Lithium cells and batteries pose a variety of risks due to their potential for an uncontrolled chain reaction resulting in heat and fire. When discarded they display the characteristic of Reactivity as defined by USEPA (and states) and are therefore regulated as a hazardous waste. When offered for off-site transportation they are regulated as a Class 9 Miscellaneous by the USDOT/PHMSA.

However, both of these agencies allow for a “deregulation” or even an exception from full regulation if specified requirements are met.  This article is meant to be a source of useful information for anyone who seeks to comply with the regulations of the USEPA (and their state environmental agency) and the USDOT/PHMSA but also wants to take advantage of a relief from full regulation when they can.The beginning point for this article is a video briefly summarizing the requirements of the federal and state agencies.  After that will come links to other articles I’ve written describing various aspects of the applicable regulations.  If you have any questions about any of this information, please don’t hesitate to contact me.

Read these articles for more information (contact me if you still have a question):

Information of the USDOT/PHMSA specific to lithium cells or batteries in transportation:

• Classification of Lithium Batteries for Transportation in Commerce
• Lithium Cells or Batteries Shipped for Disposal or Recycling
• General Requirements and Provisions for the Transportation of Lithium Batteries
• Replacement of the Old Lithium Battery Handling Label with the New Lithium Battery Mark

Other regulations of USDOT/PHMSA applicable to the transportation of lithium cells or batteries:

• An Explanation of USDOT’s Hazard Class 9 Miscellaneous
• Special Provision 130 of the Hazardous Materials Table for the Transportation of Batteries, dry, sealed, n.o.s.

USEPA regulations for the identification and management of universal waste:

• The Universal Waste Option
• Labeling Universal Waste Containers for On-Site Storage
• Documenting the On-Site Accumulation Time Limit for Universal Waste
• Training Requirements for Handlers of Universal Waste

Other regulations of the USEPA applicable to management of lithium batteries:

• A state may have an authorized hazardous waste program that differs from the federal regulations.
• A spent or used lithium battery will display the characteristic of reactivity (D003)