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PCB Labeling and Handling for Regulatory Compliance

If items were not originally labeled by their manufacturer, the owner must label items that may contain PCBs.

Standard PCB labels are square and come in 1-in. increments from 2 in. x 2 in. to 6 in. x 6 in. (see Figure 2).

If the standard PCB label is too large to fit on a piece of equipment, a 1-in. x 2-in. PCB label may be substituted (see Figure 3).

When analytical results identify an item's PCB concentration, the concentration should be written in permanent ink on the label. When the equipment is determined to have a concentration of less than 5-ppm PCBs, a "Non-PCB" label should be affixed to the equipment. Labeling is also required for materials that do not contain PCBs. Large, low-voltage capacitors; small capacitors that are normally used in alternating circuits; and fluorscent light ballasts that do not contain any concentration of PCBs should be marked "No PCBs" by the manufacturer if manufactured after July 1, 1978.

Once a PCB Item is removed from service, the PCB Article or Container should also be labeled with the date when it was removed from service. In addition, other regulatory labeling requirements apply depending upon the contents of the container. See Appendix D for details.

Standard PCB, no PCBs, and non-PCB labels are available from EHSO

CAUTION: Aged labels on electrical equipment may not accurately represent the PCB concentration of the equipment's contents. For example, sealed transformers labeled as containing non-PCB oil may become contaminated with PCBs during servicing. Other reasons for erroneous labeling include:

bulletImproper sampling and/or analysis at the time of original labelingbulletEquipment alterations that may have caused a change in PCB concentration since the labelingbulletConfusion over the difference between the federal and the state definitions of the non-PCB classification.

Hence, electrical equipment, including sealed transformers originally labeled as non-PCB and maintained in service as non-PCB, should be handled cautiously. The equipment must be evaluated for PCBs and proper PCB classification when removed from service.

Handling Unidentified Equipment

The status of any unlabeled equipment suspected of containing PCBs must be determined through laboratory analysis, and the equipment subsequently labeled. Some items, such as small capacitors, electromagnets, switches, voltage regulators, circuit breakers, and PCB-contaminated Electrical Equipment, do not require identification and labeling as a condition for continued use. However, the PCB status of these items must be determined when the items are taken out of service.

Handling PCB Equipment

The regulatory requirements for handling PCB Equipment vary according to equipment type. The regulations divide PCB Equipment into several types:

bulletTransformersbulletCapacitorsbulletElectrical light ballastsbulletElectromagnets, switches, and voltage regulatorsbulletOther PCB Equipment.

The specific equipment requirements are described in detail in Appendix A. These requirements generally specify the conditions for continued equipment use and the frequency of equipment inspections.

It is important to note that PCB and PCB-contaminated Items stored for use and reuse are regulated as if they were in use.

To comply with federal law, you must maintain and annually update an inventory of all PCB Articles located onsite. Your company's Environmental Health & Safety Department (EHSD) should maintain this annual document log. Notify your Environmental staffabout any newly discovered and unlabeled PCB Equipment for inclusion in this log. Appendix B provides more information for EPD on the required recordkeeping.

Avoiding Radioactive Contamination of PCB Equipment

Users of PCB Equipment must take all precautions necessary to prevent radioactive contamination of PCBs. Few disposal options exist for radioactive PCBs.

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