Document KR7owQKyM6q4ZYo90dn8eGq02

rEPA United States Environmental Protection Agency December 1979 Toxic Substances Polychlorinated Biphenyls: An Alert for Food and Feed Facilities HONS 000206 This booklet has been published by the Environmental Protection Agency in cooperation with the Department of Agriculture and the Pood and Drug Administration. Polychlorinated Biphenyls: An Alert for Food and Feed Facilities HONS 000207 Important Notice: PCB Incineratora At the time this booklet went to press, there were still no approved PCB incinerators available for commercial use in the United States. Until incinerators are available, it is not advisable to remove PCB fluids or infact PCB ` containing equipment unless safe storage facilities are available off the site. Several food contamination incidents have been caused by PCBs in storage. These incidents indicate that removing PCB equipment or draining fluid from a PCB transformer and storing the equipment or fluid may result in an increased risk of contamination. Therefore, instead of removing this equipment from service at this time, carefully examine the risk of leaks or spillage and monitor continued operations closely. (See suggestions in paragraph C of checklist.) If there is potential for leaks or spills, corrective measures must be taken, including removal of the equipment and fluid to a safe storage area away from the premises. If you have any questions, consult with your regional EPA or FDA office or local USDA inspector. At the present time, we anticipate that the first inciner ator will be available in spring 1980. EPA will publicize information on commercial PCB incinerators as soon as they are approved. In addition, you may check on the availability of incinerators by either calling EPA's Office of Industry Assistance toll-free (600) 424-9065 or calling your regional EPA or FDA contact or local USDA inspector. (See list of names and numbers in the booklet.) December 1979 HONS 000208 FOREWORD UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON OC December 1979 The food end feed industries are particularly vulnerable to contamination from polychlorinated biphenyls (PCB). PCBs are ubiquitous, persistent industrial chemicals that are known to cause serious health and environmental effects. The Environmental Protection Agency has responsibility for regulatory control of PCBs and other toxic substances under the Toxic Substances Control Act of 1976. We are working cooperatively with the Pood and Drug Administration, which regulates chemical substances in food and their use in food and animal feed plants, and the Department of Agriculture, which has responsibility for assuring the safety of meat and poultry, to protect our food supply from PCB contamination*. -- ------------- .. . This booklet has been prepared tot Alert you to the serious potential problems associated with the use of PCB-containinq equipment in the food and feed industry. Provide information that will help you establish a program for contamination prevention in these facilities, and Provide information on current PCB government regulations and a reference of sources of additional information. PCB contamination has already caused costly destruction of large quantities of food and uncountable damage to our environment. We urge you to alert your managers and employees to the problem of PCB contamination and to institute a program for preventative aotion without delay. This brochure will assist you in your efforts. HONS 000209 Why the concern? 2 In recent years, there have been a number of incidents where food has been contaminated with polychlorinated biphenyls (PCBs) and other toxic chemicals. This contamination has resulted from accidental spills, improper disposal, and unintentional misuse of PCB-containing materials and equipment. PCBs are now known to have extremely hazardous health and environmental eflects, even at iow levels of concentra tion in the food chain. PCB-containing equipment, such as electrical transformers, has been extensively used in food and feed processing facilities. We are especially concerned that future accidental contamination be prevented. This booklet has been prepared to help you identify potential problems and prevent costly future incidents that could have adverse effects on health and the environment. HONS 000210 What are PCBs -- why, how. and where are they used? PCBs are a class of chemicals called chlorinated hydro carbons. PCBs range in consistency from heavy oily liquids to waxy solids. Their most important properties are chemical stability, low flammability, high boiling points, and tow electrical conductivity. Since their development in 1929, PCBs have been used in a variety of industrial applications. Hundreds of millions of pounds of PCBs have been used as fluids in electrical transformers, capacitors, and electromagnets, and heat transfer and hydraulic systems. Why are PCBs hazardous? 