Hazardous Waste Program fact sheet
Division of Environmental Quality Director: Leanne Tippett Mosby

The primary concern regarding the disposal of used fluorescent lamp ballasts is the health risk associated with polychlorinated biphenyls (PCBs). Human exposure to these possible carcinogens can cause skin, liver and reproductive disorders. Fluorescent and high-intensity discharge lamp ballasts contain a small capacitor that may hold high concentrations of PCBs (greater than 90 percent pure PCBs or 900,000 parts per million). The chemical compounds were widely used as insulators in electrical equipment such as capacitors, transformers, switches and voltage regulators through the late 1970s. The Toxic Substances Control Act was enacted in 1976 and subsequently banned the production of PCBs in the United States. The proper method for disposing of used ballasts depends on several factors, such as the type and condition of the ballasts and the regulations and recommendations in effect. Toxic Substances Control Act specifies the disposal method for ballasts that are leaking PCBs. In addition, generators of PCB-containing ballast wastes may be subject to notification and liability provisions under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) – also known as “Superfund”. (Note: PCBs are not regulated as hazardous waste; however, there may be other components in the ballast that would cause it to test out as a hazardous waste. Hazardous waste is not covered in this technical bulletin. Additional regulations will need to be met if the ballast contains hazardous waste.)

Small Capacitors in Fluorescent Light Ballasts and Cause for Failure
Light ballasts are the primary electric components of fluorescent light fixtures and are generally located within the fixture under a metal cover plate. The ballast units are generally composed of a transformer to reduce the incoming voltage, a small capacitor (that may contain PCBs) and possibly a thermal cut-off switch or safety fuse. These components are surrounded by a tarlike substance that is designed to muffle the noise that is inherent in the operation of the ballast. When a ballast unit fails, excessive heat can be generated which will melt or burn the tar material, creating a characteristic foul odor.

In considering causes of ballast failure, some privately conducted tests have indicated that operation of power saving lamps with standard ballast or standard lamps with power-saving ballast tends to significantly increase the ballast operating temperature and decrease its normal life span. It appears that ballasts will fail less frequently if standard lamps are used only with standard ballasts and power-saving lamps with power-saving ballasts. Fluorescent lamps should be changed in pairs: new lamps should not be used with old lamps.

When upgrading lighting, make sure your contractor removes all disconnected PCB-containing ballasts from the light fixtures. Non-leaking PCB-containing ballasts may still pose a hazard if left in upgraded fixtures, especially in the case of fire.

Identifying PCB Ballasts
Use the following guidelines to identify ballasts that contain PCBs:

It is extremely important to find out if a ballast containing PCBs is leaking before you remove it from the fixture, so that you can handle it properly.

Recommendations for Handling Leaking PCB Ballasts
The Environmental Protection Agency recommends the following for anyone with a fluorescent light ballast leaking PCBs:

Disposal of Leaking and Non-Leaking PCB Ballasts (and contaminated materials)
A puncture or other damage to a ballast in a lighting system exposes an oily tar-like substance. If this substance contains PCBs, the ballast and all materials it contacts are considered PCB waste and are subject to Toxic Substances Control Act requirements. Use trained personnel or contractors to handle and dispose of leaking PCB-containing ballasts.

Arrangements must be made with a facility for the pick-up, manifesting and shipment of ballasts, PCB-soiled items or fluorescent fixtures containing PCBs, to an approved chemical waste processing site. These firms will also perform minor PCB spill cleanups and arrange for the removal of PCB capacitors. (See the Commercial Hazardous Waste and PCB Facilities Located in Missouri, List, PUB968.) Leaking PCB-containing ballasts must be incinerated in an approved high-temperature incinerator.

Non-leaking small PCB capacitors (lighting ballasts) are not required to be incinerated. There are several options for disposal of non-leaking ballasts.

Packing PCB Ballasts for Disposal
Despite the disposal method selected, ballasts are packed, according to PCB regulations, in 55-gallon drums for transportation.

Transporters of leaking PCB ballasts and PCB contaminated waste need to be licensed hazardous waste transporters. All PCB-containing ballasts must be shipped using a hazardous waste manifest and transported by a hazardous waste transporter registered by the EPA to transport PCBs.

Record Keeping
To track transported Toxic Substances Control Act or hazardous waste (leaking PCB ballasts and PCB-contaminated waste), generators must prepare a hazardous waste manifest. The manifest identifies the type and quantity of waste, the generator, the transporter and its ultimate destination. Please contact the Missouri Department of Natural Resources’ Hazardous Waste Program for blank copies of manifests.

The manifest must accompany the waste wherever it travels. Each handler of the waste must sign the manifest and keep one copy. When the waste reaches its destination, the owner of that facility returns a copy of the manifest to the generator to confirm that the waste arrived. If the waste does not arrive as scheduled, generators must immediately notify the Missouri Department of Natural Resources’ Hazardous Waste Program, so that they can investigate and act appropriately. Copies of the completed manifests should be kept for at least three years.

How may I obtain copies of hazardous waste laws and regulations?
Copies of the Revised Statutes of Missouri are available through the Reviser of Statutes at 573-526-1288 and are available online at www.moga.state.mo.us. Copies of the Missouri Code of State Regulations are available through the Missouri Secretary of State at 573-751-4015 and are available online at http://www.sos.mo.gov/adrules/csr/current/10csr/10csr. Federal regulations may be viewed at federal depository libraries or may be purchased from a U.S. Government Bookstore, the U.S. Government Printing Office, or from a commercial information service such as the Bureau of National Affairs. Federal Regulations are also available online at http://www.ecfr.gov/cgi-bin/ECFR?page=browse.