Document Xza9kmo2DjL3JRx5o3J39BMDK

vEPA Urntd Siaies Enyiroi menial Proledjon Agency December 1979 Toxic Substances __ Polychlorinated Biphenyls: An Alert for Food and Feed Facilities This booklet has been published by the Environmental Protection Agency in cooperation with the Department of Agriculture and the Pood and Drug Administration. HONS 202234 foreword UNITFD STATES ENVIPONMEN FAL PROTECTION AGCNCT v, A C.H Nt* ri ' g ^ I- 1 December 19"? 9 The food and feed industries are particularly vulnerable to contamination from polychlorinated biphenyls (PCS), PCBs are ubiquitous, persistent industrial chemicals that are known to tause Serious health and environmental effects. The Environmental Protection Agency has responsibility for regulatory control of PCBs and other tonic substances under the Tome Substances Control Act of 1996. We are working cooperatively with the Food 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 PCS contamination. Thla booklet has been prepared to; * Alert you to the serious potential problem# 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 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 action without delay. This brochure will assist you in your efforts. MONS 202235 Polychlorinated Biphenyls: An Alert for Food and Feed Facilities MONS 202236 Why the concern? 2 In recent years, there have been a number of incidents where food has been contaminated with polychlorinated biphenyls fPCBs) and other toxic chemicals. This contamination has resulted from accidental spills, improper disposal, and unintentional misuse of PCB-containrng 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 PCBa 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 a* fluid* in electrical transformers, capacitors, and electromagnets, and heat transfor and hydraulic systems. HONS 202237 Why ere PCBs hazardous? 3 PCBs have also been used as plastrcrzers 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 alectrica! 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 nee 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 auch 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 202238 4 Why should food and fad related induatriaa be aspacially concerned about pCBa? The Yusho incident illustrates the serious human health and economic consequences of PC8 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 PCBe 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 involvrng stored electrical transformers m the same warehouse, Death and severe illness of feedlot cattle in Kansaa caused by inadvertent use of PCB-contaminated od 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 animate, and major disruption of the companies involved. HONS 202239 PCBs In th environment 5 Unltke most organtc chemicals which break down fairly rapidly in the environment, PCBs are extremely stable. The potential for biomagnification in the food chain is of special concarn Biomagnification is the process through which small amounts of toxic substances leach 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 provida the food for small fish and other animals which are in turn eaten by higher forma 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. HONS 202240 6 Where might PCBs he found In food industry facilities? The following types of equipment may contain PCS fluids or other liquids such at miners! oil that ere contaminated with PCBs; Transformers Large capacitors (over 3 ibs of fluid) Electromagnets Heat transfer and hydraulic systems Small capacitors Equipment conteining 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 Squid. SmeM capacitors ate of lass concern because the PCBs are usually m a nonkqutd, nonmoMe state. CAPACITORS Capacitors have been manufactured m a wide range of sues for venous industrial uses. Capaci tors may contain PCB dielectric fluids HONS 202241 7 HEAT TRANSFER SYSTEM Haat transfer sysrams containing PCBs have baan usad m food procassmg aquipmani Existing federal regulations concerning PCBa 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 (EPA). Under FDA regulations foods and feeda are considered to be contaminated and may not be sold in interstate commerce if they contain PCBs m excess of certain prescribed concentrations. (See Table 1.) The use of PCBs m food and animal feed processing facilities, except enclosed use in transformers and capacitors, is prohibited by FDA regulation 121 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, capacitors, and capacitor-containing equipment with PCB concentrations greater than 50 ppm is allowed. HONS 202242 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, 1384 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 atl 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 aH your food and feed related facilitiea. i HONS 202243 i 9 Checklist for Action What can I do? A. Determine If you have PCB equipment. 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 nameplates. If your transformer or capacitor has a manufacturer's nameplate with a trade name, rafer to Table 2 at the and of this booklet. If the trade name does not appear there, the equipment may stiH contain PCBs. Contact the manufacturer, referencing the serial number to determine if the equipment contains PCBs. If there is no nameplata, or if this approach is unsuccessful... 