Document O1mBD3wr0pY563bJ7KqrrDELL

t oEPA United States Environmental Protection Agency December 1979 Toxic Substances Polychlorinated Biphenyls: An Alert for Food and Feed Facilities M0N6 OU7640 This booklet has been published by the Environmental Protection Agency in cooperation with the Department ol Agriculture and the Food and Drug Administration. FOREWORD UNIltn STATES ENVIRONMENTAL PROJECTION ACjENCv December 1979 The food and 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 tonic substances under the Tonic 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. Thia booklet has been prepared to: Alert you to the serious potential problems associated with the use of PCB-containing 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 ot additional information. PCB contamination has already caused costly destruction u 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 action without delay. Thia brochure will assist you in your afforts. MGNS 007641 Polychlorinated Biphenyls: An Alert for Food and Feed Facilities HONS 007642 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 effects, even at low 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. 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 low 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 paints, 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 007644 4 Why should food and feed related industries be aapacially concerned about PCBa? The Yusho 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 to prevent similar costly contamination in the future. These include: Discovery of PCSs in fishmeal used as a feed ingredient in North Carolina aa a result of a leaking heat exchanger, Contamination of fishmeal in Puerto Rico resulting from a fire involvrng 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 st a pecking company in Billings, Montana. These incidents have resulted in die destruction of large quantities of food, feed, and farm animals, and major disruption of the companies involved. HONS 007645 PC 8s in ths 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 PC8 content increases until human food supplies may be contaminated above the levels considered to be safe for consumption. MUNS 007646 6 Where might PC8 be found in food industry facilities? The following types of equipment may contain PCS fluids or other liquids such as mineral oil that are contaminated with PC8s: Transformers Large capacitors (over 3 lbs. of fluid) Electromagnets Heat transfer end 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 liquid. Smalt capacitors are of lass concern because the PCBs are usually in a nonliquid, nonmoMe state. CAPACITORS Capacitors have bean manufactured in a wide range of sires for various industrial uses. Capaci tors may contain KB dielectric fluids MONS 007647 7 HEAT TRANSFER SYSTEM Heat transfer systems containing PCBs have been used in food processing equipment Existing federal regulations concerning PCBs end 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 UJSDA), end the Environmental Protection Agency (EPA). 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 0.006 percent are not regu lated. The use of intact, non-leaking transformers, electromagnets, capacitors, and capacitor-containing equipment with PCB concentrations greater than 50 ppm is allowed. HONS 0G764d 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 PC8s in all transformers, capacitors, and other electrical equipment in food end 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. MQNS 007649 9 A. Oatarmina if you hava PC8 aquipmant. B. Consider replacing PCB-contetning equipment with non-PCB equipment. Checklist for Action What can I do? 1. Locata any potantial PC8 sourca. 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 aquipmant 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 nameplates. 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 still 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 assistance 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 trsneformer 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... 5. Have the samples analyzed. This is the only way to be certain whether or not your equipment contains PCBs. If you determine that you have 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 no prevent the possibility of future food contamination. HONS 007650 C. Take special precautions for continued use. / 10 As an alternative in transformers, you may want to consider replacing the PCB fluid with noivPCB 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 (0.005%) or greater. The first approved incinerators will be available sometime in 1980. Until incinerators are available, PC8s removed from service must be stored for later disposal. If it is not possible for you to replace your PCB-contain* inq 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 end by taking steps to contain the potential uncontrolled loss of PCBe 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 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 seeled with material which wiH not dissolve in solvents such as PCB and trichlorobenzene? Is the well/floor interface tight? HONS 007631 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 PCB unit in a location where vehicular traffic might be a hazard? If so, a vehicle barrier might be useful. 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 seated 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 famIMar with mandatory labeling and storage requirements. 1. Labeling requirements. EPA label for PCB look, like thia. HONS 00765^ Obtain further information. 