A former coworker contacted me with a question on January 29, 2016:
I have a quick question for you Dan. If a facility has 5 – 6 consumer (car type) lead-acid batteries that they want to take to a salvage yard for recycling, is there a DOT exemption or something that keeps them from being classified as a hazardous substance. I think they need to transport with shipping papers and be properly labeled. Let me know if you have any experience with this.
I had time to fire off a reply that day:
Please note below:
- When discarded by recycling a liquid lead acid battery will be a hazardous waste per USEPA regulations.
- Liquid lead acid batteries sent for reclamation are excluded from regulation as a hazardous waste per 40 CFR 266.80.
- A liquid lead acid battery is a hazardous material per USDOT regulations.
- A liquid lead acid battery that is not a hazardous waste may be transported by a non-transportation business under the Materials of Trade exception at 49 CFR 173.6.
- The following is required under the Materials of Trade exception:
- Secure batteries in vehicle.
- Label batteries.
- Likely batteries contain a Reportable Quantity (RQ) for lead, so this must be marked on the side.
- Inform driver of Materials of Trade exception and some basic worker safety.
- No more than 66 lbs/battery & no more than 440 lbs of HazMat in the vehicle.
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Note from Daniels Training Services: My reply does not take into account the exception from regulation available to shippers of batteries found at 49 CFR 173.159(e).