Fact Sheet: Case Study: Guidelines for Transporting Used Lead-Acid Batteries

Alaska Department of Environmental Conservation
Division of Environmental Quality
September 1994

A fact sheet on guidelines for transporting used lead-acid batteries, from the Alaska Department of Environmental Conservation Division of Environmental Quality.

Introduction

Increasingly, communities throughout Alaska are exploring ways to recycle lead acid batterie. To assist community recycling activities, this fact sheet provides information on the regulatory requirements for transporting used lead-acid batteries including:

• identification of the regulations governing battery transport;
  
• packaging requirements;
  
• marking, labeling, and placarding requirements;
  
• shipping paper requirements;
  
• considerations for transporting batteries by air; and
  
• considerations for transporting damaged batteries.

Regulations Governing Transport of Batteries

• Lead-acid batteries are primarily automotive-type batteries, including batteries from motorcycles, snowmobiles, boats, and forklifts. Department of Transportation regulations governing the transport of lead-acid batteries are found at 49 Code of Federal Regulation (CFR) Parts 172, 173, and 176.

• DOT regulations specify requirements for packaging of spent batteries, completion of forms, labeling, and correct placement of the batteries in the transportation carrier. Failure to comply with these requirements may result in civil or criminal penalties for the carrier and/or the person shipping.

• In addition to DOT regulations, there are a number of other laws governing the transport of ba batteries: the International Maritime Organization (IMO) addresses transport by vessel, and the International Civil Aviation Organization (ICAO) addresses transport by aircraft. However, compliance with DOT packaging and transport regulations generally is sufficient. (Communities should contact the carrier they plan to use to verify that adherence to DOT regulations is sufficient for that carrier).

• Communities that are transporting batteries for recycling purposes (rather than disposal) are not subject to Resource Conservation and Recovery Act (RCRA) requirements at 40 CFR 62-266.

Packaging Lead-Acid Batteries for Transport

Below are general guidelines for packaging spent batteries for transport by air, land, and sea. Except where otherwise indicated, the packaging requirements for all three modes of transport are the same. There are two main ways that batteries are packaged for transport in Alaska--either on wooden pallets or in plastic fish totes.

Use of Wooden Pallets

• Stack batteries upright, pole side out, on a wooden pallet. One laver should contain approximately 24 batteries. (See diagram in Attachment A).
  
• Place honeycomb cardboard on top of the first layer, and form a second later of batteries over the cardboard. No more then three vertical layers of batteries should be stacked on a single pallet.
  
• Wrap the package several times with shrink wrap.
  
• Secure the three lavers of batteries to the pallet with two vertical straps of noncorrosive banding material (use one-half inch 300-pound break strength polypropylene straps).

Use of Fish Totes for Packaging Batteries

In Alaska, many communities use fish totes for transporting spent lead acid batteries. If packaged according to DOT requirements, the use of fish totes appears to be acceptable.

• Stack batteries upright (approximately 18-24 per layer) in the tote, cover the first layer with honeycomb cardboard, and place the second layer on top. Cover the second layer with cardboard as well.

  NOTE: While there are some advantages to using totes (they are easy to obtain and provide containment for leaking batteries), there are some potential drawbacks:
  

  • Totes may crack in cold weather conditions (polyethylene is preferable to PVC);
    
  • When filled with batteries, totes are extremely heavy and therefore difficult to manipulate with a fork lift, which increases the possibility that they might crack during transport and handling.
    
  • It can be difficult and expensive to establish a system whereby the totes are returned to the sender.

Marking, Labeling, and Placarding Requirements

Marking

Marking of packages is generally the responsibility of the person or community that is initiating the shipment. All battery packages must be marked with the following information (this may be completed by hand);

• the proper shipping name, i.e. "Batteries, wet, filled with acid";
  
• the identification number "UN 2794"; and
  
• either the consignee's or the consignor's name and address.

Labeling

In addition, all packages must be labeled with a "CORROSIVE" sticker. (See example of marking and labeling sticker in Attachment B.) As these stickers must conform with DOT specifications and measurements, communities might wish to order them. Labels can be ordered from safety/compliance catalogues, carriers, or recyclers.

Placarding

When batteries are transported by vessel, the shipping container and vessel must be placarded with "CORROSIVE" placards (as pictured in Attachment B).

