Even when not required by environmental regulations, the following best practices are recommended.
- Establish and maintain a PCB management system that includes proper identification, marking, recordkeeping, inspection, and testing of PCB-related equipment.
- Training programs should include hazards associated with PCBs and procedures for proper storage and disposal.
- Emergency response and SPCC plans should include sections on how to prevent and respond to potential spills or releases of PCBs or PCB contaminated material.
- Label all equipment that contains oil as “PCB contaminated material” or as “non-PCB contaminated” equipment.
- To the extent reasonable and cost effective, replace PCB materials and PCB contaminated materials with non-PCB products. Equipment that no longer contains PCBs or PCB contaminated material can then be reclassified and labeled as “non-PCB contaminated.”
- Assign responsibility and accountability for PCB items to specific personnel.
- Test bulk used oil for PCBs if there is reason to believe the oil may be contaminated with PCBs.