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Lighting Retrofits, PCBs and Mercury
Important information:
Schools required to replace metal halide and mercury vapor lighting
Senate Bill 479
Important information for all building owners and school districts:
All fluorescent lights and many magnetic ballasts and thermostats contain hazardous materials that must be disposed of properly in order to avoid serious potential environmental and health problems. The Environmental Protection Agency (EPA) may issue substantial fines to business owners and school districts that do not follow defined disposal procedures even if the process is contracted to a third party. The following Web page contains information and valuable resource links regarding this important issue and we encourage you to read it.
Lighting retrofits are one of the most common and effective energy conservation measures available. Replacing T-12 lights and magnetic ballasts with T-8 lights or HID lights and electronic ballasts saves energy. In addition, these newer lights and ballasts provide a better quality of light, are quieter and last longer.
However, all fluorescent lights and many magnetic ballasts contain hazardous materials that must be disposed of properly. Fluorescent lights contain mercury, and old magnetic ballasts contain polychlorinated biphenyls (PCBs). If improperly disposed of, these materials can leach into ground water or surface waters and cause serious health problems. They can also cause health problems through direct contact as well. They can affect memory, vision, and hearing, damage the central nervous system, and have a permanent impact on fetal and child development.
In addition to potential health problems, you can be subject to hefty fines if you improperly dispose of these materials. These fines can be up to $27,000 per day.
As of January 1, 2004, the Oregon Business Energy Tax Credit Program requires project owners to report how any lighting fixtures and lamps replaced in a lighting project and thereafter will be recycled. The Program also requires that a project owner report how any replaced mercury-switch thermostats will be recycled. Proper disposal is an eligible cost and can be listed as such on the Business Energy Tax Credit application form.
In 1979, the EPA banned the further manufacture of equipment containing PCBs. Ballasts manufactured after 1979 that do not contain PCBs are labeled "Non-PCB."
But, most fluorescent light ballasts manufactured before 1979 used capacitors containing PCBs. Sealed inside the capacitor is about a teaspoon of concentrated PCBs. Potting material surrounds the capacitor, which is encased in a ballast box. Magnetic ballasts containing PCBs must be disposed of in accordance with formal hazardous waste procedures.
Postponement of a lighting retrofit only delays an impending problem. A ballast leak or fire could take place without warning at any time. If a leak or fire happens in the middle of a work day, employees could face serious long-term health problems. In addition cleanup is lengthy and costly.
Organizations are responsible for leaks in their fluorescent lighting ballasts. When conducting a lighting retrofit an organization becomes a generator of PCB-containing ballast waste and could be liable in any potential Superfund cleanup for improper disposal or release into the environment.
The Toxic Substances Control Act of 1976 was enacted by Congress to give the EPA the ability to track the 75,000 industrial chemicals currently produced or imported into the United States.The Seattle Office of the EPA conducts inspections, usually at utilities, scrap and salvage dealers, pulp and paper industry, wood product mills, commercial buildings, large universities, and federal facilities. The EPA is authorized to issue civil penalties of up to $27,000 per day per violation and criminal penalties.
In order to remove PCBs from a facility, you must hire a qualified contractor with experience in PCB-removal, or provide adequate in-house disposal training in compliance with EPA regulations. Federal law requires that, as a generator of PCB (or any hazardous waste) a Uniform Hazardous Waste Manifest must be completed. A copy of this document is available from the disposal company scheduled to receive the waste.
A business, school, or organization is also required to have a hazardous waste generator identification number. You can obtain this number by filling out and submitting EPA form 7710-53. (Click here for Instructions)
Proper disposal of ballasts containing PCBs is an eligible cost for the Oregon Business Energy Tax Credit as well as SB1149 public purpose funds for schools.
Mercury is a toxin that does not dissipate in the environment. It is a bio-accumulative toxin that builds up in the human body, adversely impacting health.
Fluorescent lamps contain small amounts of mercury. In 1976, the Federal Resource Conservation and Recovery Act regulated that mercury must be managed as a hazardous waste. This classification is dependent on amount of mercury collected and the timetable for its disposal.
If the weight of the waste lamps is less than 220 pounds, or approximately 300 four-foot T-12 lamps, then the lamps can be considered "Conditionally Exempt Hazardous Waste."
If this exemption is not applicable, the waste can then be managed as "Universal Waste." This classification streamlines the disposal process, saving time and money, while ensuring that the mercury is handled properly.

Disposal of lamps containing mercury is an eligible cost for the Oregon Business Energy Tax Credit as well as SB1149 public purpose funds for schools.

PCB Links
DEQ: Waste Lamps and Ballasts
DEQ: Businesses Collecting Universal Waste in Oregon
EPA: PCB home page
EPA: Overview of PCBs
EPA: PCBs in Fluorescent Light Fixtures
EPA: Handling Light Fixture Ballasts Safely
Recycling fluorescent lamps
Thermostat recycling
Finding Qualified Contractors
EPA: Form 7710-53 Notification of PCB Activity (pdf)
Form 7710-53 Instructions (pdf)
State of Oregon: Example of Contract for PCB Removal (Word)
School-Specific PCB Links
EPA: Fine for School PCB Violation
EPA: PCB Lighting Ballasts in Schools
EPA: A Guide for School Administrators on Removing PCBs from Light Fixtures (pdf)
EPA: A Guide for School Maintenance Personnel on Removing PCBs from Light Fixtures (pdf)
Mercury Links
DEQ: Waste Lamps and Ballasts
DEQ: Businesses Collecting Universal Waste in Oregon