February 26, 1987

Mr. Robert Sawyers
41 Edith Place
Merrick, New York 11566

Dear Mr. Sawyers:

Thank you again for your letter of December 21, 1986, in which you requested information on Polychlorinated Biphenyls (PCB). I hope you received the interim letter from Deborah Feldman of my staff explaining the delay in our response. We have completed our data collection on PCB and are now able to address your specific questions.

1. First of all, not all fluorescent light ballasts contain PCB. The Environmental Protection Agency (EPA) banned the manufacture of PCB in 1978. Thus, all light ballasts manufactured thereafter should not contain PCB. Additionally, EPA requires that light ballasts manufactured after 1978 be labeled by the manufacturer indicating that the ballast does not contain PCB ("NO PCB" notation). Since the use of PCB in light ballasts was not regulated by EPA prior to 1978, any ballast without a label must be assumed to contain PCB. Therefore, you can check the light ballasts in the respective classroom to determine if you have a problem.

If it turns out that the ballasts are not labeled, suggesting that it contains PCB, do not be alarmed. The actual amount of PCB contained in the ballast is very small, approximately 1.5 ounces. Also, the fact that you may have a defective light ballast does not necessarily give rise to PCB release. The incidence of such, is minimal. Additionally, the amount of airborne concentrations in the classrooms will vary according to the type of air circulation and room size.

John Kominsky, an industrial hygienist at the National Institute for Occupational Safety and Health (NIOSH) studied PCB contamination from defective fluorescent light ballasts. We have enclosed a copy of his draft report as well as two pertinent health hazard evaluation reports. He concluded that short term exposure to PCB after an electrical burnout does not pose a significant health risk. However, a burnout can result in an increase in airborne and surface concentrations depending upon size of room and ventilation. To prevent continued exposure, the rooms should be ventilated and tables and chairs should be wiped.

2. The Occupational Safety and Health Administration (OSHA) has an air contaminant standard for exposure to PCB of 1 milligram of PCB per cubic meter of air averaged over an eight hour workshift. there are no other requirements with regard to PCB. OSHA does not have a standard for PCB contamination on hard surfaces.

3. The information presented in your letter is not sufficient for response. We must know the exact size of the classroom to calculate the concentration of pollutant in the air.

4. The following recommendations are offered by EPA:

a. Open all the windows to ventilate the room. Keep the room ventilated for up to 24 hours.

b. Wipe hard surfaces such as table tops, desks, chairs and uncarpeted floors with a paper towel. Surfaces should then be thoroughly cleaned twice. Only certain solvents and detergents are effective in cleaning up spilled PCBs. You may refer to the enclosed Fact Sheet for a detailed list.

For more explicit information see the enclosed Fact Sheet entitled "PCBs in Fluorescent Light Fixtures."

5. Yes. The room should be evacuated.

6. The EPA Fact Sheet indicates that the room could be reentered after it has been ventilated for 24 hours. However, in a telephone conversation with Ms. Denise Kheenan of EPA, and Rick Hartle of NIOSH, they contended that the children could return to the classroom after cleanup. Ms. Kheenan's and Mr. Hartle's respective phone numbers are noted below if you wish to discuss this with them.

7. It is not necessary to have the room tested after burnout, but it may be a good idea to do so. You may contact the OSHA Long Island Area Office at the address listed below to discuss the situation with them. If the room is fully ventilated, the amount of PCB in the air should not pose any significant health risk.

8. There is no requirement to sample the room prior to reentering, but it may be prudent to do so. Again, you may contact the OSHA Long Island Area Office to discuss this with them.

9. Since sampling methods are updated frequently, to be assured the most recent sampling methods for PCB you should contact the OSHA Long Island Area Office at the address listed below.

10. Yes, but light ballasts should not fail that frequently. If you are having a problem with repeated leaking light ballasts, again contact the OSHA Long Island Area Office to discuss the situation with them.

11. Yes. Wear rubber gloves that will not absorb PCB and consider using goggles or a face shield and a rubber apron. Avoid personal contamination by not touching your face while wearing gloves.

Also, turn off the light fixture at the switch, and disconnect electricity at the fuse or breaker box. Let the ballast cool for 20 to 30 minutes before trying to remove the ballasts. For more specific information see the attached Fact Sheet.

12. The EPA recommends the following procedure: Remove the metal over the wiring and ballast unit. Loosen the ballast by taking out the metal screws which hold it to the end of the fixture. Cut the electrical wires going to the ballast and remove the ballast.

13. There is no requirement to install new ballasts that do not contain PCB, but it is prudent to do so.

The following are the addresses and telephone numbers referenced above:

US Department of Labor - OSHA
990 Westbury Road
Westbury, New York 11590
(Telephone: 516-334-3344)

Denise Kheenan
US EPA Chemical Regulation Branch
401 M Street, S.W. TS 798, Room NE 117
Washington, D.C. 20460
(Telephone: 202-382-3935)

Rick Hartle
NIOSH
4676 Columbia Parkway
Cincinnati, Ohio 45226
(Telephone: 513-841-4374)

We hope this information will be helpful to you. If you have any further questions, please contact us again.

Sincerely,



Richard D. Edsell
Director
Office of Science and Technology Assessment