A pound of PCBs
Missouri DNR puts the CERCLA threshold at "a pound or more of PCBs (roughly equivalent to 10-12 fluorescent ballasts)". Disposing of that much in 24 hours requires notifying the National Response Center.
Ballast recycling that sorts out the PCBs first.
Ballast recycling starts with sorting, because some old ballasts contain PCBs and follow separate federal rules. EPA guidance treats ballasts made before July 2, 1979, or unlabeled ones through 1998, as possible PCB ballasts.
In plain terms
A ballast's PCBs sit in one of two places: the small capacitor, or the potting material that fills the case. Federal rules treat those two very differently. EPA says only T12 magnetic ballasts may contain PCBs, not T8 or T5 ballasts. So sorting starts with the fixture type.
- Magnetic and electronic
- Pre-1979 units kept apart
- Lamps and batteries too
- A record for every job
The PCB record
Where 40 CFR 761 sends each ballast.
Four questions decide the path: when the ballast was made, where its PCBs sit, whether it leaks, and how long it waits. Each row cites the section that answers it.
The date test
Assume a capacitor made before July 2, 1979 holds 500 ppm or more of PCBs, unless its PCB concentration is established. Without a test result, the date decides.
40 CFR 761.2(a)(4)
The label test
Ballasts made from July 1, 1979 to July 1, 1998 without PCBs had to carry a "No PCBs" label. No label means assume PCBs, unless the ballast is known to be made after 1979.
EPA guidance
PCBs in the capacitor only
An intact, non-leaking ballast with PCBs only in its small capacitor may go out as municipal solid waste. Capacitor manufacturers are the exception.
40 CFR 761.60(b)(2)(ii)
PCBs in the potting
These must go to a TSCA-approved disposal facility. The rule also allows bulk product waste, household waste where applicable, or the decontamination provisions.
40 CFR 761.60(b)(6)(iii)
Bulk product waste
The definition names "Fluorescent light ballasts containing PCBs in the potting material" outright, so potting ballasts follow the bulk product waste paths.
40 CFR 761.3, 761.62
Leaking ballasts
EPA classes a leaking ballast as PCB bulk product waste for incineration. Fixtures it contaminated become PCB remediation waste, and cleanup follows the spill rule.
40 CFR 761.125(c)(1)
Storage for disposal
Leaking ballasts may be stored for disposal up to 30 days. Ballasts with potting at 50 ppm or more may be stored up to 180 days. Date the container when the first unit goes in.
40 CFR 761.65(c)(1), (c)(9)
The lamps beside them
EPA says intact lamps from the same fixtures are universal waste, under a separate federal rule. See lamp recycling for that side of the job.
40 CFR Part 273
Sources: eCFR, 40 CFR Part 761 (2026). EPA, PCBs in school buildings (January 2025 snapshot), 2020 ballast fact sheet and ballast storage chart. The sorting steps are in our PCB ballast identification guide. Federal rules shown. States can be stricter. Not legal advice.
Identification triage
PCB, non-PCB or DEHP: sort before you ship.
Three kinds of ballast come out of an older ceiling. The lamp type, the label and the date sort most of them, and anything uncertain goes with the PCB units. On our pickups, we keep pre-1979 and unlabeled ballasts apart from the rest of the load.
The tests below are EPA's own. They do not replace a manufacturer's data or a lab result when a ballast's history is unknown. Watch for guides that quote 1978 or 1980; the federal date is July 2, 1979.
