OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

March 11, 1993

The Office of Senator Phil Gramm
Attn: Ms. Trish Flynn
2323 Bryan, Suite 1500
Dallas, TX 75201

Dear Ms. Flynn:

This is in response to your correspondence of December 3, 1992 on behalf of your constituent, Dan Bigler, regarding exposures to polychlorinated biphenyls (PCB's) in lighting equipment.

Mr. Bigler stated that he is "hopeful that the U.S. Department of Labor will respond shortly to provide some definitive guidance regarding policy application concerning exposures to PCB in lighting equipment." As our previous correspondence covered in detail, the Occupational Safety and Health Administration (OSHA) does have standards for exposure to PCB's in its Air Contaminant Standard (29 CFR 1910.1000). These standards apply to employees that may be exposed to PCB's, particularly in the repair, remodeling, and disposal of PCB-containing lighting equipment.

Mr. Bigler's concerns about pollution prevention may be addressed directly to the Environmental Protection Agency. Concerns about the health impact on school-aged children and the general public may be directed to that agency and Department of Health and Human Services.

The Directorate of Compliance Programs remains available if Mr. Bigler has specific questions about OSHA's enforcement of the Air Contaminant Standard. Thank you for your interest in employee safety and health.


Roger A. Clark, Director
Directorate of Compliance Programs