OSHA Hazard Information Bulletins
December 18, 1992
| DATE: |
|
| 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 degrees 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 degrees C are
between 0.000006 and 0.004 milligrams per cubic meter (mg/m(3)).
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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