ECAR Fact Sheet for Louisiana
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.

The Louisiana Department of Environmental Quality (DEQ) has prepared a guidance document to help auto recyclers manage lead-acid batteries. Much of the information is included in the fact sheet below. You can access the DEQ’s lead-acid battery guidance under Other Relevant Resources.

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).

Waste Classification. Spent lead-acid batteries may be managed under Louisiana’s Universal Waste Rule. 

Small Quantity (SQH) and Large Quantity (LQH) Handlers. A SQH of universal waste is a handler who does not accumulate 5,000 kilograms or more total of universal waste batteries, pesticides, thermostats, lamps, or antifreeze, calculated collectively, at any time. A LQH of universal waste is a handler who accumulates 5,000 kilograms or more total of universal waste batteries, pesticides, thermostats, lamps, or antifreeze, calculated collectively, at any time. This designation as a LQH of universal waste is retained through the end of the calendar year in which 5,000 kilograms or more total universal waste is accumulated.

Notification Requirements.  A SQH is not required to notify the DEQ of its universal waste handling activities. A LQH of universal waste must have sent written notification of universal waste management to the state’s permit division, and have received an EPA Identification Number, before meeting or exceeding the 5,000 kilogram storage limit.

Lead-Acid Battery Storage. Lead-acid batteries that show evidence of leaks, spills, or damage that could cause leaks must be kept in a container that is closed, structurally sound, and compatible with the contents. If a container develops a leak, it should be moved into an over pack container.

As long as the casing of individual battery cells is not breached and remainsintact and closed you may:

• sort batteries by type;

• mix battery types in one container (keep in mind any compatibility issues);

• discharge batteries to remove the electric charge;

• regenerate used batteries;

• disassemble batteries or battery packs into individual batteries or cells;

• remove batteries from consumer products; or

• removing electrolyte from batteries provided that cells are immediately closed after removal.

Accumulation Times. Do not store lead-acid batteries for more than one year. You should keep records of accumulation times using one of the following methods:

• Marking either the storage area, the containers, or individual items of lead-acid batteries with the earliest date that the batteries became a waste or were received;

• Maintaining an inventory system on-site that identifies the date the lead-acid batteries became a waste or were received; or

• Using any other method which clearly demonstrates the length of time that the lead-acid batteries have been accumulated from the date it became a waste or was received.

Labeling Lead-Acid Batteries. Both SQH’s and LQHs must clearly mark or label spent lead-acid batteries as "Universal Waste-Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)."

Employee Training. You must inform all employees who handle or have responsibility for managing lead-acid batteries of proper handling and emergency procedures.

Response to Releases. You must immediately contain all releases and other residues of lead-acid batteries and determine whether any material resulting from the release is a hazardous waste.

Transporting Lead-Acid Batteries. Lead-acid batteries can only be taken to another universal waste handler, a destination facility, or other approved destinations. A SQH of universal waste is not required to keep records of shipments of universal waste. If SQH’s self-transport lead-acid batteries off-site, you must comply with the state’s transporter requirements.

A LQH of universal waste must keep a record of each shipment of universal waste received at the facility. The record may take the form of a log, invoice, manifest, bill of lading, or other shipping document. The record for each shipment of universal waste received must include the following information:

• The name and address of the originating universal waste handler or foreign shipper from whom the universal waste was sent.

• The quantity of each type of universal waste received.

• The date of receipt of the shipment of universal waste.

Shipments Off-Site. A LQH of universal waste must keep a record of each shipment of universal waste sent from the handler to other facilities. The record may take the form of a log, invoice, manifest, bill of lading or other shipping document. The record for each shipment of universal waste sent must include the following information:

• The name and address of the universal waste handler, destination facility, or foreign destination to whom the universal waste was sent.

• The quantity of each type of universal waste sent.

• The date the shipment of universal waste left the facility.

Recordkeeping Requirements. A LQH of universal waste must retain records for at least three years from the date of receipt of shipments to the facility or from the facility.

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

Louisiana Universal Waste Management Requirements (Part V, Chapter 38)

Federal EPA Standards Applicable to Generators of Hazardous Waste

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 lead-acid battery storage areas and management procedures.

1. Are lead-acid batteries stored in drums, tanks or other containers that are in good condition? Store lead-acid batteries in a container that remains closed, is structurally sound, and compatible with the batteries and that lacks evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions.

2. Are you storing the lead-acid batteries for the permitted accumulation time? Do not store lead-acid batteries for more than one year from the date the batteries are generated or received.

3. Are lead-acid battery storage containers and tanks properly labeled? Clearly label or mark each container or tank of lead-acid batteries with any one of the following phrases: "Universal Waste-Battery(ies)," "Waste Battery(ies)," or "Used Battery(ies)."

4. Is the area around the lead-acid battery containers free of releases? Releases must be immediately stopped, cleaned up and managed properly. Any releases that pose a threat to human health or the environment must be reported immediately to DEQ.

5. Are lead-acid batteries transported to an approved recovery facility? Ensure that all shipments of lead-acid batteries were taken to another universal waste handler or a destination facility, or other approved destinations by the transporter.

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 lead-acid battery storage areas and management procedures.

• Lead-acid batteries that show evidence of leaks, spills, or damage that could cause leaks must be kept in a container that is closed, structurally sound, and compatible with the contents.

• Do not accumulate lead-acid batteries for more than one year.

• Ensure all employees are properly trained with handling and emergency procedure relating to lead-acid batteries.

• Immediately contain all releases of lead-acid batteries and report any releases that pose a threat to human health or the environment.

• Ensure lead-acid batteries are sent to approved recycling or other facilities.

• Keep any records relating to lead-acid batteries for at least three years.

Contacts

1. For more information, contact the Louisiana Department of Environmental Quality (DEQ), Office of Environmental Services at 225-219-3181.
2. To report a spill or leak, call the DEQ’s 24-Hour Notification Hotline at 225-342-1234. You can access notification procedures at the DEQ’s Single Point of Contact Procedures website.
3. To report an environmental incident or complaint, contact the nearest regional office.

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. Louisiana – Universal Waste Fact Sheet

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