| Attribute | Possible PCB | Non-PCB | DEHP capacitor |
|---|---|---|---|
| Typical ballast | T12 magnetic ballast from an older fixture | T8 or T5 ballast, or any ballast labeled "No PCBs" | Some ballasts made after 1979, from manufacturers that used DEHP in capacitors |
| Date and label test | Made before July 2, 1979, or no "No PCBs" label and no proof of a later date | Labeled "No PCBs", or known to be made after 1979 | Made after 1979; the label alone does not settle it |
| Federal rule | Capacitor only and intact: municipal solid waste allowed. Potting PCBs: TSCA-approved paths | The PCB disposal rules do not apply; state and local rules still can | Used DEHP in ballasts "no longer meets the listing description" for U028, but parts can still be hazardous by characteristic |
| Where the concern sits | The small capacitor, the potting material, or both | No PCBs, by label, lamp type or date | The capacitor fill, not the potting |
| If it leaks | PCB bulk product waste for incineration, stored no more than 30 days | Clean it up and contain it; ask your state about the residue | Contain it and ask your state; parts can test hazardous |
| Local limits seen | Ramsey County, MN bars PCB ballasts from the trash. Illinois treats leaking units as special waste | King County, WA bars all ballasts, PCB or not, from transfer stations | EPA notes states can be stricter than the federal reading |
| On our pickup | Kept apart from the rest of the load | Collected with your lamps and batteries | Tell us on the quote request so it is counted |
Scroll the table sideways to see every column.
Sources: EPA, PCBs in school buildings (January 2025 snapshot) and 2020 fact sheet. 40 CFR 761.60 and 761.65. EPA letter of June 8, 1994 (RCRA Online 11842). Ramsey County, MN; King County, WA; Illinois EPA. Identification guidance, not a lab test.
Beyond the federal floor
Why the trash allowance is narrower than it looks.
Federal rules let some intact PCB ballasts go out as municipal solid waste. Reporting thresholds, county rules and shipping limits narrow that option quickly on a real job. Here is what we found in agency guidance.
Leaking means special waste
Illinois EPA says non-leaking PCB ballasts "are considered a municipal solid waste". Leaking ones are special waste, and they ship with a manifest. One bad unit changes the paperwork for that container.
No transfer stations
The county is blunt: no ballast goes to any transfer station, "both PCB and non-PCB". The rule covers every ballast from the ceiling, not only the old magnetic ones.
Assume 50 ppm
Ecology publication 22-04-029 tells schools to assume 50 ppm or more. Ballasts then go to a TSCA incinerator or chemical landfill within one year.
Out of the trash
The county's wording is plain: "It is illegal to place ballasts that contain PCBs in the trash". Check your own county's rule before any ballast leaves the site.
Not a mail-back item
PCB ballasts do not go in lamp mail-back kits. Book a scheduled pickup for them, and note the rough count on your quote request so the crew comes ready.
Sources: Missouri DNR publication 2081; Illinois EPA; King County, WA; Washington Department of Ecology publication 22-04-029; Ramsey County, MN. These are agency and county rules, not statewide recycling mandates. Confirm the rule where you work.
Retrofit workflow
Five steps from fixture to record.
Most ballasts leave a building during a lighting retrofit or a demolition. This order keeps PCB units out of the general waste stream. Running the crew? See recycling for contractors.
Survey before demo
Open a sample of fixtures on each floor. Note the T12 magnetic ballasts, read every label for "No PCBs", and write down the counts.
Pull them whole
EPA tells demolition crews to "avoid breaking these items" and "handle them separately from other demolition waste". A cracked case can turn into a leak.
Sort into three bins
Possible PCB, non-PCB and leaking. A leaking unit never shares a container with intact ones, and unsure units go in the PCB bin.
Date every container
Leaking ballasts get 30 days in storage for disposal. Potting ballasts at 50 ppm or more get 180. The date on the container starts each clock.
Ship with a record
We schedule pickup around your job, with lamps and batteries on the same visit. You get a recycling record for every job.
If a ballast is leaking
What changes when a ballast leaks.
EPA warns that "An FLB failure can happen without warning at any time". PCBs are "persistent, bioaccumulative toxicants", so a leak changes the waste class, the storage clock and the paperwork.
- Keep people clear: exposure is mainly through contaminated air or touching contaminated materials
- Start cleanup under 40 CFR 761.125(c)(1); one EPA page sets a 24-hour window
- Treat the ballast as PCB bulk product waste for incineration
- Treat fixtures it contaminated as PCB remediation waste
- Keep intact lamps from the fixture as universal waste
- Ship the leaking ballast within the 30-day storage limit
- In Illinois, ship leaking units as special waste with a manifest
- Keep it out of lamp mail-back kits; book a pickup instead
- Tell us about the leak on the quote request before pickup
- Check your state agency for any added cleanup rules
Sources: EPA, PCBs in school buildings (January 2025 snapshot); 40 CFR 761.65(c)(1) and 761.125(c)(1); Illinois EPA. Federal rules shown. States can be stricter. Not legal advice.