4. Seek assistance from a servicing axpart. Call on your local transformer servicing company or the engineering servica 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 sampla your heat transfer systems, hydraulic systems, or other suspect oil. (Do not attampt 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. . B. Consider replacing PCB-contekilng equipment with non-PCB ~ equipment EPA, FDA, and USDA ara considering prohibiting the use of PCBs in ail alectncal 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 202244 C. Taka special precautions for continued use, 10 As an alternative in transformers, you may want to consider replacing tha PCB fluid with non-PCB fluid. You should be aware that the transformers will contain residual PCB concentrations aftar replacement and. therefore, may be subject to future federal regulation. EPA disposal regulations require incineration of aM PCB liquids with concentrations of 500 ppm (0.005%) or greater. The first approved incinerators wfll be available sometime in I960. 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-contsining 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 leek 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 wey 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 aver 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, ara thera curbs or pans to servo 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 wali/fioor interface tight? MONS 202245 11 6. Is tha floor in tha vicinity of a PCB unit free from cracks? Cracks that look like thay would not prevent tha loss of fluid should be grouted and painted wrth solvent resistant materials, or government approvad materials if required. 7. Is tha 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 locatad near machinery which might throw projecttlas 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 seel, such as unweldad steel plates or in a mobile machine? If so, a catchbasin might be installed under die 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 m 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 storsge requirements, D. Be femWsr with mandatory labeKng and atorage requirements. 1. Labeling requirements. Jhe epA for PCB# i***, uke this. MQNS 202246 E. Obtain further Information. 12 You must label the following items: transformers containing liquids with more than 500 ppm of PCBs, PCS capacitors with 3 (three) or more pounds of fluid operating et 2,000 volts or more, containers such as bags, bairels, 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 pieced on the following items when they aie 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 e 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 end other moving equipment. For assistance with the storage design criteria, contact the EPA regional office for your atata. A list of EPA regional offices appears at the beck of this booklet. (See Appendix B.) if you do not yet have the EPA regulations on PCBs, you can obtain a free copy from EPA by casing toll free (8001 424-9065 (in Washington, DC, 554-14041 and asking for a reprint of the PCB Ban Regulation, Faderai Ragistar, May 31, 1979, and for a fist of the approved PCB Disposal Facilities. (f you went more background information on tha regulation, ask for a fraa 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.S. Environmental Protection Agency, 401 M Street, S.W., Washington, OC 20460. You may also contact die nearest EPA Regional Office. (See Appendix B.) Other useful background information on PCBs is listed in Appendix A. HONS 202247 Table 1. 13 FDA Limits on PCB Concentration In Food Food Concentration (parts per million) Milk and manufactured dairy products 1 5 ppm (fet basis) Poultry 3 ppm (fat basis) Red meat 3 ppm (action level) (fat basis) Eggs 0.3 ppm Fish and shellfish 5 ppm (edibla portion)* Feed for food producing animats 0.2 ppm (except concentrates, supplements, and premixesl Infant and | unior foods 0.2 ppm Animal feed components 2.0 ppm of animal origin Paper food packaging m 10 ppm direct contact with food (action level) Source." Title 21, Code of Federal Regulations, Section 10930; Federal Register, Vot. 44, No. 127, Juno 29, 1979, pp 38330-38340 *4 regutonon establishing e new level of 2 ppm wet promuF geted but wet stayed on October 5, 1979 untd further nonce. HONS 202248 14 Table 2. PCB Manufacturer* and Trade Name* PCBs have been marketed and used by manufacturers in their products under various trade names. This list is not necessarily complete sinca many companies have gone out of business and information is no longer available. Manufacturer Country Trade Name Aerovox Allie-Chalmer* American Corp, Axel Electronic* Bayer Caffaro Caffaro Caffero Capacitor Specialists Chemko Cornell Dubilier Dings Co. Electrical Utilities Corp. Electro Engineering Works Electromagnetic filter Co. Envirotech Buell Eriez Magnets ESCD Mfg. Co. Ferranti-Packard Ltd. General Electric Geneva industries H. K, Porter Helena Corp. Hevi-Duty Electric ITE Circuit Breaker Jard Corp. Kanegafuchi KuNman Electric McGraw Edhon ; Maloney Electric Moncanto 