What are the marking requirements for vehicles transporting PCBs?

Vehicles transporting either (1) > 45 kg (99.4 lbs) of liquid PCBs with a concentration >=50 ppm of PCBs or (2) one or more PCB Transformers must be marked on each end and each side of the vehicle.

What is the significance of EPA adding 40 CFR Part 761.40(k)(2) about marking PCB Transformers and PCB Large (Low or High Voltage) Capacitors?

40 CFR Part 761.40(k)(2) requires marking of all equipment containing a PCB Transformer or PCB Large (Low or High Voltage) Capacitor that electronic assembly was not marked at the time of manufacture, distribution in commerce, or removal from use. This means that if the mark falls off or otherwise disappears from a PCB Transformer or PCB Large (Low or High Voltage) Capacitor while in use, the owner/operator is responsible for making sure the equipment is remarked. Prior to this amendment, the responsibility for marking had been put solely on the manufacturer or retailer, and no responsibility for maintaining the mark had been placed on the owner/operator of the equipment.

CAUTION CONTAINS PCBs

A toxic environmental contaminant requiring special handling and disposal in accordance with U.S. Environmental Protection Agency Regulation electronic assembly 40 CFR 761 – For Disposal Information contact the nearest U.S. E.P.A. Office.

In case of accident or spill, call toll free the U.S. Coast Guard National Response Center: 800-424-8802

Are there any other labeling requirements?

Yes. In addition to applying the PCB mark to the required PCB and PCB Items, PCB wastes being stored prior to disposal must also be labeled with a notation indicating the date that the item was removed from service for disposal. If the wastes in storage include drums of PCB-contaminated soil from a remediation activity, the “date removed from service for disposal” would be the date on which the soil was excavated and placed into drums. If the wastes are liquid wastes (e.g., solvents used for flushing or decontaminating PCB Items), the “date removed from service for disposal” is defined as the date that the first batch went into the drum. If PCBs in containers or PCB Items are contaminated with hazardous wastes regulated under the authority of the Resource Conservation and Recovery Act (RCRA), they must be marked in accordance with the applicable RCRA hazardous waste marking requirements, as defined in 40 CFR Part 262, as well as with the applicable TSCA marking requirements.