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It's Tier II Reporting Time, Do You Know Where Your Batteries Are?
Barbara Jo Ruble, CPEA, QEP, Principal and STC President, Baltimore, MD
As an EHS compliance auditor, one of the most common problems I find when reviewing Emergency Planning and Community Right to Know (EPCRA) Tier II reporting, is that facilities with large quantities of lead-acid batteries fail to report inventories of sulfuric acid and lead from those batteries on their chemical inventory reports-or for facilities in California, on their Hazardous Materials Business Plan (HMBP) reports. Most people tell me that they thought batteries were excluded or exempt from chemical inventory reporting, but they're wrong. Why? Let's look at what makes a chemical reportable under EPCRA.
40 CFR Part 370.10 says that the EPCRA Tier II reporting requirements apply to facilities that are required by the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) to have Material Safety Data Sheets (MSDS) available for a hazardous chemicals, and
- have a hazardous chemical present at any time in a quantity of 10,000 pounds or more; or
- if the hazardous chemical is an Extremely Hazardous Substance (EHS), have a quantity equal to or greater than the Threshold Planning Quantity (TPQ)for that material.
OSHA has stated that lead acid batteries are hazardous chemicals subject to the MSDS requirements of HCS, and are not eligible for the article exemption because they have the potential to leak, spill, or break during normal conditions (CPL 02-02-038, March 20, 1998). All lead acid batteries are considered hazardous chemicals, including gel cells.
Sulfuric acid is an EHS with a TPQ of 500 pounds. So, if you add up the sulfuric acid from all the lead acid batteries and other sources at your facility and the total is equal to or greater than 500 pounds, you must report sulfuric acid on your Tier II or HMBP report. Lead is also a hazardous chemical but not an EHS. Therefore, you must also add up the lead in all your batteries and other facility sources and determine if you have exceeded the 10,000 pound reporting threshold. Lead is heavy and what seems to be a small amount can quickly add up to more than 10,000 pounds. The typical fork-lift battery weighs approximately 2000 pounds and 60% to 70% of that is lead; if your facility has 8 fork-lifts, you probably have to report for lead as well. And don't forget to add in all the uninterruptable power supply (UPS) batteries in your computer/server room, the starter batteries for your generators or fire pump engines, and all the other lead-acid batteries in your building.
Do you know where your batteries are?
Barbara Jo Ruble, QEP, CPEA, and STC President, has more than 30 years of experience helping corporations to develop, assess, and improve their EHS management systems and compliance programs. She has performed more than 150 EHS compliance audits or management systems assessments of industrial facilities worldwide. Barbara has also provided independent review of corporate EHS auditing programs and has developed comprehensive EHS guidance manuals, training programs, and multi-media auditing protocols for various industrial. Her ability to put EHS issues in laymen's language and find practical solutions to complex problems helps her provide solution-oriented audit services. For more information about STC's EHS Auditing Services, contact Barbara at (410) 625-1952; email: burble@stcenv.com.
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