Q&A: Transporting Lead Acid Batteries for Reclamation as a Material of Trade

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.

Thanks,

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.

FYI: Even though this situation does not require HazMat Employee training, the fact that they receive hazardous materials makes them subject to the training requirements. They may also need RCRA training.

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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).

Questions like this come into me all the time. Sometimes they can be answered simply. Sometimes more time and research is required. Either way, I’m happy to answer any questions you may have about the transportation of hazardous materials or the generation and management of hazardous waste.

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

A Question About Transportation of Liquid Lead Acid Batteries

A question from a reader of my Newsletter on July 22, 2015:

Is there a certain height maximum that wet batteries UN2794 can be loaded for highway transportation? I believe there is and I am looking for the specific information. If so can you tell me specifically where I can find this information. I just finished reading your article from November 13 2014 for Packaging Wet Batteries for Transportation and did not see anything regarding loading height limits.

Thank You

My reply the very next day (7.23.15):

Thank you for contacting me. The answer to any question about packaging for batteries, wet, filled with acid can be found in 49 CFR 173.159 (referenced from column 8 of the Hazardous Materials Table).

173.159(d)(1) includes the only reference to packaging height that I can find in the HMR. It reads in part: “Electric storage batteries are firmly secured to skids or pallets capable of withstanding the shocks normally incident to transportation are authorized for transportation by rail, highway, or vessel. The height of the completed unit must not exceed 11⁄2 times the width of the skid or pallet. …”

173.159(e) contains a very good exception from most of the HMR when transporting solely batteries (i.e. no other HazMat on the vehicle) by highway or rail.

I hope this helps. Please don’t hesitate to contact me with any other questions.

Thanks again for contacting me.

Dan

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

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