
3. PCB Hazards Health Concerns
The most common health effect that has been found in people exposed to high levels of PCBs for short periods
of time are skin conditions such as acne and rashes. Liver effects and damage have also been reported following
high levels of exposure. Women who have been exposed to high levels of PCBs have been reported to have had
babies with lower birth weights and some problems with motor skills and memory. Of greatest concern is that
prolonged exposures to PCBs may cause cancer in people, based on information from animal studies. Additional
health effects that have been seen in animals exposed to PCBs for long periods include changes in the immune
system and impaired reproduction.

PCBs leaking on to a classroom
tool box. 3
PCBs do not readily break down into safer chemicals in the environment and they have been shown to persist for
many years. People can also store PCBs in their fat tissue for many years, which can reflect a number of environ-
mental sources of PCB exposures. If a PCB-ballast catches on fire, the PCB oil may produce by-products, such
as dioxin and furans, generally considered more toxic than PCBs themselves.
The most common ways that people can be exposed to PCBs from leaking light ballasts is by touching or
accidentally ingesting PCB oils or PCB-contaminated materials. When PCBs are present in high concentration,
people may also be exposed by breathing contaminated air. Given the nature of PCBs and their possible adverse
health effects, a conservative approach is recommended to minimize the possibility of exposure. For more infor-
mation about the health effects of PCBs, please refer to the following Web sites: www.epa.gov/pcb/effects.html or
www.atsdr.cdc.gov/tfacts17.html.
As PCB ballasts age, the chemicals may leak out and create a potential health and environmental hazard. The hazard
is worsened when the incident is mishandled. U.S. EPA reported that improper cleanup of leaking ballasts at several
schools in Oregon in 1999 and 2000 potentially exposed school staff and maintenance workers to PCBs.
4. Laws, Regulations, and Penalties for Mishandling PCB Wastes
Laws and Regulations
PCB manufacture, use, storage and disposal are regulated by U.S. EPA under TSCA and Part 761, Title 40 of the
Code of Federal Regulations (40 CFR Part 761). TSCA regulates any materials or wastes that contain PCBs at
concentrations of 50 ppm (parts per million) or greater. Light ballasts containing PCB oil in the small capacitor
or the potting compound are included in this regulation.
Leaking PCB ballasts are regulated as hazardous wastes and toxic substances. Proper handling and cleanup of
leaking PCB ballasts is necessary to protect public health and the environment. TSCA regulates disposal of PCB
wastes with concentrations over 1 ppm. Leaking PCB light ballasts often generate wastes in excess of 1 ppm. In
addition, PCBs are regulated under TSCA if an impervious surface shows 10 micrograms (ug) per 100 square
centimeters (cm
2
) of PCBs. Examples of this in the classroom are the surfaces of floors, desks, and bookcases.
PCB wastes are also regulated as hazardous waste by DTSC under the Health and Safety Code (HSC) and Title
22 of the California Code of Regulations (22 CCR). Criteria for determining PCB wastes are:
total threshold limit concentration (TTLC) of 50 ppm of PCBs, and/or
soluble threshold limit concentration (STLC