ECAR Fact Sheet for Pennsylvania
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.

Lead-acid batteries, commonly used in vehicles, can create disposal problems. Landfilling presents the risk of groundwater contamination. With incineration, the risk is toxic air emissions. Given present disposal options, recycling is the only safe solution. Recycling these batteries not only conserves natural resources and energy, it reduces risks to human health and the environment.

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

In Pennsylvania, recycling of lead-acid batteries is required.

Recovery/Sale/Resale of Lead-Acid Batteries. If a lead-acid battery that is still functional is recovered from a scrap automobile and offered for sale/resale as is, it would not be a solid waste (and therefore also not a hazardous waste) since it is not being discarded, abandoned, or recycled.

Reclamation of Lead-Acid Batteries. If you must reclaim the batteries through regeneration (such as electrolyte replacement), you are exempt from hazardous waste regulations, except for identification and management of any wastes generated through regeneration (such as spent/waste acid, broken batteries, etc.).

Regulations regarding such regeneration, as well as other activities associated with spent, lead-acid batteries can be accessed under "Links to Regulations."

Disposal. You may not place a used lead-acid battery in a landfill, discard or otherwise dispose of a lead-acid battery except by delivery to an automotive battery retailer or wholesaler, to a secondary lead smelter permitted by the Environmental Protection Agency, or a collection or recycling facility authorized by the Pennsylvania Department of Environmental Protection (DEP). A list of authorized battery recyclers can be accessed under "Other Relevant Resources."

Lead-acid battery wholesalers. If you sell new lead-acid batteries at wholesale, you must accept, at the point of transfer, used lead-acid batteries from customers in a quantity at least equal to the number purchased. If you accept batteries in transfer from an automotive battery retailer, you have 90 days to remove batteries from the retail point of collection.

Inspection of automotive battery retailers. If you resell lead-acid batteries, you may be inspected by DEP.

Storing or transporting scrap lead-acid batteries. If you store or transport scrap lead-acid batteries, they are not subject to hazardous waste regulations, providing that the batteries remain whole and intact. Used lead-acid batteries must be stored properly to prevent contamination or injury from acid spillage or leakage. Indoor storage is recommended because it reduces risks from temperature extremes which cause batteries to crack and leak.

Spills. Any spilled acid must be handled as a hazardous waste because it is corrosive and may contain toxic levels of lead. Report any spills that escape the storage area to your DEP regional office, or contact DEP's 24-hour hotline at 800-541-2050. If the batteries are not reclaimed, you must follow the hazardous waste regulations.

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

Section 15.10 of Pennsylvania's "Municipal Waste Planning, Recycling and Waste Reduction Act," Act 101 of 1988.

Pennsylvania Hazardous Waste Regulations

Pennsylvania Requirements for Spent Lead-Acid Batteries Being Reclaimed

Federal EPA Standards Applicable to Generators of Hazardous Waste

Federal EPA Regulations for Spent Lead-Acid Batteries Being Reclaimed

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 used battery storage areas and management procedures.

1. 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 conditions 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.

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.

• If batteries are cracked and/or leaking, they need to be placed in a sealable five-gallon bucket and managed as hazardous waste.
• Acid from batteries that is spilled on the salvage yard soil could pose a danger of burns from contact on human skin.
• Any spills should be cleaned up promptly.
• Indoor storage is recommended for lead-acid batteries.
• Batteries should be placed upright on pallets, stacked no more than five high, and inspected regularly.
• Cracked or leaking batteries may be placed singly in sealable 5-gallon polypropylene pails or other containers that are sturdy, acid-resistant, leak-proof and sealable, and kept closed within the storage area.
• An indoor storage facility has at least three walls and a roof permanently attached to a masonry or other floor. An acid-resistant coating, such as epoxy, may be applied to an asphalt or concrete floor to prevent corrosion from spillage. Acid-resistant curbing should be constructed around the storage area to contain any spills that escape the building. Curbs for small storage areas could be constructed of either asphalt or a simple wooden frame completely covered with a 20-40 mil sheet of acid-resistant polyethylene, polypropylene, or polyvinyl chloride.
• Check batteries for leaks, cracks, etc. prior to storing.

Contacts

1. For more information, contact the recycling coordinator in your DEP Regional Office, or the Division of Waste Minimization and Planning at 717-787-7382. Signs for retail establishments that meet the requirements of 15.10(c)(2) are available upon request.
2. To report a spill, contact DEP's 24-hour hotline at 800-541-2050.
3. To report an environmental incident or complaint, contact the DEP Field Office

Related ECAR Fact Sheets

1. Hazardous Waste

Other Relevant Resources

1. PA Universal Waste page.

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