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OSHA Hazard Information Bulletins
Light Ballasts and Chlorodiphenyl (PCB)


December 18, 1992

MEMORANDUM FOR:

REGIONAL ADMINISTRATORS

THROUGH:

  • LEO CAREY
  • Director
  • Office of Field Programs

FROM:

  • PATRICIA K. CLARK
  • Director
  • Directorate of Technical Support

SUBJECT:

  • Hazard Information Bulletin - Light Ballasts and Chlorodiphenyl (PCB)

The Directorate of Technical Support issues Hazard Information Bulletins (HIBs) in accordance with OSHA Instruction CPL 2.65 to provide relevant information regarding unrecognized or misunderstood health hazards, inadequacies of materials, devices, techniques, and safety engineering controls. HIBs are initiated based on information provided by the field staff, studies, reports and concerns expressed by safety and health professionals, employers, and the public. Information is compiled based on a thorough evaluation of available facts, literature and in coordination with appropriate parties.

We have received a letter from the Environmental Energy Group that indicates leaking chlorodiphenyls (PCBs) from fluorescent light ballasts may be of some concern. Their information shows that electricians and maintenance technicians are not being provided proper protective equipment when handling and removing old light ballasts that can result in contact with PCB- contaminated surfaces.

Chlorodiphenyls are oily, viscous liquids (at 20°C) that vary in color from dark brown to pale yellow. Airborne exposures from leaking ballasts are of less concern than skin contact because the vapor pressures at 20°C are between 0.000006 and 0.004 milligrams per cubic meter (mg/m3).

Both of the PELs for chlorodiphenyls have skin designations; therefore, protection must be provided to prevent potential absorption in the body as a result of skin contact. The most prominent effects from occupational exposure to PCBs have been skin and mucous membrane effects. These include swollen eyelids, excessive eye discharge and burning eyes; burning and edema of the face and hands; acute contact dermatitis, hyperpigmentation of the skin and mucous membranes, chloracne, and discoloration of the fingernails; and thickening of the skin. Chronic absorption through the skin can cause fatty degeneration of the liver.

Environmental Protection Agency regulation 40 CFR 761, promulgated in 1971, authorized the use of most existing electrical components containing PCBs for the remainder of their useful lives. Ballasts are usually replaced only upon failure. Since they remain operational for as long as thirty years, many ballasts filled with PCBs are still in use.

Information from the Environmental Energy Group and other sources suggests that a significant number of these ballasts are likely to leak. Where leaks are likely to exist, 29 CFR 1910.1000(a)(4) requires employers to prevent worker exposure through the use of gloves, other appropriate personal protective equipment, engineering controls or work practices.

Appropriate equipment must provide a protective barrier to prevent the chlorodiphenyl from migrating through it. Glove materials that prevent PCBs from breaking through in 24 hours should provide adequate skin protection. These materials include Neoprene (chloroprene latex), polyvinyl alcohol, FEP Teflon and Viton fluorocarbon rubber.

On the other hand, natural rubber latex and polyethylene materials allow permeation of PCBs in less than one hour. Gloves made of these materials should not be used for handling ballasts without additional precautions.

Employers are required to inform the workers of the potential hazard. OSHA Instruction CPL 2-2.38C regarding the "Hazard Communication Standard," 29 CFR 1910.1200, makes it clear that employers must have information programs for hazardous chemicals that are "present for a long period of time without employee exposure until repair ... activities are performed."

Please distribute this bulletin to all area offices, State Plan States and Consultation Projects. Copies of this bulletin may be sent to appropriate local groups for their information.

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