Fact Sheet for California
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following fact sheet was prepared by the ECAR Center staff. Once
prepared, each ECAR Center fact sheet undergoes a review process
with the applicable state environmental agency(ies). You can check
on the status of the review process here.
Please read the disclaimer on the status page. While we have tried
to present a summary of the essential information on this topic,
you should be aware that other items, such as local regulations,
may apply to you.
What You Need to Know
contain lead and sulfuric acid, lead-acid battery disposal
is fully regulated as a hazardous waste management activity. However, when
intact lead-acid batteries are recycled, the handling requirements
are relaxed. This fact sheet will tell you:
- How to determine whether spent batteries should be considered a hazardous
- What you need to do to handle batteries in compliance with the rules
that apply to you.
the state of California, spent lead-acid batteries do not fall under
EPA's special "universal waste" designation. That designation
is reserved for other types of batteries. However, California will
give handlers of batteries a break from the demanding hazardous
waste regulations if:
- You generate no more than 10 batteries per year, or store or transport
not more than 10 batteries at one time. If this is the case, you
are not subject to the reporting and recordkeeping requirements
as long as the batteries will go to someone who stores, recycles,
uses, reuses or reclaims them.
- You generate more than 10 batteries per year, or store or transport
more than 10 at one time, but you follow the requirements and
keep records about the batteries.
is illegal to dispose of lead-acid batteries and can be punishable
by a penalty of up to $25,000 per occurrence. If you plan to do
anything other than recycle batteries, you must manage them as hazardous waste.
The following rules apply to the
management and storage of spent batteries:
- Undamaged batteries should be stored upright on a covered pallet
over a non-reactive curbed or sealed surface to prevent the terminals
- Damaged batteries are batteries that are cracked, broken or missing
one or more caps. You must store and transport damaged batteries
in non-reactive, secure, closed containers. (If missing caps can
be replaced and there are no other leaks or damage, the battery
can be managed along with intact batteries.)
- Damaged and intact batteries can be transported together so long
as the container holding the damaged batteries is labeled in ink
or paint with the date the first battery was placed there (accumulation
- Generators and interim storage facilities (those that hold batteries
until they are sent to a battery recycler) that keep one ton or
less may store batteries for up to one year at a single location.
- If you hold more than one ton of batteries at one location, you may
not keep them for longer than 180 days.
any of the above quantities or times are exceeded, the business
is no longer exempt from the hazardous waste requirements.
If you ship more than 10 batteries
at a time, a legible hazardous waste manifest or a bill of lading
must accompany the shipment. The generator, transporter and storage,
recycling or disposal facility must retain their copies of those
documents for 3 years.
transporter must make certain that the batteries are loaded so as
to prevent damage, leakage of lead, or short circuits, and must
comply with all Department of Transportation regulations for hazardous
materials. You may transport damaged batteries with intact ones
so long as DOT standards are met.
Recordkeeping. Brokers and handlers of more than
10 batteries per year and those who transport more than 10 batteries
at one time are required by the battery regulations to keep all
copies of bills of lading or manifests related to the transport
of lead-acid batteries for a period of at least 3 years.
no longer requires you to submit an annual battery report per section,
but you must keep the data that would enable you to create such
a report. That data should be found on the bills of lading and manifests.
to the Regulations. Use
the following links to view the regulations pertaining to battery
California Code of Regulations
an inspector comes to your facility, there are certain things he
or she checks to see if you are in compliance with environmental
regulations. It makes good sense for you to perform a "self-audit"
and catch and correct problems before they result in penalties.
Also, there are some compliance incentives associated with self-audits
(see Audit Policy Page).
the following list to audit your used battery storage areas and
- Does the facility generate, store or transport no more than 10 batteries
per year? Review
records and current inventory to verify the size determination
was correct. If so, you are not subject to the reporting and recordkeeping
requirements so long as the batteries are being recycled.
- Does your facility generate, store or transport more than 10 batteries
per year? If
the management requirements are followed correctly, you may still
manage the batteries under the relaxed standards.
- All battery handlers are required to meet specific accumulation time
limits and quantity limits. Facilities handling one ton or less may store batteries for up to
one year at any single location. Facilities holding more than
one ton of batteries at one location may keep them no longer than
- All battery handlers are required to manage the batteries and other
solid waste generated from battery activities according to specific
parameters and procedures.
Verify that batteries are managed in a way that prevents releases
of any batteries or battery components to the environment. Verify
that batteries that show evidence of leakage, spillage, or damage
that could cause leakage under reasonably foreseeable condition
are stored in a container. Verify that containers are closed,
structurally sound, compatible with the contents of the battery,
and lack evidence of leakage, spillage, or damage that could cause
- Facilities that transport more than 10 batteries at one time are
required to track off-site shipments. The hazardous waste manifest or bill of lading must accompany the
shipment and copies must be kept by the generator, transporter
and recycling facility for 3 years. It should include:
- names and addresses of generator, transporter
and receiving location
- number of batteries transported
- damaged batteries are marked
Management Practices (BMPs)
tell you what you have to do to be in compliance, but they don't
explain how to do it. That's where "best management practices"
come into play. BMPs are proven methods that help you to get into
compliance and stay there. The following BMPs are recommended for
battery storage areas and management
- Remove batteries before crushing any vehicles.
- Test batteries to determine usability or resale quality.
- If lead-acid batteries are recharged for resale, remove lead cable
ends from batteries, store lead parts in a covered container that
is strong enough to hold the weight of the lead and recycle the
lead with a reputable recycler.
- If spent lead-acid batteries are going to be recycled as scrap batteries,
leave lead battery cable ends attached to the scrap batteries.
- Check batteries for leaks, cracks, etc. prior to storing.
- Place cracked or leaking batteries in a closed, watertight, acid
resistant storage container.
- Store batteries upright, on wooden pallets, in a secure, covered
location, on a bermed impermeable surface or in watertight,
acid resistant containers.
- Do not pile batteries higher than four batteries high.
- Remove other known sources of lead from vehicles when practical.
- Store lead parts in a covered container that is strong enough to
hold the weight of the lead.
- Recycle lead parts with a metals or battery recycler.
the DTSC Public and Business Liaisons at 800-728-6942, or go to
http://www.dtsc.ca.gov. Follow the 'Toxic
Questions?' and 'Contact a Live Person!' links to the page listing
each of the Duty Officers' email addresses.
- To report large spills and releases to the environment, contact your
local emergency response offices (usually 911) as well as the
Office of Emergency Services Warning Center: 800-852-7550.
ECAR Fact Sheets
in the Solution Guidance Manual (Developed by the State of California
Auto Demantlers Assn)
Department of Toxic Substances Control Management of Spent Lead-Acid
Batteries Fact Sheet
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