ECAR
Fact Sheet for Ohio
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
Battery components are toxic and
corrosive. Lead and sulfuric acid can contaminate the air, soil
and water. Direct contact with sulfuric acid can burn the skin and
eyes. Because exposure to lead in the environment can pose a serious
health hazard, used lead acid batteries are hazardous and they have
to be handled according to special rules. However, by properly
recycling your used lead acid batteries, you can get something of
a break from the otherwise very demanding rules that apply to most
hazardous wastes. This fact sheet will tell you:
- How to handle batteries so that
you are not subject to the full scope of Ohio's hazardous waste
rules
- What you need to do to handle
batteries in compliance with the rules that apply to you
Regulations
If you are removing lead acid batteries
from vehicles and sending them to a recycling facility, they are
not subject to the full scope of Ohio's hazardous waste rules. For
batteries that will be recycled, you can manage them under Ohio's
existing battery rules in OAC
3745-58-70. Or you can manage
them under Ohio's hazardous waste regulations as a "universal waste,"
which is a special designation. Both regulations have reduced standards
for batteries that will be recycled.
*If you are not recycling lead acid
batteries, you must evaluate them before they are disposed of to
determine if they are a hazardous
waste. Because of the lead
and acid contained in these batteries, they will likely be a characteristic
hazardous waste, and the applicable hazardous waste rules must be
followed.
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) ø 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) ø 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 stormdrains.
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.
Transportation. A transporter
of universal waste is not required to get an identification number
or required to obtain a hazardous waste transporter permit from
Ohio EPA. A waste manifest is not required either, but a transporter must
comply with all applicable US Department of Transportation (US DOT)
regulations, including having the shipment properly packaged, labeled,
marked, placarded, and transported with the proper shipping papers.
Contact US DOT at (517) 377-1866 for more information. A transporter
of universal waste is required to deliver the shipment to a universal
waste handler, destination facility, or foreign destination.
Links to the Regulations. Use
the following links to view the regulations pertaining to battery
management.
Ohio
Administrative Code (OAC) 3745-273 on Universal Waste Management
Standards
40
Code of Federal Regulations, Part 273- RCRA Standards for Universal
Waste Management
Identification
and Listing of Hazardous Waste
Part
262 - 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
battery storage and management procedures.
- 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.
- If the facility is a LQHUW,
they are required to have an EPA Identification Number. Verify
that the facility has an EPA Identification Number.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
Contacts
- For more information, contact Ohio
EPA's Compliance Assurance Section at 614-644-2917.
Related
ECAR Fact Sheets
- Hazardous
Waste
Other
Relevant Resources
- Environmental Compliance Guide for Vehicle Salvage Yards
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