Lead-acid batteries are a popular power source because they’re cost-effective, rechargeable, and can be used in everything from electric vehicles to industrial equipment. But they’re also considered a hazardous chemical by the EPA, and must be reported as such for environmental compliance. This article provides an overview of lead-acid batteries and their risks, along with the regulatory requirements that apply to their storage and use. A general rule is if a facility brings lead-acid batteries on-site that exceeds the EPA Threshold Planning Quantity (TPQ), an Emergency Planning and Community Right-to-Know Act (EPCRA) report is required.
Lead-acid batteries are commonly used in equipment like electric vehicles, forklifts, and industrial machinery. They’re used just as frequently as backup power sources for things such as a building’s lighting and fire protection systems. Lead-acid batteries are effective because of their low upfront costs and ability to be recharged, which limits costs long-term.
Primarily, lead-acid batteries consist of lead-based plates that sit in a bath of sulfuric acid and water, or electrolyte. This is why the EPA qualifies them as a hazardous chemical requiring EPCRA reporting.
Reporting Lead-acid Batteries Under EPCRA
Section 302 in particular requires you to report an EHS to your State Emergency Response Commission (SERC) and Local Emergency Planning Committee (LEPC), within 60 days of when the Threshold Planning Quantity (TPQ) for lead-acid batteries is above the specified threshold of 1,000 pounds.
You can report a lead-acid battery either as a mixture, or its sulfuric acid separately as an EHS. If you report batteries as a mixture, you must outline the physical and health hazards of every chemical component in a battery, as listed on each component’s Safety Data Sheet (SDS).
The Hazards of Damaged Lead-Acid Batteries
A lead-acid battery is known to break from time to time. When it does, the electrolyte begins to leak from its casing and can pose health and safety hazards within a facility and possibly to a surrounding area. If this happens, you must take immediate action to report the spill to your SERC and LEPC and file an EPCRA 304 Notification. The notification must include information like the chemical name, anticipated health risks, emergency contact, and other associated safety information.
If you have hazardous chemicals at your facility, a best practice is to prepare for this type of notification well ahead of a possible spill. Many facilities choose to post this information by a phone in an accessible area so the information can be gathered and communicated quickly. You should also notify your SERC and LEPC immediately over the phone for any accidental leaks or spills.
Lead-Acid Batteries and Their Impact to Environmental Compliance
Lead-acid batteries, as well as lithium-ion batteries, are cost-effective and excellent backup power sources for things such as a building’s lighting and fire protection systems. But because of their hazardous chemical make-up, sulfuric batteries can present health and safety concerns if they’re ever damaged.
Knowing how to manage, report, and properly dispose of sulfuric batteries such as lead-acid and lithium-ion batteries is important. EPCRA was created to help keep facilities, communities and especially first responders and firefighters safe in the event of chemical-based emergencies.
Another reason is that hazardous chemical management is impacted by regulatory scrutiny and accountability from corporations. Sustainability and environmental stewardship are often key priorities and must be adhered to. While EPCRA violations can result in fines and facility closures for a business, recovering from a damaged reputation after a fire or explosion can be extremely difficult.
For lead-acid batteries, lithium-ion batteries, and hazardous chemicals overall, the best way to ensure EPCRA compliance is having visibility over your chemical inventory and knowing it’s constantly up to date across your organization. Encamp can help you and your team achieve, and maintain, such visibility by tracking and centralizing compliance data from all facilities, validating it for accuracy, and even automating EPCRA Tier II reports to all of your required jurisdictions.
Eugene Simonds is an Encamp Compliance Manager, a former Environmental Engineer, and was an environmental consultant before joining Encamp. As a consultant, he specialized in multimedia environmental compliance for a select range of clients and industries. A licensed Professional Engineer (PE) and certified RCRA/DOT/HAZWOPER, his passion is simplifying the environmental compliance experience for everyone.
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