ECAR Fact Sheet for Indiana
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

As the name implies, lead-acid batteries contain both lead and acid (sulfuric acid). Lead can enter the body by ingestion (this usually occurs when putting hands or other objects contaminated with lead dust into the mouth) or by breathing lead dust. The effects of lead on the adult body include the following: problems with reproduction, digestion, and with memory and concentration; high blood pressure; nerve disorders; and muscle and joint pain. Lead is even more dangerous to children because their bodies are more sensitive to lead's effects and because their bodies absorb more lead than do adults' bodies.

Because batteries contain lead and sulfuric acid, lead-acid battery disposal can be 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.

The Indiana Department of Environmental Management (IDEM) has prepared a guidance document to help auto recyclers manage lead-acid batteries. Much of that information is included in the fact sheet below. You can access the link to IDEM's Compliance Manual for Auto Salvage Facilities under Other Relevant Resources.

Regulations

In Indiana, you have several options when disposing of used lead-acid batteries.

Reclamation/Recycling. If you generate, collect, transport, store or regenerate lead-acid batteries for reclamation purposes, you facility may be exempt from certain hazardous waste management requirements. However, if you reclaim batteries and store them prior to reclamation, you are subject to many of the hazardous waste management requirements. A material is "reclaimed" if it is processed to recover a usable product or if it is regenerated. Recovery of lead values from spent batteries is considered reclamation.

Managing as a Universal Waste. Used lead-acid batteries managed as Universal Waste under a special EPA rule have different, less stringent rules, than those managed as hazardous waste.

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.

Managing as a Hazardous Waste. Batteries that are not recycled/reclaimed or managed as a universal waste must be managed as hazardous waste. In addition, a waste determination must be made on all broken or leaking batteries.

Battery Storage.  If you store batteries, you must ensure that the storage area is sufficiently ventilated to prevent the accumulation of explosive mixtures of gases. Ensure that your used batteries are properly managed and recycled by following the steps below:

• Properly store all spent lead-acid batteries in an area with secondary containment or in an area that provides a means to control and contain any battery acid spillage.
• If batteries are stored outdoors, the storage-area must be curbed to contain leaks, and covered to prevent snow and rain from entering.
• Within 90 days from the date you receive the spent lead-acid battery, the battery must be transferred back to the wholesaler; to a facility that collects lead acid batteries for delivery to a recycling facility; or to an IDEM-permitted secondary lead smelter (if sent to a secondary lead smelter in Indiana.)
• 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.

Battery Transporting and Disposal - Labeling. When transporting used batteries that are not cracked or leaking, label them as follows:

• "Battery, wet, filled with acid, 8, UN2794, PGIII, Corrosive" or "Battery, wet, non-spillable, 8, UN2800, PGIII, Corrosive"

When transporting batteries that are cracked and/or leaking, label them as follows:

• "Battery fluid, acid, 8, UN2796, PGII, Corrosive"

If you dispose of spilled battery acid as a hazardous waste, follow applicable storage and disposal requirements, and label the waste as follows to meet DOT requirements:

• "Sulfuric acid, spent, 8, UN1832, PGII, D002"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.

Selling Batteries. Auto salvage facilities that sell batteries must comply with applicable state rules. You must post a sign in a location that is conspicuous to your customers. The sign must be at least 8.5" wide by 11" high and the lettering must be at least 18-point type. The state requires specific language to be placed on the sign.

Charging Batteries. If you charge batteries, you must comply with the following:

• Charge batteries only in areas designated for that purpose.
• Ensure that materials needed to flush and neutralize spilled electrolyte (i.e., a hose and baking soda) are readily available.
• Ensure the reinstalled batteries are properly positioned and secured in the vehicle.
• Provide a carboy tilter or siphon to employees who handle electrolyte.
• Ensure that vehicles are properly positioned with the brake applied before attempting to change or charge batteries.
• Ensure that the batteries' vent caps are functioning. Open the battery or compartment cover to dissipate heat.
• Prohibit smoking in the battery charging area.
• Take precautions to prevent open flames, sparks, or electric arcs in battery charging areas.
• Keep tools and other metallic objects away from the top of uncovered batteries.
• Provide suitable facilities within the work area for emergency drenching or flushing of the eyes and body.

