24 Energy Savings Plus Health | INDOOR AIR QUALITY GUIDELINES FOR MULTIFAMILY BUILDING UPGRADES
PRIORITY ISSUE 4.0 POLYCHLORINATED BIPHENYLS (PCBs)
ASSESSMENT PROTOCOLS (AP) MINIMUM ACTIONS (MA)
EXPANDED
ACTIONS (EA)
AP 4.1 Determine Whether Fluo-
rescent Light Ballasts Containing
PCBs Are Present
Some multifamily residential build-
ings may contain fluorescent light
fixtures with ballasts manufactured
before 1979 that contain PCBs.
Ballasts manufactured between
July 1, 1978 and July 1, 1998
that do not contain PCBs were
required to be labeled "No PCBs."
Newer fluorescent lighting typically
uses electronic ballasts that do
not contain PCBs and should be
clearly marked as electronic.
If fluorescent light ballasts do not
have the statement "No PCBs"
or are not marked as electronic,
assume that the ballasts contain
PCBs or contact the manufacturer
to determine whether the ballasts
contain PCBs. If the manufacturer
is not sure whether the ballasts
contain PCBs, assume that they
do.
AP 4.2 Assess Caulk That Will Be
Disturbed
Assess whether caulk will be
disturbed during the building up-
grade activities. Consider the age
of the structure, since buildings
built or renovated between 1950
and 1979 may be more likely to
contain PCBs in caulk. Typical
locations include around windows,
door frames, masonry columns and
other masonry materials.
Note:
PCBs were not added to caulk after
1979; however, caulk containing
PCBs manufactured before 1979
could have been used in buildings
after that time.
MA 4.1 Replace PCB-Containing Fluorescent Light Ballasts
Whether PCBs are confirmed or assumed to be present, new lighting
fixtures can be used to replace the existing fixtures. PCB-contain-
ing fluorescent light ballasts that are leaking must be replaced and
properly disposed of pursuant to EPA regulations, as described
in 40 CFR Part 761 Subpart D. Any oil and stains leaked from
PCB-containing ballasts also must be properly cleaned up or dis-
posed of in accordance with the PCB decontamination or disposal
regulations. EPA recommends that non-leaking PCB-containing flu-
orescent light ballasts also be replaced because of their increased
likelihood to fail and leak and because of the increased energy
efficiency of new ballasts.
MA 4.2 Address Caulk Potentially Containing PCBs When It
Will be Disturbed During Building Upgrades
If PCBs are potentially present in caulk and the caulk will be dis-
turbed during the building upgrades (e.g., window or door replace-
ment, improved weatherization sealing), take steps to minimize
exposure. For more information, go to Polychlorinated Biphenyls
(PCBs) in Building Materials.
MA 4.3 Properly Dispose of PCB-Containing Light Ballasts,
Caulk and Other Materials
When removing PCB-containing light ballasts, caulk and other
materials contaminated by PCBs, specific notification, packing,
reporting, storage, transportation and disposal requirements apply,
see 40 CFR Part 761. Ensure that waste management also meets
local and state requirements. Document and store copies of all
test results. Include documentation of all sampling locations and
disposal measures, including disposal companies used and final
destination of waste materials.
EPA Regional PCB Coordinators are a resource for all PCB issues.
Note:
Fluorescent light bulbs contain small amounts of mercury. Ensure
that the bulbs are handled properly to avoid breakage and the
release of contaminants. More information on fluorescent bulb
disposal requirements may be obtained from your state solid and
hazardous waste agencies. See Priority Issue 23.0 Protecting IAQ
During Construction for more information on limiting exposure to
mercury.
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References for Priority Issue 4.0 Polychlorinated Biphenyls (PCBs):
EPA: Polychlorinated Biphenyls (PCBs) in Building Materials
EPA: PCB-Containing Fluorescent Light Ballasts (FLBs) in School Buildings
EPA: Polychlorinated Biphenyls (PCBs)
EPA: Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, And Use Prohibitions, 40 CFR Part 761
Subpart D—Storage and Disposal
EPA: Recycling Mercury-Containing Light Bulbs (Lamps)
EPA: Regional PCB Contacts
EPA: Steps to Safe Renovation and Abatement of Buildings That Have PCB-Containing Caulk
See Appendix A: Worker Protection