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Update on Battery Regulations: DOT Rule Changes and Compliance Issues

A recent update regarding the Department of Transportation (DOT) highlights significant changes to battery regulations under Special Provision 130. This provision mandates insulating all batteries to prevent short circuits, with no distinction made between spent and new batteries. The rules now permit common household batteries, including rechargeable types, to be shipped together if properly insulated. Additionally, recent DOT inspections revealed compliance issues at battery recycling facilities, emphasizing the need for strict adherence to these regulations to ensure safe shipping and recycling practices.

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Update on Battery Regulations: DOT Rule Changes and Compliance Issues

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  1. Update on Batteries Bill Pollock; Alameda County HHW program bill.pollock@acgov.org

  2. A few Flaming UPS trucks pique DOT’s Interest in battery recycling

  3. DOT Rule Change • Special Provision 130 Published in the Federal Register (Jan 14th HM215J & HM 224D) • Requires insulating all batteries to prevent short circuit • Makes no distinction between spent batteries and new batteries–does not exclude alkalines • Uniquely it regulates batteries when shipped as Universal waste

  4. DOT April 3rd 2009 letter focuses specifically on spent batteries and details DOT’s concerns about spent battery recycling and transportation. • The new rules do allow common household batteries including rechargeable NIMH and NICAD to be comingled and shipped on a bill of lading as long as SP130 is followed – (taping- or otherwise protected from short circuit

  5. DOT Enforcement • DOT visited Kinsbursky in LA, a destination facility for the BIG Green Box • DOT found numerous compliance issues with the way batteries are shipped in the Big Green Box • Northern California HHW program was issued written warning letter by the DOT

  6. Programs respond by Taping batteries Carefully stacking Eco Solutions has a clear acrylic pour in substance that will coat batteries and be acceptable to recyclers. Latex paint can be used for batteries destined for Haz Waste Landfill * Other chemicals may change hazard class for transport and disposal

  7. Various entities request relief from SP 130 for specific batteries through a DOT Interpretation letter Unlike Exemptions and Special Packing authorizations Interpretation immediately apply to anyone shipping these materials

  8. DOT Interpretation letters On DOT Website http://www.phmsa.dot.gov/hazmat/regs/interps • Interpretation # • 09-90 April 16th from Paul Johnson @ Kinsbursky • Spent 1.5 volt alkaline batteries of any form factor are not considered a hazard and are not subject to SP 130 insulating requirements • 09-150 August 13th From George Kerchner • Spent 6 volt C/ZN and 9 volt Alkaline batteries are not considered a hazard and are not subject to SP 130 insulating requirements. • 09-135 from Florida HHW program • 09-169 from Pennsylvania HHW transporter: • Reaffirms Kinsbursky letter with respect to 1.5 volt Alkalines

  9. DOT Interpretation letters continued • 09-112 June 23rd George Kerchner letter. • Government agencies transporting spent batteries from a collection site to a Government facility in a Government owned vehicle using a Government employee as driver is not considered “In Commerce “and not subject to the entire HMR including SP130. The collection site does not have to be Government facility – can be a store or commercial entity. *NOTE Using a Contractor to transport or contract personnel to drive a government vehicle puts the activity “In Commerce” HMR requirements and SP 130 will apply.

  10. T&D Vendor Requirements Destination Facility requirements

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