3 PCBs have also been used as plasticizers in points, adhesives, and caulking compounds; fillers for invest ment casting waxes; and dye carriers in carbonless copy paper. Concern over PCBs' toxicity and persistence in the environment led Congress to prohibit their manufacture, processing, or distribution in commerce. Although PCBs have not been manufactured in the United States since 1977, the chemical has been permitted to remain in older electrical transformers and other industrial machinery. Knowledge of PCB toxicity in humans is based pri marily on an incident which occurred in Yusho, Japan in 1968 when PCBs leaked from a heat exchanger and contaminated rice oil. Among the many symptoms observed were chloracne (skin rash}, discoloration of the gums and nailbeds, swelling of joints, waxy secre tions of glands in the eye lids, as well as more general effects such as lethargy and joint pain. There are also well documented tests on laboratory animals that show PCBs cause reproductive failures, gastric disorders, skin lesions, tumors, and other effects of concern. HONS 000211 4 Why should food and food related industries be especially concerned about PCBs? The Yueho incident illustrates the serious human health and economic consequences of PCB contamination in food or feed related industries. Several other incidents underline the need for special attention toprevent ... similar costly contamination in the future. These include: Discovery of PCBs in fishmeal used as a feed ingredient in North Carolina as a result of a leaking heat exchanger, Contamination of fishmeal in Puerto Rico resulting from a fire involving stored electrical transformers in the same warehouse, Death and severe illness of feedlot cattle in Kansas caused by inadvertent use of PCB-contaminated oil as a carrier for insecticide, Contamination of animal feed ingredients with PCBs leaking from a transformer in storage at a packing company in Billings, Montana. These incidents have resulted in the destruction of large quantities of food, feed, and farm animals, and major disruption of the companies involved. HONS 000212 PCBs in the environment 5 Unlike most organic chemicals which break down fairly rapidly in the environment, PCBs are extremely stable. The potential for biomagnification in the food chain is of special concern. Biomagnification is the process through which small amounts of toxic substances reach higher levels of concentration at each stage of the food chain. Microorganisms and plants take in traces of PCBs from the environment. These microorganisms and plants provide the food for small fish and other animals which are in turn eaten by higher forms of animal life. At each step of the sequence, the PCB content increases until human food supplies may be contaminated above the levels considered to be safe for consumption. MONS 000213 6 Where might PCBs be found in food industry facilities? The following types of equipment may contain PCB fluids or other liquids such as mineral oil that are contaminated with PCBs: Transformers Large capacitors (over 3 (bs. of fluid) Electromagnets Heat transfer and hydraulic systems Small capacitors Equipment containing small capacitors including: electrical switch gear, fractional HP motors, and ballasted lighting fixtures. Transformers, large capacitors, electromagnets, and heat transfer and hydraulic systems are of primary importance because they contain free flowing Hquid. Small capacitors are of less concern because the PCBs are usually in a nonliquid, nonmobUe state. CAPACITORS Capacitors have been manufactured in a wide range of sins for various industrial uses. Capaci tors may contain