Remember PCBs?

Are you talking about Printed Circuit Boards? (If not ignore the following)

If so manufactures will use standard material specs.... the only thing I'd worry about was any change over to lead free solder.

I think someone is being over fussy... remember the system should be there to help you not vice versa.

There is no point auditing what has already gone..they should concentrate on getting it right now, e.g. Auditing current suppiers.

Who is doing this internal audit? Suggest he write some procedures to ensure adeqaute documentation in future...delegate upwards.

Quote from my old Dad, when asked by the Ministry of Defence about documentation.

'You can have a device that works, or a room full of paper explaining why it doesn't. Which do you want?'

For clarifications sake, PCBs are Polychlorinated Biphenyls and were/are used as a dielectric media in transformers and capacitors (most common). I am currently wading through the EPA instruction for guidance but it is mostly legalese.

Oh well that would have been nice at trick one... I've ranted about acronyms sooo many times I'm shedding fur with furrstration.

BWFT

(T is Time.... W is waste, you can work the rest out yourself...)

Acronyms are on the Red List, though as they are being discharged into cyberspace, it's OK.

out2sea71,

I'm a little unclear what exactly you are after... What is your company vending, and to whom?

Was this "letter" requested by the person conducting the internal audit?

Does your company own, store or use electrical (or hydraulic) equipment that could contain PCBs, or generate hazardous/regulated (PCB) waste?

You should be able to contact the equipment manufacturers for any electrical transformer, capacitor, or dielectric fluid filled switch (etc.), and based upon the model & serial #, by Federal law, the manufacturer must provide you with information regarding the specific type of dielectric fluid it contains, and the quantity...

Beyond that, you may find that many manufacturers will not state unequivocally that their equipment contains "No PCBs".

The EPA regulations governing manufacturing, use, storage & disposal of PCBs (40 CFR Part 761) contain provisions that allow the operator of potential PCB –containing electrical equipment to make assumptions regarding the PCB content. These assumptions apply ONLY to equipment that is in use; prior to disposing of any such potential PCB containing equipment, actual testing for PCB content must be performed, as stipulated in the regs.

The allowable assumptions appear at 40 CFR Part 761.2, and include:

(1) Any transformers containing < 3 pounds (1.36 kilograms (kgs)) of fluid, circuit breakers, reclosers, oil-filled cable, and rectifiers whose PCB concentration is not established can be assumed to contain PCBs at < 50 ppm.

(2) Any mineral oil-filled electrical equipment that was manufactured before July 2,1979, and whose PCB concentration is not established is assumed to be PCB-Contaminated Electrical Equipment (i.e., contains ≥50 ppm PCB, but < 500 ppm PCB).

All poletop and pad-mounted distribution transformers manufactured before July 2, 1979, must be assumed to be mineral oil filled. Any person may assume that electrical equipment manufactured after July 2, 1979, is non-PCB (i.e., < 50 ppm PCBs).

If the date of manufacture of mineral oil-filled electrical equipment is unknown, any person must assume it to be PCB-Contaminated.

(3) Any person must assume that a transformer manufactured prior to July 2, 1979, that contains 1.36 kg (3 pounds) or more of fluid other than mineral oil and whose PCB concentration is not established, is a PCB Transformer (i.e., ≥ 500 ppm).

If the date of manufacture and the type of dielectric fluid are unknown, any person must assume the transformer to be a PCB Transformer.

(4) Any person must assume that a capacitor manufactured prior to July 2, 1979, whose PCB concentration is not established contains ≥500 ppm PCBs. Any person may assume that a capacitor manufactured after July 2, 1979, is non-PCB (i.e., < 50 ppm PCBs). If the date of manufacture is unknown, any person must assume the capacitor contains ≥500 ppm PCBs. Any person may assume that a capacitor marked at the time of manufacture with the statement ''No PCBs'' in accordance with § 761.40(g) is non-PCB.

You can find a somewhat helpful EPA guidance document, entitled

"The PCB Q and A manual"

At:

http://www.epa.gov/pcb/pubs/qacombined.pdf

I hope this helps...

Good morning and thank you for the reply. We are a manufacturing company that produces large diesel crankshafts. We were audited over what we use in the process of forging these pieces. Many of our machines are hydraulic, pneumatic and electrical. Your reply was in line with with which I was looking. My supervisor was looking to go a bit deeper by getting each machine vendor to supply a list of all dialectric material used and quantities. I was only looking for a governing document that says such a request would be in accordance with... (ex, ISO 9001) I have visited the EPA site before and provided him with a bit of guidance in the direction he move during the next audit.

Thanks again