HIDDEN DANGERS OF END-OF-LIFE BATTERIES AND THE REGULATIONS YOU CAN'T IGNORE
Jennifer McCrohan, Managing Consultant — Seattle, WA
rechargeable lithium batteries. Each battery chemistry carries unique hazards and a distinct regulatory landscape. An additional challenge is posed by the fact that regulations governing the management of waste batteries were developed over 40 years ago - long before the development of many of the batteries that are in use today. As such, the United States (US) Environmental Protection Agency (EPA) and generators of waste batteries must think critically about how the RCRA regulations apply to new chemistries that may pose hazards and challenges different from batteries in use when the regulations were initially promulgated. Alkaline Batteries Alkaline batteries are commonly used for household and office devices and are available in a wide range of sizes, including AAA, AA, C, D, and 9 Volt. Typically, alkaline batteries are not rechargeable and must be disposed of once “dead”. Alkaline batteries historically contained mercury, but modern alkaline batteries are mercury-free in accordance with the Mercury- Containing and Rechargeable Battery Management Act of 1996. Today most alkaline batteries consist of a zinc anode, a manganese-based cathode, and a separator soaked in an alkaline electrolyte. Dry cell alkaline batteries do not meet the criteria for D002 (corrosive)
Batteries are one of the most ubiquitous waste streams across all industrial, commercial, and office facilities. As our workplaces have evolved to depend on electronics, consumer devices, and even electric vehicles and forklifts, new types of batteries and their associated hazards and environmental compliance requirements have been introduced. This article outlines common battery types and associated regulatory requirements under the federal Resource Conservation and Recovery Act (RCRA), including generator waste management methods, relevant regulatory requirements, and risks and challenges associated with managing end-of-life batteries. Generators of waste batteries must also assess state-specific waste requirements and other environmental obligations to ensure compliance with all applicable regulations. This article also discusses news and hot topics in the world of end-of-life battery management. Introduction to Common Battery Types There are many different types of batteries in use today in the myriad of electronics that have become essential to daily life. Common categories of battery chemistries include non-rechargeable alkaline batteries, lead-acid batteries, and rechargeable and non-
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