PCB dielectric fluids. MONS 0002X4 7 T I HEAT TRANSFER SYSTEM Heat transfer systems containing PCBs have bean used in food processing equipment. Existing federal regulations concerning PCBs and food Concern about highly toxic PCBs contaminating human food has led to a number of regulatory actions by the Food and Drug Administration (FDA), the U.S. Depart ment of Agriculture (USDA), and the Environmental Protection Agency IEPA). Under FDA regulations foods and feeds are considered to be contaminated and may not be sold in interstate commerce if they contain PCBs in excess of certain prescribed concentrations. (See Table 1.) The use of PCBs in food and animal feed processing facilities, except enclosed use in transformers and capacitors, is prohibited by FDA regulation (21 CFR 110.40, 500.45). EPA has issued rules governing the use of PCBs. In general, PCB mixtures with concentrations less than 50 parts per million (ppm) or 0.005 percent are not regu lated. The use of intact, non-leaking transformers, electromagnets^xapacitors, and capacitor-containing equipment with PCB concentrations greater than 50 ppm is allowed. M0NS 000215 8 The EPA rule permits the continued use of PCBs in servicing of electromagnets and transformers and in heat transfer and hydraulic systems until July 1, 1984. As of November 1,1979, PCBs may no longer be used in heat transfer systems in plants manufacturing or processing food, drugs, and cosmetics. EPA rules include provisions for marking, disposal, storage, and recordkeeping, portions of which are discussed later in this booklet, The potential for further regulatory action exists. EPA, FDA, and USDA are considering prohibiting the use of PCBs In all transformers, capacitors, and other electrical equipment in food and feed related industries. The following Checklist for Action has been prepared to assist you in conducting a full safety check of your facility. We urge you to use this checklist to implement a program for safety and contamination prevention in all your food and feed related facilities. HONS 000216 9 Checklist for Action What can 1 do? A. Determine if you have PCB equipment. % V n 1. Locate any potential PCB source. You should inventory your plant for transformers, capacitors, heat transfer systems, hydraulic systems, and fluid stored for use in this equipment. After you have located these items,... 2. Examine the equipment for caution labels. A caution label specifically identifying the equipment as containing PCBs may be present. If so, skip to Section B of this checklist. If not,... 3. Transformers and large capacitors may bear namepfatee. if your transformer or capacitor has a manufacturer's nameplate with a trade name, refer to Table 2 at the end of this booklet. If the trade name does not appear there, the equipment may stilt contain PCBs. Contact the manufacturer, referencing the serial number to determine if the equipment contains PCBs. If there is no nameplate, or if this approach is unsuccessful... 4. Seek aeeistance from a servicing expert. Call on your local transformer servicing company or the engineering service department of your utility company. They can assist you to obtain a sample of your trans former fluid for analysis. You may also want to sample your heat transfer systems, hydraulic systems, or other suspect oil. (Do not attempt to sample fluids in capaci tors.! Then... 6. Have the samples analyzed. ) This is the only way to be certain whether or not your 1 equipment contains PCBs. If you determine that you have PCB equipment,... B. Consider replacing PCBcontaining equipment with non-PCB ' equipment. EPA, FDA, and USDA are considering prohibiting the use of PCBs in all electrical equipment in food and feed related industries. Although the prohibition on PCB-containing equipment is not yet in effect, we urge voluntary removal of this equipment and replacement with non-PCB equipment to prevent the possibility of future food contamination. HONS 000217 C. Take special precautions for continued use. 10 As an alternative in transformers, you may want to consider replacing the PCB fluid with non-PCB fluid. You should be aware that the transformers will contain residual PCB concentrations after replacement and, therefore, may be subject to future federal regulation. EPA