Identifying and Handling PCB Ballasts During a Lighting Retrofit

Prior to the late 1970's, ballast manufacturers used a group of compounds called polychlorinated biphenyls, or PCBs, to insulate and cool the inner components in certain electrical products. One common application was to cool the internal capacitor of fluorescent lamp ballasts. These components contained a small amount of PCB oil and most of it is typically absorbed by several layers of paper within the device. Since these compounds were found to be health hazards and were linked to the development of certain cancers, they were prohibited by the US Congress in 1979. The risk of PCB leakage is quite low, however anyone considering a lighting retrofit project, or involved in these types of projects routinely, must understand how to determine if a ballast contains PCBs and what to do if it does.

Identification

There are several methods that can be used to determine if ballasts contain PCBs:

• Ballasts that were manufactured without PCBs will have a very obvious "No PCBs" mark on the manufacturer’s label.
• Many manufacturers will imprint a manufacturing date on the ballast case. Any ballast with a manufacturing date prior to 1979 should be assumed to contain PCBs. This may lead to false positives, but it would eliminate the risk of downstream contamination. Date codes after July 1, 1980, can be considered to not contain PCBs.
• If the building was erected after July 1, 1980, there is a good chance that the light fixtures were manufactured after the legislative cutoff for PCBs and therefore be PCB-free.

Unfortunately, after many years of exposure to heat, dust and other elements, the labels on old ballasts become illegible or are missing altogether. If PCBs cannot be ruled out based on the age of the building or lighting system as a whole, the prudent response would be to treat suspect ballasts as if they did contain PCBs. This is especially true if PCB ballasts have already been found in the facility.

Screening and Disposal

When working in a facility where PCB ballasts may be present, the safest course of action is to screen all fixtures being removed. In cases where the risk of misidentifying a PCB ballast as non-PCB is high, it may be beneficial to remove all ballasts from old fixtures. Requiring the same amount of effort for both types of ballasts ensures a consistent process will be followed. Ballasts that are positively identified as not containing PCBs can safely be disposed of in the standard waste stream or sent to a recycling facility that can reclaim the metals. All other ballasts should be treated as having PCBs. These must be sealed in a poly bag and placed inside an 18-gauge steel drum. The drum must be properly labeled and, when full, locked with a ring and bolt. Personnel working with PCB ballasts should wear nitrile gloves and disposable coveralls. All gloves, coveralls and any cleaning materials that are used should be disposed of with the PCB ballasts in the steel drums.