• Placarding is generally not required for transport by air; trucks must be placarded only if the shipment is more than 1,000 pounds. (Note: A typical pallet containing approximately 72 batterys may weigh between 2,500 and 3,000 pounds.)
  
• If placarding is required, this is usually the responsibility of the transportation carrier.

Shipping Papers

Required Elements

When transporting batteries, the person or community offering the batteries must provide certain information in writing. This is also known as a "bill of lading" (Attachment C contains three examples of shipping papers). Communities may purchase official forms or the required information simply may be recorded on a piece of paper, including:

• Name of shipper.
  
• Contents of package.
  
• Description of hazardous material, including:
  
  • the proper shipping name, "Batteries, wet, filled with acid";
    
  • the specified hazard class, "8";
    
  • the identification number, "UN 2794";
    
  • the packing group, "PG III";
    
• Shipper's certification.

Considerations for Transport by Air

• DOT regulations establish weight limits for the transport of batteries on passenger air carriers (25 kg. gross per package). 25 kg. is equivalent to approximately one battery contained in its own wooden or plastic box. There is no limit to the number of individual packages that may be transported per flight.

• Federal Aviation Administration (FAA) representatives in both Alaska and Washington state have indicated that when transporting spent lead acid batteries by air, the shipper may decide to classified the batteries according to an alternate classification under the hazardous materials table at 49 CFR 172.101 (Environmentally hazardous substances, solid, not otherwise specified; rather than "Batteries, wet, filled with acid.").
  • Under this alternate classification, the packaging and labeling requirements are less stringent.
    
  • Communities interested in transporting spent lead acid batteries by air should contact various air carriers to verify their classification of lead acid batteries under the DOT regulations.

Considerations for Transporting Damaged Spent Batteries

• A used lead-acid battery is considered damaged if there is a possibility it could leak due to a crack or if it is missing one or two caps. Cracks often may occur if batteries are stored or transported at sub-zero temperatures.

• Many transportation companies are reluctant to ship lead acid batteries that are known to be cracked or leaking. Air carriers, in particular, may require that leaking batteries be entirely drained of acid prior to transport.

• However, if a shipper does accept leaking batteries, they must be separated from intact batteries and then sealed in a container, such as a fish tote, with soda ash to neutralize the acid. A plastic-lined 55-gallon drum also may be used.

For Your Information

General Questions

For questions about battery recycling, including a partial listing of battery collectors in Alaskan communities, please contact the DEC Pollution Prevention Office in your region.

• Southeast Regional Office, Juneau, 465-5351
  
• Southcentral Regional Office, Anchorage, 563-6529
  
• Northern Regional Office, Fairbanks, 451-2134

Questions about Transportation Regulations

• Andy Tucci, U.S. Coast Guard (Juneau), 463-2465
  
• John White, Federal Aviation Administration (Anchorage), 271-2243

Ordering Labels and Shipping Papers

Official labels and shipping papers may be ordered from safety/compliance catalogues (call Alaska DEC staff for further information) or may be obtained through battery recyclers, air carriers, shipping lines, or trucking companies.

Contact Your Local Vendor

Many vendors in Alaska will accept used batteries from their customers on a one-for-one exchange basis. Contact your vendor for more information.

The State of Alaska Department of Environmental Conservation complies with Title 11 of the Americans with Disabilities Act of 1990. This publication is available in alternative communication formats upon request. Please contact the Department at 465-5010 to make any necessary arrangements.

Additional copies of this fact sheet are available from the:

Alaska Department of Environmental Conservation
Pollution Prevention Office
3601 C Street, Suite 1334
Anchorage, Alaska 99503
907-563-6529 (phone)
907-562-4026 (fax)

This case study fact sheet is intended as guidance only. It is not intended as a substitute for any applicable state, federal, and local regulation.

ATTACHMENT: Straight Bill of Lading--Short Form--Original--Not Negotiable [refer to source document]

ATTACHMENT A: Battery Packaging Procedures (diagram) [refer to source document]

ATTACHMENT B: Example of "CORROSIVE" marking and labeling sticker [refer to source document]

ATTACHMENT C1 (3 pages): Example of shipping papers -- Straight Bill of Lading--Short Form [refer to source document]

ATTACHMENT C2: Example of shipping papers [refer to source document]

ATTACHMENT C3: Example of shipping papers -- Shipper's Declaration for Dangerous Goods [refer to source document]