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Proper Transportation of a 2,000 Pound Battery for Reclamation

Proper Transportation of a 2,000 Pound Battery for Reclamation

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.
I hope this helps.  Please don’t hesitate to contact me with any questions.
Do you have questions about the transportation of batteries with vehicles being sent for scrap?  Ask me!

Daniels Training Services

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