Because RCRA does not regulate PCBs as a listed waste, a wastestream containing PCBs will only be subject to RCRA if it exhibits one of the hazardous waste characteristics. Guidance on this concept is provided in an EPA Office of Solid Waste memo (SOC 1986-26). One exception, is PCB-containing dielectric fluid that is hazardous only because it fails the toxicity characteristc for organics (i.e., hazardous waste codes D018-D043), this waste is exempt from RCRA regulation per §261.8.

Facility operators should be aware that fluorescent light ballasts contain small capacitors which may be contaminated with PCBs. However, these ballasts may be disposed of as municipal solid waste regardless of PCB concentration per 40 CFR §761.60(b)(2)(ii). Although it is not required, you may, choose to send these light ballasts to an incinerator rather than a landfill to protect the lab from any future liabilities.