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 Asbeatol Clophen Dk Fancier Incior Oykanoi Eucaral Pyranol Askarel* Askarel* Pyranol Askarel* Non-Flammable Liquid Clorphen Kennechlor SafT-Kuhl Elemex Aroctof Santotherm FR Pyroclor HONS 202249 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. ResearcIvCottrell Sangamo Electric Sovoi Sprague Electric Co. Standard Transformer Corp. Stans Magnetics Tobe Deutschmann Labs. Universal Mfg. Corp. Van Tran Electric Wagner Electric Westlngriouse 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 -- -- Trad* Name Therminol* Pydraul*** Santovac 1 and 2 Askarel*, EEC-18 Arocior B EEC-18 Phenockw Phyralene Askarel* Otador Chlorinol Askarel* No-Flamol Inerteen NepoBn ApiroSo Kanedor 'Askarel m the generic name used far nonflammable insulating kquaf m transformers and capacitors. Various products used as boat transfer fluids, such as Thormtnof Fft-O, wars manufac tured under this name. '"Venous products used as hydraulic fluid, such as Pydraul A 2Q0, ware manufactured under this name. HONS 202250 Appendix A 16 Other Available Information on PCBa 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 hettth issues for servicing PCB equipment or cleaning up PCB spills. "Criteria for a Recommended Standard ... Occupa tional Exposure to Polychlorinated Biphenyls IPCBsl." DHEW (NIOSH) Publication No- 77-226. September 1977. Order from Superintendent of Documents, U.S Government Printing Office. Washington, D.C. 20402 Price M.00 plus postage. "Assessment of the Use of Selected Replacement Fluids for PCBs In Electrical Equipment'' Report No. EPA 56016-77-008. 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 Ssrvice, Springfield, Virginia 22161. Report No. NT1S 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 262-012. HONS 202251 17 Appendix B When Cm ( Seek Assistance? Assistance from EPA or FDA mav ho obtained by contacting your nearest regional office, Plante 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 office# for FDA and EPA. REGION 1; Connecticut Maine, Massachusetts. New Hampshire, Rhode Island, Vermont EPA FDA Mr. Robert Dangei Toxic Substances Coordinator John F. Kennedy Federal Building Boston, MA 02203 (617) 223-0585 Mr A. J. Beebe Regional Director 566 Commercial Street Boston, MA 02109 (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 (212)264-1926 FDA Mr. Caesar A. Roy Regional Director 830 3rd Avenue Brooklyn, NY 11232 1212) 965-5416 REGION III: Delaware, Maryland, Pennsylvania. Virginia, Weat Virginia, District of Columbia EPA Mr. Charles Sapp Toxic Substances Coordinator FDA Mr, R. J. Davis Regional Director Curtrs Building (3AH20) 2nd and Chestnut Street 6th r Walnut Street Philadelphia, PA 19106 (215) 697-4066 Room 900 Philadelphia, PA 19106 (216)5974390 REGION IV: Alabama, Florida, Georgia, Kentucky, Mississippi. North Carolina. South Carolina. Tenneesee eA Ml. Ralph Jennings Toxic Substances Coordinator 346 CourtJarxJ Street, NE Adame, GA 30306 (404) 881-3964 FDA Mr. M. D. Kinstow Regional Director 880 W Peachtree Street Atlanta, GA 30309 (404) 8814266 REGION V: Indiana. Illinois, Michigan, Minnesota, Ohio, Wisconsin EPA Mr. Karl Bremer Toxic Substances Coordinator 230 South Dearborn Street. Room 1166 Chicago, lb 60604 (312) 363-2291 FDA Mr. L. R. Claiborne Regional Director 175 W. Jackson Boulevard Room A-1945 Chicsgo, IL 60604 (312) 353-1047 HONS 202252 18 REGION VI: Arkansas, Louisiana, New Mexico, Oklahoma, Texaa EPA Mr. JOhn Weat PCB Coordinator Ftrat International Building 1201 Elm Street Daliat, TX 7S270 (214| 707-2734 FOA Mr. P. B. White Regional Director 3032 Bryan Street Daflaa, TX 75204 1214) 749-2736 REGION VII: Iowa. Kanaaa, Missouri, Nebraaka EPA Mr. Wollgang Brandner Toxic Substances Coordinator 324 East 11 Street Kanaaa City, MO 64106 (816) 374-6538 PDA Mr. Clifford G. Shane 109 Cherry Street Kanaaa City, MO 84106 (816) 3746646 REGION VIII: Colorado. Montana, North Dakota. South Dakota, Utah, Wyoming EPA Mr. Dean GiHam FDA Mr. F. L. Lofsvold Toxic Substances Coordinator 1860 Lincoln Street Regional Director 721 19th Street Denver, CO 80295 US Customhouse Room 500 (303) 837-3926 Denver, CO 80202 (303) 837-4915 REGION IX: Arizona, California, Hawaii, Nevada, American Samoa, Guam, Truat TarritoHaa of tha Pacific. Waka Island EPA FDA Mr. Garatd Gavin Mr. I. B, Barch PCB Coordinator Regional Director 216 Fremont Street UN Plaza San Franciaco, CA 94105 Federal Office Btdg. (415)6564806 Room 526 San Francisco, CA 94102 (4151 556-2062 REGION X: Alaska, Idaho. Oregon. Washington f>'_ EPA > Or. Jim Everts Toxic Substances Coordinator 1200 6th Avenue Seattle, WA 98101 (2061442-5660 FDA Mr. J, W. Swanson Regional Director 909 1st Avenue Room 5003 Seattle. WA 96174 HONS 202253 For additional information you may cal tha Industry Aasiatanca Office toll Ira* at (6001424-9066 (in Wash ington, DC 554-1404), or writs to Director, industry Assistance Office ITS-799), Office of Toxic Substances, U.S. Environmental Protection Agency, 401 M Street, S.W., Washington, DC 20400. HONS 202254 Uftrtad Stain Environment^ PrOMtKW Agency Washington 0 C 20440 OAoal Buimtti Penalty for Private Uti S30C Poetape and Peee Paid Eftonrortmaraal Protachan Agency 6PA 334 IS Third Claai t HONS 202255