Lighting fixtures with ballasts containing PCB and light bulbs containing mercury pose health, environmental and financial risks unless properly managed. In many locations these materials can be disposed of as normal waste but a growing number of states prohibit these materials from going to landfills.
Mercury-containing bulbs are one of many mercury sources that could impact the environment during disposal. Mercury-containing lamps are discussed on our lamp recycling page.
Ballasts and capacitors with PCB in the dielectric fluid were common, manufacturing practice until outlawed in 1979. The estimate is that 300 million capacitors containing PCB remain in service. Magnetic ballasts for fluorescent and high intensity discharge lamps must be assumed to contain PCB unless labeled "No PCB."
Service Lamp can provide complete ballast recycling. This page discusses:
Electronic ballasts used for fluorescent, compact fluorescent and high intensity discharge lighting do not contain PCB. Electronic ballasts do not pose a health or environmental risk because of their content. Recycling to recover metal used in the case and circuitry is the recommended means of disposing of electronic ballasts as with any other electronic product.
Electronic ballasts are used most commonly with T8 and T5 linear fluorescent lamps. This type of ballast is also used with pin base compact fluorescents as well.
Electronic ballasts for T12 lamps have recently been introduced to replace magnetic ballasts. Electronic ballasts are not regulated as hazardous waste and can be disposed of safely in landfills and municipal incinerators.
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Magnetic ballasts containing PCB fall under government regulation. The Toxic Substances Control Act of 1976 (TSCA) bans the manufacture and distribution of PCB and regulates disposal and storage of ballasts. "Large quantities" of ballasts should be disposed of at hazardous waste incinerators or chemical waste landfills. The regional EPA office serving the Pacific Northwest defines a "large quantity" as five or more ballasts per year. Retail stores, offices and schools operating T12 fluorescent fixtures could easily experience five failures in a year.
Check with your regional EPA office to determine their definition of a "large quantity" and check with your city, county or state EPA to determine if disposal of magnetic ballasts containing PCB is regulated further. Many states and jurisdictions have developed regulations governing the disposal of non-leaking, PCB-containing ballasts that are more stringent than Federal regulations.
The Superfund Law
The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA or Superfund Law) provides extensive liability for improper hazardous waste disposal. Liability can extend to individuals within an organization who knowingly direct the improper disposal of hazardous waste. Anyone disposing of more than one pound of PCB, 12-16 magnetic fluorescent ballasts, or mercury in any landfill is a Potentially Responsible Party in any subsequent Superfund cleanup of the landfill. CERCLA also requires building owners and waste generators to notify the National Response Center at (800) 424-8802 when disposing a pound or more of PCB, roughly 12-16 magnetic ballasts, in a 24-hour period.
It is important to note that contracting for the disposal of hazardous waste does not necessarily relieve the waste generator from CERCLA liability. The contractor should be qualified and supply required documentation.
Non-leaking, PCB-containing ballasts
A ballast containing PCB is not necessarily hazardous waste. It would be good practice to treat it as such until the disposal is complete. The key phrase is "non-leaking, PCB-containing ballast."
Once a capacitor is ruptured, the ballast and anything that comes in contact with the heavy, yellowish oil becomes hazardous waste.
This presents the waste generator with an interesting situation. While federal law says ballasts with non-leaking, PCB containing ballast are not hazardous waste that does not release the organization or individual from Superfund liability if a cleanup is required. The only safe and reasonable course is to recycle magnetic ballasts.
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Fluorescent bulbs that are recycled result in about 95% of the material by weight being reused. Recycling PCB-containing fluorescent ballasts reclaims some metal but the potting material and capacitors are processed for incineration rather than being recycled. Incineration is by a certified, high temperature facility. Municipal incinerators are not sufficient for disposing PCB or PCB contaminated material.
EPA has, since 2001, strongly advocated retrofit -- removing installed ballasts and replacing with new, electronic ballasts. Clearly magnetic ballasts containing or with the possibility of containing PCB pose a risk to the building owner, occupants and the waste generator.
The risk and attending cleanup and disposal cost increases dramatically in the event of fire. Partially burned PCB creates dioxins held to be more toxic than the PCB. The risk in the event of fire in the building or in the fixture itself plus the fact that more energy efficient ballast-lamp systems are available should make retrofit a priority in all applications.
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For additional information on recycling lamps and ballasts or call Service Lamp, 800-222-LAMP.