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

Indiana Universal Waste Requirements

Indiana Hazardous Waste Requirements (3.1-1-1 to 3.1-16-2)

Indiana Battery Recycling Requirements (IC 13-20-16)

EPA Standards for the Management of Spent Lead-Acid Batteries Being Reclaimed (Subpart G) 
              

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.

1. Has the facility made a size determination (SQHUW vs. LQHUW)? Review records and current inventory to verify the size determination was correct. A large quantity handler of universal wastes (LQHUW) is a facility that accumulates 11,000 lbs. or more of all universal wastes at any time during the calendar year.
2. If the facility is a LQHUW, they are required to have an EPA Identification Number. Verify that the facility has an EPA Identification Number.
3. All handlers of universal waste are required to meet specific accumulation time limits. Verify that the facility has a system in place to determine accumulation times and that no used batteries have been on-site for more that one year.
4. All handlers of universal waste are required to manage the batteries and other solid waste generated from battery activities according to specific parameters and procedures. Verify that universal waste 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 leakage.
5. All handlers of universal waste are required to manage releases according to specific procedures. Verify that all releases of waste battery residues are immediately contained. Verify that the handler determines if the material resulting from the release is a hazardous waste. Verify that if the material is hazardous waste, it is handled appropriately in accordance with all applicable RCRA requirements.
6. All employees who handle or have responsibility for managing universal wastes are required to be trained. Verify that all employees have been trained in the proper handling and emergency response procedures relative to their responsibilities during normal facility operations and emergencies.
7. Universal waste batteries are required to be labeled. Verify that universal waste batteries (each battery), or a container in which the batteries are contained, are labeled or marked clearly with any one of the following phrases:

• UNIVERSAL WASTE BATTERY(IES)
• WASTE BATTERY(IES)
• USED BATTERY(IES).

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. You should:

• Request documentation from your transporter confirming that your batteries were delivered to permitted lead-acid battery recycling facility. It is your responsibility to ensure that your batteries are recycled. If the transporter improperly disposes of your batteries, you can be held financially responsible for the clean up costs resulting from the improper disposal.
• Store all lead-acid batteries on an impermeable surface such as coated concrete or asphalt.

You Should Consider:

• Requiring your customers to pay a refundable deposit on all batteries purchased. This deposit is intended to encourage customers to bring their spent battery back to your facility for recycling.
• Storing your used batteries on a wire shelf and installing polyethylene spill trays below the shelf to catch any spilled acid. Storing batteries on a wire shelf with plastic spill trays placed below the shelf will allow you to easily inspect all batteries for damage and to contain any leaking battery acid. By storing your batteries in this manner, you can readily determine which battery is leaking and can properly neutralize the acid.
• Use an authorized recycler.
• Indoor storage is recommended for lead-acid batteries.
• Store batteries on an acid resistant rack or tub.
• Batteries stored outside should be stored on impermeable surfaces such as concrete and should have secondary containment.  Also, it is recommended that batteries be covered to prevent acid run off.
• Keep a neutralizing agent, such as baking soda, nearby in case of leaks or spills. If a spill does occur, the waste must be treated as a hazardous waste.
• When stacking batteries, make sure they are stored so that any fluid from leaking batteries will not be released into the environment.
• Electrolyte fluid in spent batteries contains enough lead to qualify it as a hazardous waste. This fluid, if discharged onto the ground, will likely make the soil which absorbs it a hazardous waste. 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. 

Contacts

1. For more information, contact the Indiana Department of Environmental Management (IDEM) at 800-451-6027 or 317-232-8603.
2. Report spills and environmental emergencies immediately to IDEM by telephone at 1-888-233-7745.
3. Submit a pollution complaint online through the IDEM Pollution Complaints Clearinghouse.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Indiana Auto Salvage Program Home
2. Indiana Auto Salvage Compliance Manual

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