disposal regulations require incineration of all PCB liquids with concentrations of 500 ppm (0.05%) or greater. The first approved incinerators will be available sometime in 1980. Until incinerators are available, PCBs removed from service must be stored for later disposal. If it is not possible for you to replace your PCB-containing equipment, you will want to ... The risk of PCB contamination can be minimized by analyzing the risk of spillage associated with each individual PCB unit and by taking steps to contain the potential uncontrolled loss of PCBs from the unit. You should consider the following questions: 1. Is there any evidence of an active leak from the PCB unit? If so, take whatever steps are necessary to protect your product or usable byproduct. Of course, leaking equipment should be repaired immediately. If your product is being contaminated, contact the appro priate agency to determine the best way to destroy it. 2. Is the PCB unit located in an area where there is a way that leaking fluid from the unit could find its way into your process? If so, these units should be given priority in the development of spill prevention meas ures. Special consideration should be given to potential leaks resulting from accidents as discussed in the following. 3. Is any liquid ever pumped from the vicinity of the PCB unit to the process area? If so, can the PCB unit be isolated from the pump? 4. If the PCB unit is pad mounted, are there curbs or pans to serve as a barricade against loss of fluid? 5. If the PCB unit is located in an area surrounded by porous cinderblock walls, have they been sealed with material which will not dissolve in solvents such as PCB and trichlorobenzene? Is the wall/floor interface tight? HONS 000218 11 6. Is the floor in the vicinity of a PCB unit free from cracks? Cracks that look like they would not prevent the loss of fluid should be grouted and painted with solvent resistant materials, or government approved materials if required. 7. Is the PCS unit in a location where vehicular traffic might be a hazard? If so, a vehicle barrier might be usetul. 8. Is the PCB unit located near machinery which might throw projectiles with sufficient energy to damage the unit? If so, a shield, such as a fence, may provide the necessary protection. 9. Is the PCB unit mounted on a surface which might be difficult to seal, such as unwelded steel plates or in a mobile machine? If so, a catchbasin might be installed under the unit. 10. Are 'there floor drains in the vicinity of a PCB unit? If so, can they be sealed or otherwise isolated from the unit? 11. If you have PCB equipment or drums of PCB fluid in storage for future use, can they be removed from the process area? Are they marked or labeled to warn of PCB presence? If you have PCB equipment, you may be subject to mandatory labeling and storage requirements. 0. Be familiar with mandatory labaling and storage requirements. 1. Labeling requirements. The EPA label for PCBs looks like this. HONS 000219 E. Obtain further information. 12 You must label the following items: transformers containing liquids with more than 500 ppm of PCBs, PCB capacitors with 3 (three! or more pounds of fluid operating at 2,000 volts or more, containers such as bags, barrels, or drums used to hold PCBs, electric motors using coolant with 50 ppm or more of PCBs, hydraulic systems or heat transfer systems containing 50 ppm or more of PCBs, and the storage areas described in the following. In addition, labels must be placed on the following items when they are removed from service: PCB capacitors containing more than 3 pounds of fluid operating at less than 2,000 volts and equipment containing a PCB transformer or large high voltage capacitor. 