FEBRUARY 26, 2015: A QUESTION FROM A PREVIOUS ATTENDEE OF ONE OF MY TRAINING SEMINARS:
I had a question come up about transporting batteries to a recycle vendor. A 2000 lb lead acid battery that is on one of my trucks going to a scrapper. What is required. Are you going to need a placard on the truck and label on the battery as corrosive along with the paperwork or is it an ORM-D? How does DOT view this type of load?
MY REPLY ON MARCH 2ND (I WAS BUSY!):
Sorry for the delay in replying. I can get you an answer, but I need some more information: Please clarify what you mean by “on one of my trucks going to a scrapper.” Is this battery still connected to a vehicle? Is the vehicle gas-powered (gasoline)? How will it be transported? In a vehicle? On a vehicle? Towed by a vehicle?
Please advise on the above and I can get you an answer.
CUSTOMER REPLIED (3.3.15):
One of our trucks from our distribution center, a 53’ trailer semi, was transporting a bad forklift battery to a scrap vendor. The battery was skidded up and packed correctly according to DOT regs. It was going via semi, over highway, to the scrap vendor. Essentially its an ORM-D for recycle so you’re outside of RCRA.
MY QUICK REPLY ON MARCH 3RD:
You are correct on several counts and should be in compliance with DOT & EPA regulations overall. Some clarification:
- A lead acid battery of the type you describe is a hazardous material per DOT regulations when offered for transportation.
- A battery of this size is not subject to the ORM-D Exception.
- Pursuant to DOT regs [49 CFR 173.159(d)] authorized packaging for shipping a battery of this type includes “secured to skids or pallets”. Other basic packaging requirements must be met.
- DOT regs [49 CFR 173.159(e)] include an exception from full regulation as a hazardous material for batteries of this type if they are secured properly and other basic requirements are met. Therefore, no shipping papers, placards, labels, or markings as a hazardous material are required.
- A lead acid battery sent for recycling is a hazardous waste pursuant to the regulations of the EPA.
- However, an exclusion exists for a Recyclable Material as a lead acid battery if it is sent for reclamation (40 CFR 266, Subpart G). Per this exclusion a lead acid battery sent for reclamation is not subject to the regulations as a hazardous waste. This exclusion does not apply if the battery is sent for disposal other than reclamation.