The PCB Mark

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The PCB Mark

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What is a PCB mark and what does it look like?

The PCB mark (see Figure 1) is a label with black striping around the border that contains certain information specified in the regulations that apply to PCB Items (i.e., any manufactured item containing or contaminated with PCBs). There are two marking formats, “Mark ML” and “Mark MS”; the only difference between the two is the size of the mark. PCB Mark ML is a 6" x 6" square; PCB Mark MS is a 1" x
2" rectangle. The text of the mark includes the warning “Caution Contains PCBs,” instructions in case of accident or spill, and the telephone number of the National Response Center. The PCB mark must have either a yellow or white background.

Where is the PCB mark required to be attached?

The mark must be placed in a prominent position on the exterior of a PCB Item so that it can be easily read. The mark must also be sufficiently durable to equal or exceed the life of the PCB Item. If Mark ML is too large for the item, it may be proportionally reduced in size to a minimum of 2" x 2". If a mark smaller than 2" x 2" is required, Mark MS may be used. If Mark MS is too large, it may be reduced in size proportionally to a minimum size of 1 cm x 2 cm. Both marks are commercially available from vendors of industrial placarding and health and safety supplies.

What types of PCB Articles and PCB Equipment require marking?

Items requiring marking include:
 1. PCB Transformers (i.e., transformers with >500 ppm of PCBs),
 2. PCB Large High voltage capacitors,
 3. PCB Large Low voltage capacitors,
 4. PCB Equipment (containing any of the three articles listed above),
 voltage regulators with  3 lbs of  500 ppm of PCBs,  electric motors with coolants  50 ppm of PCBs,  hydraulic systems with hydraulic fluids 50 ppm of PCBs, and
 5. heat transfer systemswith fluid  50 ppm of PCBs.

What types of PCB Containers require marking?

Containers with 50 ppm of PCBs, liquid or non-liquid, must be marked (e.g., containers with PCB remediation waste or PCB bulk product waste, either of which has 50 ppm of PCBs).

What types of PCB Article Containers require marking?

A PCB Article Container must be marked if it contains a PCB Article, PCB Equipment, or PCB Container that must be marked.

What are the marking requirements for areas where PCB Articles are in use or operating?

There are two types of locations where PCB Articles in use or operating must be marked. One is the access (e.g., machine room door, vault, highway, fence) to where a PCB Transformer or a voltage regulator with  3 lbs of  500 ppm of PCBs is located. The other is a protected location for an individual PCB Large (Low or High Voltage) Capacitor. A protected location may be a pole, structure, or fence. In such cases the individual capacitor does not require marking but (1) the protected location must be marked, (2) a record identifying the PCB Large Capacitors must be kept at the protected location, and
(3) the individual capacitor(s) must be marked when removed from the protected location.

If there is more than one door or access leading to the location inside a building of a PCB Transformer or voltage regulator with  3 lbs. of  500 ppm of PCBs, which door or access should be marked?

All doors or accesses leading from the outermost door to the door immediately accessing the PCB Transformer or voltage regulator location should be marked. Although the regulations do not require that all these doors be marked, it is a best management
practice to do so. The reason is that marking all doors from the outermost door leading to the innermost door immediately accessing the PCB Transformer or voltage regulator assists fire fighters in identifying the location of the PCB Transformer or voltage regulator.

What PCB storage locations are required to be marked?

Only areas storing PCBs and PCB Items for disposal are required to be marked.

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