Batteries

ECAR Fact Sheet for Colorado
Batteries

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources

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The 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

Because batteries contain lead and sulfuric acid, lead-acid battery disposal is fully regulated as a hazardous waste management activity. When intact lead-acid batteries are recycled, the handling requirements are relaxed, but the batteries are still subject to limited hazardous waste regulations. This fact sheet will tell you:

How to determine whether spent batteries should be considered a hazardous waste.
What you need to do to handle batteries in compliance with the rules that apply to you.

Regulations

Automotive recyclers who generate, collect, transport, store, or regenerate lead-acid batteries for reclamation purposes may be exempt from certain hazardous waste management requirements. The basic rule of thumb is that the batteries must be either reclaimed either through regeneration or another means. If the batteries are not reclaimed, you must follow the hazardous waste regulations.

You may choose to manage your spent lead-acid batteries under the "Universal Waste" rule, which is a special EPA designation. EPA developed universal waste regulations to encourage recycling of certain specific wastes. These rules are less demanding than the hazardous waste rules. The universal waste rules are applicable to auto recycling companies who receive and store batteries for recycling, but are not applicable to companies that reclaim batteries (covered under separate rules).

Auto recyclers who receive, store, and send batteries off-site for recycle are "universal waste handlers." There are two groups of handlers, based on the amount of universal waste accumulated on-site at any one time:

Small Quantity Handler of Universal Wastes (SQHUW) – accumulates less than 11,000 lbs. (5,000 kg) of universal waste at any time during a calendar year.
Large Quantity Handler of Universal Wastes (LQHUW) – accumulates 11,000 lbs. or more (5,000 kg) of universal waste at any time during the calendar year, which would require the site to have an EPA Identification Number.

Once you trigger the LQHUW status you remain a LQHUW for the rest of the calendar year. However, you re-evaluate your classification at the start of each calendar year.

Battery Storage. Always store lead-acid batteries in a secured, covered location, that is designed to contain leaks and temperature extremes. Keep batteries away from open flames or other ignitable sources. Do not stack lead acid batteries since they may crack and leak acid and other hazardous components, thereby incurring a potential expensive cleanup. Keep batteries off the ground to prevent them from coming in contact with water, which may result in contaminated runoff into creeks and streams. Do not store batteries around inside floor drains or outside storm drains.

Improper storage practices can result in potential violations to the Federal Clean Water Act, as well as violations of state and local water quality laws.

Labeling and Marking. Waste batteries (i.e., each battery), or a container or tank in which the batteries are contained, must be labeled or marked clearly with any one of the following phrases: "Universal Waste -- Battery(ies)," or "Waste Battery(ies)," or "Used Battery(ies)."

Response to Releases. Should your batteries leak onto the ground, you must immediately contain all releases and determine whether any material resulting from the release is hazardous waste. If so, you must manage the hazardous waste in compliance with all applicable laws.

Links to the Regulations. Use the following links to view the regulations pertaining to battery management.

Colorado Universal Waste Management Requirements (Part 273)

Self-Audit Checklist

When 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).

Use the following list to audit your battery storage and management procedures.

All battery handlers are required to manage the batteries and other solid waste generated from battery activities according to specific parameters and procedures. Batteries must be stored in a way that protects human health and the environment. Store batteries indoors and under cover. Do not store by combustible materials. If acid leaks out of the batteries, treat the spilled acid as a hazardous waste.

Best Management Practices (BMPs)

Most regulations 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 procedures.

Store batteries indoors or under cover to keep them dry and prevent damage to the casings.
Never store batteries near combustibles such as gasoline because of the risk of sparks caused by electrical discharge of batteries.
Store batteries so that any leaking liquid will be caught and won't go onto the ground. The liquid inside batteries is sulfuric acid and it may contain dissolved lead and cadmium.
It is preferable that you store the batteries inside a well-ventilated area, on pallets and in an organized manner.
Neutralize small spills with common baking soda, lime or cement. Wear eye protection and gloves. Contain the spill and manage it as hazardous waste.
Use a wooden frame lined with heavy polypropylene or a small plastic swimming pool to store batteries. Check frequently for cracks or tears.
If batteries are stored over asphalt or concrete, coat these surfaces with acid-resistant epoxy, fiberglass, plastic coating, or a polypropylene liner.
Store leaking or cracked batteries in sealed, five-gallon plastic pails.
Store batteries in an upright position to prevent leakage from vent holes.
Do not stack batteries more than five high.
When transporting lead-acid batteries, they should loaded to prevent them from short-circuiting, becoming damaged or leaking acid.
Accumulate as few lead-acid batteries as possible.
Ensure that you send your lead-acid batteries to permitted recyclers, brokers or other allowable facilities.
Before you start collecting lead-acid batteries, arrange and know where they will be ultimately sent.
Make sure you are in compliance will all local and fire department laws, as they may have restrictions on battery storage.
Never drain the acid from the battery.
Ensure that your employees are trained how to handle lead-acid batteries, specifically leaking batteries.
Always use eye protection and gloves when handling lead-acid batteries.
Always wash your hands after handling lead-acid batteries.

Contacts

For more information, contact the Colorado Department of Health and Environment’s technical assistance line at 303-692-3320, or toll-free at 888-569-1831, if outside of the 303 area code.
To report a spill or leak, at minimum, call the Colorado 24-hour Emergency Spill/Release Reporting Line at 877-518-5608 and the Local Emergency Planning Committee at 303-273-1622, immediately or within 24-hours. Refer to the Spill Response Fact Sheet to determine your reporting requirements.
To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR Fact Sheets

Other Relevant Resources