Lead-acid batteries are essential in many industries, powering everything from forklifts to backup power systems. However, these batteries contain hazardous chemicals like lead and sulfuric acid, which are subject to Tier II reporting requirements under the Emergency Planning and Community Right-to-Know Act (EPCRA). If stored in significant quantities, businesses are required to report lead-acid batteries as part of their hazardous chemical inventory.
Under EPCRA Sections 311-312, facilities must report hazardous chemicals that exceed specified thresholds. For lead-acid batteries, this typically depends on the quantities of the battery's components, such as lead and sulfuric acid.
Extremely Hazardous Substances (EHS): The threshold for reporting chemicals classified as EHS, such as sulfuric acid, is the Threshold Planning Quantity (TPQ) or 500 pounds, whichever is lower. For sulfuric acid, the TPQ is 1,000 pounds, but the lower 500-pound threshold applies.
Hazardous Chemicals Requiring a Safety Data Sheet (SDS): For chemicals like lead, which require an SDS but are not classified as EHS, the reporting threshold is 10,000 pounds.
Next Steps: If your facility stores chemicals that meet or exceed these thresholds, you must submit a Tier II report to the relevant local and state authorities, including the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC).
Navigating environmental regulations can be complex and time-consuming. At Watkins Group, LLC, we simplify compliance by offering tailored solutions for Tier II reporting, TRI reporting, stormwater permitting, SPCC plan development and more.
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ISO 14001:2015 Environmental Management System Lead Auditor
CESCO - Certified Environmental and Safety Compliance Officer (NREP)
CSRP - Certified Sustainability and Resilience Professional (NREP)
Hazardous Waste Operations and Emergency Response (HAZWOPER 40) OSHA
Occupational Safety and Health Administration
(OSHA 30 - 1910)
To determine if you need to report lead-acid batteries, you must calculate the total amount of hazardous components—primarily sulfuric acid—in the batteries stored on-site.
Step-by-Step Calculation:
Identify Battery Components: Lead-acid batteries contain lead, lead oxide, sulfuric acid, and water. For Tier II reporting, sulfuric acid is the main chemical that usually triggers the reporting requirement.
Determine Battery Weight: Let's assume each battery weighs 60 pounds and contains 44% sulfuric acid.
Calculate Sulfuric Acid Weight: Multiply the total battery weight by the percentage of sulfuric acid:
60 pounds x 0.44 = 26.4 pounds of sulfuric acid per battery.
Evaluate the Number of Batteries: If you have multiple batteries—let’s say 20 lead-acid batteries used for forklifts—calculate the total amount of sulfuric acid stored:
26.4 pounds x 20 batteries = 528 pounds of sulfuric acid.
Since the total sulfuric acid exceeds the 500-pound threshold, your facility must report sulfuric acid as an Extremely Hazardous Substance (EHS) under EPCRA.
Once your facility exceeds the reporting thresholds for hazardous chemicals in lead-acid batteries, you must take the following steps:
Prepare and Submit Tier II Reports: Submit your report to your SERC, LEPC, and local fire department annually. These reports inform emergency responders of the hazardous materials stored at your facility.
Include All Relevant Information: Your report must contain detailed information about the chemicals on-site, their hazards, storage conditions, and emergency contact details.
Watkins Group, LLC helps businesses stay compliant with Tier II reporting by calculating chemical thresholds, preparing reports, and ensuring timely submissions to the necessary authorities.
Failure to comply with Tier II reporting requirements can lead to significant penalties, including fines of up to $57,317 per day, per violation. Additionally, non-compliance can leave your facility vulnerable during emergency situations, as first responders rely on accurate chemical inventory data to ensure proper safety measures are in place.
Navigating Tier II reporting for lead-acid batteries can be complex, but Watkins Group, LLC is here to help. Our services include:
Chemical Inventory Audits: We review your chemical inventory to determine whether your facility meets reporting thresholds.
Threshold Calculations: We handle all calculations for components like sulfuric acid to ensure accurate reporting.
Tier II Report Preparation: Our team prepares and submits all required reports, ensuring compliance with EPCRA and avoiding potential fines.
Contact us today to learn how Watkins Group, LLC can simplify your chemical reporting process and keep your business compliant.