Missouri Department of Natural Resources, publication 2081Landfilling PCB ballasts is allowed, but it carries a "high potential of CERCLA liability."
Ballast questions
What people ask before a ballast pickup.
Short answers, each tied to the rule behind it. For the lamp side of a retrofit, the storage and labeling questions are different.
Can ballasts go in the trash?
Only in narrow cases. An intact, non-leaking ballast with PCBs only in its small capacitor may go out as municipal solid waste under 40 CFR 761.60(b)(2)(ii). Potting PCBs need a TSCA-approved path, and Ramsey County, Minnesota bars PCB ballasts from the trash outright.
How can I tell if a ballast contains PCBs?
Check the lamp type, the label and the date. EPA says only T12 magnetic ballasts may contain PCBs. Ballasts made before July 2, 1979 may contain them. Treat an unlabeled ballast as PCB unless you know it was made after 1979.
What is a DEHP ballast?
A DEHP ballast has a capacitor filled with DEHP, which some manufacturers used after 1979. In a June 8, 1994 letter, EPA said used DEHP in ballasts "no longer meets the listing description" for U028. The parts can still be hazardous by characteristic, and states can be stricter.
How long can PCB ballasts be stored?
A leaking ballast can be stored for disposal up to 30 days under 40 CFR 761.65(c)(1). A ballast with potting PCBs at 50 ppm or more can be stored up to 180 days. Date each container when the first ballast goes in.
Why does capacitor versus potting matter?
It decides the federal disposal path. PCBs only in the small capacitor of an intact ballast allow municipal solid waste disposal under 761.60(b)(2)(ii). PCBs in the potting make it bulk product waste under 761.3, which must go to a TSCA-approved facility or another 761.62 path.
Do non-PCB ballasts have any disposal limits?
Yes, in some places. The PCB rules stop applying, but local rules do not. King County, Washington says ballasts, "both PCB and non-PCB", cannot be disposed of at any transfer station. Check your county before treating a labeled "No PCBs" ballast as ordinary trash.
Are PCB ballasts dangerous to handle?
Intact ones are mainly a disposal problem, but leaks are a health concern. EPA calls PCBs "persistent, bioaccumulative toxicants" and says exposure is mainly through contaminated air or touching contaminated materials. EPA also warns that a ballast failure "can happen without warning at any time", so handle old units whole.
Does a large retrofit trigger PCB reporting?
It can if ballasts are disposed of rather than recycled. Missouri DNR says disposing of a pound or more of PCBs in 24 hours requires notifying the National Response Center. It puts a pound at roughly 10 to 12 fluorescent ballasts. Count before anything goes in a dumpster.
What does a "No PCBs" label tell me?
It marks a ballast made without PCBs. EPA says ballasts made between July 1, 1979 and July 1, 1998 that do not contain PCBs must be labeled "No PCBs". Without the label, treat it as a PCB ballast unless you know it was made after 1979.
Who is responsible for ballasts removed in a retrofit?
Often both the building owner and the contractor. ALMR, the lamp recyclers' trade group, warns contractors "may share that legal responsibility" for retrofit waste. It adds that the most significant lamp and ballast enforcement actions "have involved lighting retrofits". Agree in writing who books pickup and keeps the record.
Can businesses schedule a ballast pickup?
Yes. We schedule pickup around your job, and one pickup can take lamps, ballasts and batteries together. Pickup is the route for PCB ballasts, since they do not go in lamp mail-back kits. Send rough counts and we reply with a written quote.
Do I get documentation after my ballasts are recycled?
Yes, a recycling record for every job. Each job closes with a record of what was collected and where it went. Keep it with your project files, next to any manifests for leaking units in states such as Illinois.
Tell us how many ballasts are coming down.
Rough counts are enough, even before anyone has read the labels. Mention any leaking units and the lamps coming out alongside them. We reply with a written quote.