Tier II Reporting of Lead Acid Batteries

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The Emergency Planning and Community Right-to-Know Act (EPCRA) is using its teeth. In 2018, the U.S. Environmental Protection Agency (EPA) assessed $250,000 in fines to businesses for failing to submit reports. The purpose of the act is to empower communities planning for chemical emergencies. This Tier II reporting submits details of a company’s hazardous chemical inventory online.

What Qualifies You for Tier II Reporting?

We have an interest in this, as battery makers because batteries contain hazardous chemicals. The triggers are having a hazardous chemical in a quantity exceeding a threshold at least once a year. However, there is no given definition of what constitutes a hazardous chemical in terms of Tier II reporting.

Hazard Symbols and Their Meanings

Thus EHS Daily Advisor suggests any chemical classified as a physical hazard, or a health hazard meets the bill. This could for example be a simple asphyxiate, combustible dust, pyrophoric gas, or a hazard not otherwise classified. Rather use the chemical data sheet as a guide it says. Most US states allow online reporting which simplifies the process.

Where Do Lead-Acid Batteries Belong in This?

The U.S. Environmental Protection Agency has provided specific Tier II guidance for lead-acid batteries. In terms of this. those intended for consumer use are exempt. However, non-consumer ones, e.g. in forklifts are not.

In the latter case, the system treats them as ‘mixtures’ of lead and sulfuric acid, with the latter also a mixture. Sulfuric acid classifies as an ‘extremely hazardous substance’ with a Tier II reporting threshold of 500 pounds weight. While anything less than 10,000 pounds of lead need not go into the report.

If you can purchase the battery at an auto parts store it is generally not eligible for Tier II reporting. Failing that, EHS Daily Advisor suggests it is ineligible for exemption and you have to report it.


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I tripped over a shrinking bank balance and fell into the writing gig unintentionally. This was after I escaped the corporate world and searched in vain for ways to become rich on the internet by doing nothing. Despite the fact that writing is no recipe for wealth, I rather enjoy it. I will not deny I am obsessed with it when I have the time. My base is Umtentweni in South Africa on the Kwazulu-Natal South Coast. I work from home where I ponder on the future of the planet, and what lies beyond in the great hereafter. Sometimes I step out of my computer into the silent riverine forests, and empty golden beaches for which the area is renowned. Richard Farrell

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