Veterinary Compliance Assistance


On September 25, 2009, the U.S. Environmental Protection Agency announced a series of steps that building owners and school administrators should take to reduce exposure to PCBs that may be found in caulk in hospitals constructed or renovated between 1950 and 1978. More.

Polychlorinated biphenyls, or PCBs, are a class of highly stable organic compounds with good electrical insulating and dielectric properties. PCBs were used for many years in heavy duty electrical equipment, and for many other applications. Eventually, their health and environmental effects began to be understood, and their use was banned by Federal law in 1979. However, PCB-containing equipment can still be found in many facilities. Veterinary facilities managers need to be aware of the rules that apply to any PCBs that may exist on their sites, particularly during renovations.

This page contains a brief summary of the federal rules, with links to additional information.

General Background

For decades, PCBs were widely used in hundreds of industrial and commercial applications, including (among many other applications):

  • Dielectric fluids in electrical equipment like transformers and capacitors
  • Heat transfer fluids
  • Hydraulic fluids
  • Plasticizers in paints, plastics and rubber products
  • "Vehicles" in pigments, dyes and carbonless copy paper

PCBs were valued for their non-flammability, chemical stability, high boiling point and electrical insulating properties.  More than 1.5 billion pounds of PCBs were manufactured in the United States prior to cessation of production in 1977.

Unfortunately, PCBs were later found to have a number of harmful effects.  They were also so stable that, once released into the environment, they could persist for decades.  Once ingested by organisms, they were found to accumulate in tissues (being fat soluble, they could pass into fatty tissue, but being non-water soluble, they could not readily be excreted again).  They would then become more concentrated as material from lower organisms moved up the food chain, ultimately causing deleterious health effects in humans.

TSCA Regulations for PCBs

As of July 2, 1979, federal law banned U.S. production of PCBs through the Toxic Substances Control Act (TSCA). However, it remains a potential legacy problem. PCB-containing materials may be present at facilities, and PCB-laden wastes may be generated during renovations.

Note that federal PCB regulations and requirements apply both to PCB waste materials and to PCBs still in use.

Items with a PCB concentration of 50 ppm or greater are regulated for disposal under 40 CFR Part 761. Some potential sources of PCBs in veterinary facilities include:

  • Mineral-oil filled electrical equipment such as motors or pumps manufactured prior to July 2, 1979;
  • Capacitors or transformers manufactured prior to July 2, 1979;
  • Plastics, molded rubber parts, applied dried paints, coatings or sealants, caulking, adhesives, paper, Galbestos, sound-deadening materials, insulation, or felt or fabric products such as gaskets manufactured prior to July 2, 1979;
  • Fluorescent light ballasts manufactured prior to July 2, 1979;
  • Waste or debris from the demolition of buildings and equipment manufactured, serviced, or coated with PCBs; and
  • Waste containing PCBs from spills, such as floors or walls contaminated by a leaking transformer.

The general requirements for handling PCB materials and equipment include:

  • Identifying and labeling the material.  Marking is required for all PCB items, containers, storage units or areas.  Follow EPA established marking requirements, including size, color, and location of the marks.  You can find an example of the two approved PCB labels in 40 CFR Part 761.45.
  • Notifying EPA.  If you are storing or disposing of PCB waste, complete a Notification of PCB Activity Form and mail it to the Fibers and Organics Branch of the National Program Chemicals Division in EPA's Office of Pollution Prevention and Toxics (OPPT). EPA will assign an identification number (ID number) to the veterinary facility for handling PCBs. This ID number is for activities involving PCBs and may not be used for any other waste activities. If the veterinary facility has already received an ID number for other regulated wastes (e.g., RCRA), EPA will verify the number and assign the same ID number for the site's PCB activities.
  • Properly store the material. Items must be stored in accordance with EPA requirements. Storage requirements for PCB-containing materials depend on the end use of those materials. You can store approved materials for reuse for up to five years in an approved, permanent, PCB storage area. PCB articles and containers must be dated and properly labeled when placed into storage for disposal requirements. Temporary storage areas may be used for up to 30 days.
  • Properly disposing of the material. EPA specifies requirements for disposal of all PCB wastes with PCB levels >50 ppm. Rules for disposal are found at 40 CFR 761.60.
  • PCB cleanup. Must follow PCB Spill Cleanup Policy.
  • Record Keeping and Reporting. EPA requires that records be maintained for the storage, transportation, and disposal of PCBs for at lest three years. Rules for recordkeeping and reporting are found at 40 CFR 761.398.

More Resources

EPA's PCB webpage.  EPA provides various paths for the public to access information about PCBs.

TSCA Disposal Requirements for Fluorescent Light Ballasts. Disposal requirements vary depending on the type of capacitor and plotting material.

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