According to recently published guidance, the EPA views the nation’s school buildings as hotbeds of ancient fluorescent lighting ballasts (FLBs) containing toxic polychlorinated biphenyls (PCBs).  This guidance, like others before it, urges school boards to inspect their lighting and replace PCB-containing lighting fixtures whether or not they are leaking.  The Agency cites research showing that even nonleaking PCB-containing FLBs can be emitting PCBs into the interior air of a school and endangering the health of occupants. 

PCBs are persistent, bioaccumulative, and toxic (PBT) pollutants, which means they generally do not have an acute health effect but can be harmful if inhaled over an extended period of time. 

Replacement of PCB-containing lighting is not a required activity, and federal regulations kick in only when PCBs spill outside the lighting fixture.  Detailed regulations also apply to disposal of PCB wastes.  Many states have regulations regarding PCBs in lighting fixtures, which are more stringent than the federal baseline.  School boards should check with their state hazardous waste agencies if they intend to replace and dispose of PCB-containing lighting.

7-year payback

The EPA recognizes that large-scale lighting replacements are probably not top priorities for economically strapped school boards.  But the Agency argues that modern institutional light fixtures are 30 percent to 50 percent more efficient that the old T12 fixtures that may contain PCBs. (Only T12 magnetic FLBs, not T8 or T5 FLBs, may contain PCBs.  The "T" designates the lamp that goes with the FLB as "tubular" shape.  The number after the "T" represents the lamp diameter in eighths of an inch.) 

Replacement costs can be recouped in less than 7 years, depending on hours of operation and local energy costs, says the Agency.  That may not be a great inducement for school boards, although states do provide financial assistance.  Also, the worst PCB leaks from FLBs may necessitate costly emergency cleanups, compliance with regulations for storage and disposal of contaminated equipment and cleanup materials, taking classrooms or cafeterias out of use, lost school days, and medical exams.  

Reported failures

Much of the challenge with PCB-containing lighting fixtures is that they are so durable.  The EPA phased out the processing or use of PCBs in 1979, except in totally enclosed equipment.  However, a large number of FLBs that were installed before the ban, or that were stored and later used after the 1979 phaseout, may contain PCBs and may still be in use in U.S. schools. 

Depending on the number of operating hours, operating temperature, and on/off cycles, the typical life expectancy of a magnetic FLB is between 10 and 15 years.  This means that all the pre-1979 FLBs in lighting fixtures that are still in use are now far beyond their typical life expectancy, increasing the risk of leaks, smoking conditions, or even fires.  According to the Agency, recent reports show that from September 2012 to August 2013, 130 schools in New York and New Jersey reported FLB failures that may have released PCBs; 111 of the reports involved smoking or odor conditions from FLBs.

Furthermore, FLBs may not always be located in fluorescent lighting fixtures.  New York City public schools found remote FLB cabinets in the hallways of 16 of their school buildings.  These cabinets are essentially large, high-voltage electrical panels that house up to 20 FLBs. The EPA has also received reports of leaking PCBs in FLBs in schools in Oregon, North Dakota, and Massachusetts.

Identifying PCB-containing FLBs

To determine whether your school has PCB-containing FLBs, conducting a visual inspection of the FLBs in a representative number of light fixtures (not just the bulbs) is recommended.  Here are several guidelines for identifying FLBs that may contain PCBs:

• FLBs manufactured before July 1, 1979, may contain PCBs.
• FLBs manufactured between July 1, 1978, and July 1, 1998, that do not contain PCBs must be labeled No PCBs.
• If an FLB is not labeled No PCBs, it is best to assume it contains PCBs unless it is known to be manufactured after 1979.
• FLBs manufactured after 1998 are not required to be labeled.
• If the FLB does contain PCBs, they are located inside the small capacitor located within the FLB or in the potting material (a black, tar-like substance that encapsulates the internal electrical components).
• There would be approximately 1 to 1.5 ounces of PCBs in the capacitor itself and lower amounts in the potting material.
• If a FLB fails or overheats, the capacitor may break open, and both its oil and the potting material may be released from the FLB.
• PCBs may be present as a yellow, oily liquid or in the tar-like potting material that leaks from the FLB.
• The capacitor does not always leak when the FLB fails, nor does a leaking capacitor always cause the FLB to fail.

Information

EPA’s December 2013 guide

A chart showing disposal requirements for fluorescent light ballasts

An April 2013 Department of Energy guide for financing energy upgrades in K–12 school districts