2. Storage requirements. PCBs and PCB items which you remove from service for disposal must be stored in a location meeting EPA criteria to insure that they are properly contained. This location should not be near your process area. It should be isolated so that it is not vulnerable to damage and puncture from vehicular, forklift, and other moving equipment. For assistance with the storage design criteria, contact the EPA regional office for your state. A list of EPA regional offices appears at the back of this booklet. (See Appendix B.j If you do not yet have the EPA regulations on PCBs, you can obtain a free copy from EPA by calling toll free (8001424*9065 (In Washington, DC, 554-1404) and asking for a reprint of the PCB Ban Regulation, Federal Register, May 31, 1979, and for a list of the approved PCB Disposal Facilities. If you want more background information on the regulation, ask for a free copy of the EPA Support Document to the PCB Ban Regulation at the same phone number. The mailing address is: Industry Assist ance Office (TS-799), Office of Toxic-Substances, U.Sr Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. You may also contact the nearest EPA Regional Office. (See Appendix B.) Other useful background information on PCBs is listed in Appendix A. HONS 000220 Table 1. 13 FDA Limits on PCB Concentration in Food Food Concentration (parts per million) Milk and manufactured dairy products 1.5 ppm (fat basis) Poultry Red meat Eggs Fish and shellfish 3 ppm (fat basis) 3 ppm (action level) (fat basis) 0.3 ppm 5 ppm (edible portion)* Feed for food producing animals 0.2 ppm (except concentrates, supplements, and premixes) Infant and junior foods 0.2 ppm Animal feed components 2.0 ppm of animal origin Paper food packaging in 10 ppm direct contact with food (action level) Source: Title 21, Code of Federal Regulations, Section 109.30; Federal Register, Vol. 44, No. 127, June 29, 1979, pp. 38330-38340. A regulation establishing a new level of 2 ppm was promuf gated but was stayed on October 5, 1979 untH further notice. MONS 000221 14 Table 2. PC6 Manufacturers and Trade Names PCBs have been marketed and used by manufacturers in their products under various trade names. This list is not necessarily complete since many companies have gone out of business and information is no longer available. Manufacturer Country Trade Name Aerovox Allis-Chaimers American Corp. Axel Electronics Bayer Caffaro ' Caffaro Caffaro Capacitor Specialists Chemko Cornell Dubilier Dings Co. Electrical Utilities Corp. Electro Engineering Works Electromagnetic Fitter Co. Envirotech Buell Eriez Magnets ESCO Mfg. Co. Ferranti-Packard Ltd. General Electric Geneva Industries H. K. Porter Helena Corp. Hevi-Duty Electric ITE Circuit Breaker Jard Corp. Kanegafuchi Kuhlman Electric McGraw Edison Maloney Electric Monsanto Monsanto Monsanto US US US -- Germany Italy Italy Italy US Czechoslovakia US US US US US US US US US US US US US -- US US Japan US US US UK and US UK and Japan UK and Europe Hyvol Chlorextol Asbestol Clophen Dk Fenclor Incior Dykanol --. Eucarel - - Pyranol Askarel* Askarel* Pyranol Askarel* Non-Flammable Liquid Ciorphen Kennechlor Saf-T-Kuhl Elemex Aroclor Santotherm FR Pyroclor HONS 000222 15 Manufacturer Monsanto Monsanto Monsanto Niagara Transformer Corp. P. R. Mallory & Co. Power Zone Transformer Prodelec Prodelec R. C. Uptegraff R. F. Interonics Reliance Electric Co. Research-Cottrell Sangamo Electric Sovol Sprague Electric Co. Standard Transformer Corp. Stens Magnetics Tobe Deutschmann Labs. Universal Mfg. Corp. Van Tran Electric Wagner Electric Westinghouse Electric York Electronics - - _ Country US us US US US US France France US US us US US USSR us US US US US US US US US US -- -- Trade Name Therminol* * Pydraul*** Santovac 1 and 2 Askarel*, EEC-18 Aroclor 8 EEC-18 Phenoclor Phyralene Askarel* Diaclor Chlorinol Askarel* No-Flamol Inerteen Nepolin Apirolio Kaneclor `Askarel is the generic name used for nonflammable insulating Squid in transformers and capacitors ' Various products used os heat transfer fluids, such as Therminol FR-O. were manufac tured under this name. * Various products used as hydraulic fluid, such as Pydraul A-200, were manufactured under this name. HONS 000223 Appendix A 16 Other Available Information on PCBs This booklet does not go into detail about the health and environmental effects of PCBs or the chemicals now being used as substitutes for PCBs. The following reports cover these technical areas. The NIOSH Criteria Document Is particularly recommended for its discus sion of health issues for servicing PCB equipment or cleaning up PCB spills. "Criteria for a Recommended Standard ... Occupa tional Exposure to Polychlorinated Biphenyls (PCBs)." DHEW (NIOSH) Publication No. 77-225, September 1977. Order from Superintendent ol Documents, U.S. Government Printing Office, Washington, D.C. 20402. Price $4.00 plus postage. "Assessment of the Use of Selected Replacement Fluids for PCBs in Electrical Equipment." Report No. EPA 560/6-77-008, March 1979. Order from National Technical Information Service, Springfield, Virginia 22161. Report No. NTIS-PB-296 377. "Polychlorinated Biphenyls and the Environment." 