12 You must label the following items: transformers containing liquids with more than 500 ppm of PCBs, PC8 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, end 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 leas 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 ERA 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.) if you do not yet have the EPA regulations on PC8s, you can obtain a free copy from EPA by calling toil free (800) 424-9065 (in Washington, DC, 554-1404) and asking for a reprint of the PC8 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 addreaa is: Industry Assist ance Office (TS-799), Office of Toxic Substances, U S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20460. You may also contact the nearest EPA Regional Office. (Sea Appendix B.) Other useful background information on PCBs is listed in Appendix A. MOWS 007653 Tibia 1. 13 FDA Limit* on PCB Concentration in Food Food Concentration (parts per million! Milk and manufactured dairy products 1.5 ppm (fat Oasis) Poultry 3 ppm (fat basis) Red meat 3 ppm (action level) (fat basis) Egg Fish and shellfish 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) Sourer 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 promul gated but was stayed on October $, 1979 until further notice. HONS 007b5<t Table 2. PCB 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 Atlis-Chalmers American Corp. Axel Electronics Bayar Coffaro Caffsro Caffaro Capacitor Specialists Chemko Cornell Dubilier Dings Co. Electrical Utilitias Corp. Electro Engineering Works Electromagnetic Filter Co. Envirotech Buell Erie* Magnets ESCO Mfg. Co. Ferrantt-Packard Ltd. General Electric Geneva Industries H. K. Portaf Helena Corp. Hevi-Duty Electric ITE Circuit Breaker Jerd Corp. Kanagafuchl Kuhlmen 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 Chtorextoi Asbestoi Clophen Dk Fenclor Incior Dykanol Eucarel Pyranol Askarel* Askarel* Pyranol Askarel* Non-Flammable Clorphen Kennechkw Saf-T-Kuhl Elemex Aroclor Santotherm FR Pyroclor MQNS 007655 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 AskwaT, EEC-18 Aroclor B EEC-18 Phenocior Phyralene Askarel* Diacior Chlorinoi Askarel* No-Flamol Inerteen Nepotin Apirolio Kaneclor 'Ask**/ is the generic nams used for nonflammable insulating liquid in transformars and capacitor*. "Various products usad as haat transfer fluids, such as Tharminoi FR-O, ware manufac tured under'this name. * * Various products usad as hydraulic fluid, such as Pydraul A-200, were manufactured under this name. MONS QQ 7656 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 heifth issues for servicing PCB equipment or cleaning up PCB spills. "Criteria for a Recommended Standard ... Occupa tional Exposure to Polychlorinated Biphenyl* (PCBel." DHEW (NIOSH) Publication No. 77-225, September 1977. Order from Superintendent of 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 66016-77-008, 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. M qns 007657 17 Appendix B Where Can I Seek Assistance? Assistance from EPA or FDA may bo obtained by contacting your nearest regional office. Plants regulated by the Food Quality Service of USOA may obtain help from their local inspector. The following table lists by the state the ten Federal regional offices for FDA and EPA. REGION I: Connecticut Maine. Massachusetts, New Hampshire. Rhode Island, Vermont EPA Mr. Robert Dsngel FDA Mr. A. J. Beebe Toxic Substances Coordinator Regional Director John F, Kennedy Federal Building 585 Commercial Street Boston. MA 02203 (6171 223-0586 Boston, MA 02109 (6171 223-1278 REGION II: New Jersey, New York. Virgin Islands. Puerto Rico EPA FDA Mr. Ralph Larsen PCB Coordinator 26 Federal Plaza New York, NY 10007 (2121 264-1926 Mr. Caesar A. Roy Regional Director 930 3rd Avenue Brooklyn, NY 11232 (212) 96&6416 REGION III: Delaware. Maryland, Pennsylvania, Virginia. West Virginia, District of Columbia EPA Mr. Charles Sapp Toxic Substances Coordinator Curtis Building (3AH201 6th & Walnut Street Philadelphia, PA 19106 (216) 597-4066 FDA Mr. R. J. Davis Regional Director 2nd and Chestnut Street Room 900 Philadelphia, PA 19106 (216) 597-4390 REGION IV: Alabama, Florida, Georgia. Kentucky, Miesleetppi, North Caroline, South Carolina, Tennessee EPA Mr. Ralph Jennings FDA Mr. M. D. KinsJow Toxic Substances Coordinator 345 Courtland Street, NE Atlanta, GA 30308 (404) 881 -3864 Regional Director 880 W. Peachtree Street Atlanta, GA 30309 (404) 881 -4266 REGION V: Indiana, IHInois. Michigan, Minnesota, Ohio, Wisconsin EPA Mr. Kart Bremer F0A Mr. L. R. Claiborne Toxic Substances Coordinator 230 South Dearborn Street, Room 1165 Chicago, IL 80604 (312) 353-2291 Regional Director 175 W. Jackson Boulevard Room A-1945 Chicago, IL 60604 (312)353-1047 MQNS 007656 18 REGION VI: Arkansas, Louisiana, New Mexico, Oklahoma. Texas EPA Mr. John West PCS Coordinator First International Building 1201 Elm Street Dallas. TX 75270 (214) 767-2734 FDA Mr. P. 8. White Regional Director 3032 Bryan Street OeHas, TX 75204 (2141 749-2735 REGION VII: Iowa. Kansas, Missouri, Nebraska EPA Mr. Wolfgang Brandner Toxic Substances Coordinator 324 East 11 Street Kansas City, MO 64106 (816) 374-6538 FDA Mr. Clifford G. Shane 109 Cherry Street Kansas City, MO 64106 (876) 374-5646 REGION VIII: Colorado, Montana, North Dakota, South Dakota, Utah. Wyoming EPA Mr. Dean Gillam Toxic Substances Coordinator 1860 Lincoln Street Denver, CO 80296 (303) 837-3926 FDA Mr. F. L. Lofsvoid Regional Director 721 19th Street US Customhouse Room 500 Denver, CO 80202 (303) 837-4915 REGION IX: Arizona, California, Hawaii, Nevada, American Samoa, Guam, Trust Territories of the Pacific. Wake Island EPA Mr. Gerald Gavin FDA Mr. I. 0. Berch PCS Coordinator 215 Fremont Street San Francisco, CA 94105 (415) 556-4606 Regional Director UN Plaza Federal Office Bldg. Room 526 San Francisco, CA 94102 (415) 556-2062 REGION X: Alaska, Idaho, Oregon, Washington EPA Dr. Jim Everts Toxic Substances Coordinator 1200 6th Avenue Seattle, WA 98101 (2061 442-6560 FOA Mr. J. W. Swanson Regional Director 909 1st Avenue Room 5003 Seattle, WA 98174 007659 SEPA For additional information you may call ttie Induatry Aaaiatanca Offlca toll fraa at (BOO) 424-9065 (in Waehington, DC 554-14041, or write to Director, Induatry Aaaiatanca Office (TS-799), Office of Toxic Subatancee, U.S. Environmental Protection Agency, 401 M Street, S.W., Waehington, DC 20400. MONS 007660 MUMS 007661