Legislative Affairs

Yesterday ASBO International and eight other organizations submitted comments to the Environmental Protection Agency (EPA) on a proposed rule that would reassess use authorizations for polychlorinated biphenyls (PCBs) in small capacitors, specifically PCB light ballasts in schools and daycares. The rule would require schools and daycares to phase out and discontinue using PCB light ballasts in their facilities due to potential health risks regarding PCBs. Please see this EPA PowerPoint presentation on the proposed rule for more details.

While we share EPA's concerns about the potential health risks of PCBs, we are also concerned about the scope of the EPA's rule and unintended consequences the rule and its tight compliance schedule would have on local governments and schools. Some concerns from the letter are highlighted below.

• EPA's two- or four-year proposed compliance schedule would cause extreme hardship on local governments, districts, and schools to implement the rule.
• EPA's PCB data does not match up with 2014 survey findings that ASBO International and other organizations gathered with regard to PCB issues in schools. EPA believes 38% of schools have leaking PCB lighting fixtures whereas our survey data only showed 2.1% of schools; this discrepancy should require the EPA to conduct a new nationwide survey to ensure the scope/cost of the PCB problem is accurately understood before issuing a final rule.
• The rule is duplicative of a Department of Energy (DOE) rule for updating energy efficiency requirements to remove PCB light ballasts by 2020. Instead of spending time/resources on issuing a new rule, we encourage the EPA to work with local governments and schools to incentivize the early removal of  PCB light fixtures

Please see the full letter for more details and stay tuned to this thread for updates on this initiative.

Attachment(s)

E O 13132 Comments - EPA PCB Issue 9-26.pdf   636 KB 1 version