Are Your Polychlorinated Biphenyls (PCBs) Properly Marked? Fines Can Be Large!…

PCB labeling Requirements

If items were not originally labeled by their manufacturer, the owner must label items that may contain PCBs. Standard PCB labels are square and come in 1-in. increments from 2 in. x 2 in. to 6 in. x 6 in. If the standard PCB label is too large to fit on a piece of equipment, a 1-in. x 2-in. PCB label may be substituted. When analytical results identify an item’s PCB concentration, the concentration should be written in permanent ink on the label. When the equipment is determined to have a concentration of less than 5-ppm PCBs, a “Non-PCB” label should be affixed to the equipment. Labeling is also required for materials that do not contain PCBs. Large, low-voltage capacitors; small capacitors that are normally used in alternating circuits; and fluorscent light ballasts that do not contain any concentration of PCBs should be marked “No PCBs” by the manufacturer if manufactured after July 1, 1978. Once a PCB Item is removed from service, the PCB Article or Container should also be labeled with the date when it was removed from service. In addition, other regulatory labeling requirements apply depending upon the contents of the container.

CAUTION: Aged labels on electrical equipment may not accurately represent the PCB concentration of the equipment’s contents. For example, sealed transformers labeled as containing non-PCB oil may become contaminated with PCBs during servicing so a thorough transformer oil analysis is recommended.

Other labeling errors include…

• Improper sampling and/or analysis at the time of original labeling
• Equipment alterations that may have caused a change in PCB concentration since the labeling
• Confusion over the difference between the federal and the state definitions of the non-PCB classification.

Each of the following items must be marked with PCB Labels…

• PCB transformers at the time of manufacture, at the time of distribution in commerce if not already marked, and at the time of removal from use if not already marked. (Marking of PCB-contaminated electrical equipment is not required).
• PCB large high-voltage capacitors at the time of manufacture, at the time of distribution in commerce if not already marked, and at the time of removal from use if not already marked.
• Equipment containing a PCB transformer or a PCB large high-voltage capacitor at the time of manufacture, at the time of distribution in commerce if not already marked, and at the time of removal of the equipment from use if not already marked.
• PCB large low-voltage capacitors at the time of removal from use.
• Electric motors using PCB coolants.
• Hydraulic systems using PCB hydraulic fluid, according to experts such as a Hydraulic Cylinder Repair service.
• Heat transfer systems (other than PCB transformers) using PCBs.
• PCB article containers containing articles or equipment that must be marked.
• Each storage area used to store PCBs and PCB items for disposal.
• Each transport vehicle loaded with PCB containers that contain more than 45 kilograms (kg) (99.4 pounds (lb)) of liquid PCBs at concentrations of equal to or greater than 50 ppm or with one or more PCB transformers must be marked on each end and each side with the large PCB mark.
• All PCB transformers not otherwise marked under this section. (Marking of PCB-contaminated electrical equipment is not required).
• All PCB large high-voltage capacitors not marked under this section will be marked individually with the large PCB mark, or if one or more PCB large high-voltage capacitors are installed in a protected location such as on a power pole, structure, or behind a fence, the pole, structure, or fence must be marked with the large PCB mark, and a record or procedure identifying the PCB capacitors must be maintained by the owner or operator at the protected location.
• PCB equipment containing a PCB small capacitor must be marked at the time of manufacture with the statement, “This equipment contains PCB capacitor(s).” The mark must be the same size as the large PCB mark.
• Any chemical substance or mixture that is manufactured that contains less than 500 ppm PCB (0.05 percent on a dry weight basis), including a PCB that is a by-product or impurity, must be marked in accordance with any requirements contained in the exemption granted by EPA to permit such manufacture.
• The vault door, machinery room door, fence, hallway, or means of access, other than grates and manhole covers, to a PCB transformer must be marked with the large PCB mark; an alternative mark may be used under certain circumstances (where the primary fire department knows, accepts, and recognizes what the alternative mark means, and the EPA regional office approves the alternative mark).
• All PCB large low-voltage capacitors must be marked individually with the large PCB label, or if one or more PCB large, low-voltage capacitors are installed in a protected location such as on a power pole, structure, or behind a fence, the owner or operator must mark the pole, structure, or fence with the large PCB mark and maintain a record or procedure identifying the PCB capacitors at the protected location. PCB large low-voltage capacitors in inaccessible locations inside equipment need not be marked individually, provided the owner or operator properly marks the equipment.

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