PCBs on UK higher education providers' estates - do you need to take action?

1st February 2018

The Environment Agency is alerting UK higher education sector to the need to ensure any Polychlorinated Biphenyls (PCB) on their estates are known and dealt with correctly. 
 
The 2000 PCB Regulations place strict requirements and prohibitions on equipment containing them. PCBs may still be found in many types of equipment, but were often used in higher voltage electrical transformers and capacitors produced before 1987.
 
Below is a more detailed introduction to the subject. If you believe you have PCB equipment you should seek professional or legal advice. Links to more information are available at the end of the message.
 
If you have any queries, email pcb-enquiries@environment-agency.gov.uk or phone the Environment Agency on 03708 506 506 and ask ‘to discuss the PCB regulations’.
 
Awareness and identification of Polychlorinated Biphenyl (PCB) Equipment.
 
Polychlorinated Biphenyls (PCB) are a very harmful substance because of their toxicity, persistence and tendency to bio accumulate - once they are in the environment, animals or humans it is very difficult to remove them. PCBs are classed as Persistent Organic Pollutants.
 
Below is a list of types of equipment that could be contaminated with PCBs, please note that this list is not exhaustive:

• electrical transformers
• power factor capacitors
• heat transfer equipment
• pole-mounted transformers
• process heating equipment
• vacuum pumps
• high temperature hydraulic systems
• electrical resistors
• bushings and other high voltage equipment
• fluorescent light ballasts
• hospital diagnostic equipment

 
A PCB substance is any substance that has a total PCB concentration of more than 0.005 per cent by weight (50 parts per million).
PCB means any of the following substances—

• polychlorinated biphenyls,
• polychlorinated terphenyls,
• monomethyl-dibromo-diphenyl methane,
• monomethyl-dichloro-diphenyl methane,
• monomethyl-tetrachlorodiphenyl methane,

The PCB Regulations state that “anything of a type which may contain PCBs shall be treated as containing PCBs unless it is reasonable to assume the contrary”.
 
Contaminated Equipment(CE) is any equipment which contains 5dm3 (5 litres) or more of a PCB substance.
 
If you possess any contaminated equipment, you must register it with the appropriate environmental regulator and renew the registration every year. The Environment Agency is the appropriate regulator for items in England and Wales. If you hold items in Scotland or Northern Ireland, you should register these with The Scottish Environment Protection Agency (SEPA) or The Northern Ireland Environment Agency (NIEA).

Regardless of registration, you must arrange for contaminated equipment to be correctly disposed of or decontaminated as soon as possible, and declare the intended date for this work when you register. Transformers may be kept until the end of their useful life but must be decontaminated to contain 500 parts per million (ppm) or less of PCBs. Transformers also require registration.
 
When you decontaminate or dispose of equipment, the Environment Agency (if in England) will ask you to provide evidence in the form of laboratory analysis and / or hazardous waste consignment notes.
The Regulations also require the correct labelling of all Contaminated Equipment, the premises where such equipment is held and decontaminated transformers.
 
Further information about the legal requirements for PCBs and PCB Contaminated Equipment including registration are available on the following Gov.uk page https://www.gov.uk/guidance/polychlorinated-biphenyls-pcbs-registration-disposal-labelling

And for additional safety information, please see the Health and Safety Executive page https://www.hse.gov.uk/pubns/msa19.htm