1972. Order from National Technical Information Service, Springfield, Virginia 22161. Report No. NTIS COM-72-10419, This is a thorough discussion of the properties and uses of PCBs. "PCBs in the United States: Industrial Use and Envi ronment Distribution." 1976. Order from National Technical Information Service, Springfield, Virginia 22161. Report No. NTIS PC 252-012. HONS 000224 17 Appendix B Where Can I Seek Assistance? Assistance from EPA or FDA may be obtained by contacting your nearest regional office. Plants regulated by the Food Quality Service of USDA may obtain help from their local inspector. The following table lists by the state the ten Federal regional offices for FDA and EPA. REGION 1: Connecticut Maine, Massachusetts, New Hampshire. Rhode Island. Vermont ------ - ................. EPA FDA Mr. Robert Dangel Mr. A. J. Beebe Toxic Substances Coordinator Regional Director John F. Kennedy Federal Building 585 Commercial Street Boston, MA 02203 Boston, MA 02109 (617) 223-0586 (617) 223-1278 REGION II: New Jersey, New York, Virgin Islands. Puerto Rico EPA Mr. Ralph Larsen PCB Coordinator 26 Federal Plaza New York, NY 10007 (2121 264-1925 FDA Mr. Caesar A. Roy Regional Director 830 3rd Avenue Brooklyn, NY 11232 (212) 965-5416 REGION III: Delaware, Maryland, Pennsylvania. Virginia, West Virginia, District of Columbia EPA Mr. Charles Sapp Toxic Substances Coordinator Curtis Building (3AH20) 6th & Walnut Street Philadelphia, PA 19106 (215) 597-4058 FDA Mr. R. J. Davis Regional Director 2nd and Chestnut Street Room 900 Philadelphia. PA 19106 (215) 597-4390 REGION IV: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee EPA Mr. Ralph Jennings Toxic Substances Coordinator 345 Courtlsnd Street, NE Atlanta, GA 30308 (404) 681-3864 FDA Mr. M. D. Kinslow Regional Director 880 W. Peachtree Street Atlanta, GA 30309 (404) 881-4266 REGION V: Indiana, Illinois, Michigan, Minnesota, Ohio, Wisconsin EPA Mr. Karl Bremer Toxic Substances Coordinator 230 South Dearborn Street, Room 1165 Chicago, IL 60604 (3121353-2291 FDA Mr. L. R. Claiborne Regional Director 175 W. Jackson Boulevard Room A-1945 Chicago, IL 60604 (312) 353-1047 MQNS 000225 18 REGION Vf: Arkansas, Louisiana, New Mexico, Oklahoma, Texas EPA Mr. John West PCS Coordinator FDA Mr. P. B. White Regional Director First International Building 1201 Elm Street Pallas, TX 75270 1214) 767-2734 3032 Bryan Street Dallas, TX 75204 1214) 749-2735 REGION VII: Iowa, Kansas, Missouri, Nebraska EPA Mr. Wolfgang Brandner Toxic Substances Coordinator 324 East 11 Street Kansas City, MO 64106 1816) 374-6538 FDA Mr. Clifford G. Shane 109 Cherry Street Kansas City, MO 64106 (816) 374 5646 REGION VIII: Colorado. Montana, North Dakota, South Dakota, Utah, Wyoming EPA Mr. Dean Gillam Toxic Substances Coordinator 1860 Lincoln Street Denver, CO 80295 (303) 837-3926 FDA Mr. F. L. lofsvold Regional Director 721 19th Street US Customhouse Room 500 Denver, CO 80202 (3031 8374915 REGION IX: Arizona, California, Hawaii, Nevada, American Samoa, Guam. Trust Territories of the Pacific. Wake Island EPA Mr. Gerald Gavin PCB Coordinator 215 Fremont Street San Francisco, CA 94105 (415)5664606 FDA Mr. I. B. Berch Regional Director UN Plaza Federal Office- Bldg. Room 526 San Francisco, CA 94102 1415) 556-2062 REGION X: Alaska, Idaho, Oregon, Washington EPA Dr. Jim Everts Toxic Substances Coordinator . 1200 6th Avenue Seattle, WA 98101 (206) 442*5580 FDA Mr. J. W. Swanson Regional Director 909 1st Avenue Room 5003 Seattle, WA 98174 HONS 000226 SEPA For additional information you may caH the Industry Assistance Office toll free at (800) 424-9065 (in Wash ington, DC 554-14041, or write to Director, Industry Assistance Office (TS-799), Office of Toxic Substances, U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, OC 20460. HONS 000227 HONS 0 0 0 2 2 8 United States Environmental Protection Agency Washington 0 C 20460 TS-799 Official Business Penalty for Private Use S300 i*