Reporting guidance: Lead Acid Batteries

Tier 2 Reporting of Lead-Acid Batteries

At Watkins Group, LLC, we help businesses stay compliant with Tier 2 reporting requirements, especially when handling lead-acid batteries, which are considered hazardous due to their chemical components. Lead-acid batteries contain sulfuric acid, an Extremely Hazardous Substance (EHS), and other hazardous chemicals such as lead, lead oxide, and lead sulfate. The Safety Data Sheet (SDS) for the batteries should provide the weight and chemical composition needed for reporting.

Do I Need to Report Lead-Acid Batteries?

If your facility uses lead-acid batteries, here are the reporting thresholds:

• Sulfuric Acid: If the total amount of sulfuric acid on-site exceeds 500 pounds, it must be reported as an EHS.

• Lead-Acid Batteries: If the total weight of the lead-acid batteries exceeds 10,000 pounds, they must be reported.

How to Report Lead-Acid Batteries

When Only Sulfuric Acid is Reportable:

• If sulfuric acid is present in both pure and mixture forms (like in lead-acid batteries) and the total exceeds 500 pounds, you can:

  • Report sulfuric acid as a separate chemical in the Tier 2 Report, aggregating all forms at the facility.

  • OR, if sulfuric acid is only found in lead-acid batteries, report the batteries as the chemical, with sulfuric acid listed as an EHS mixture component.

When Both Sulfuric Acid and Lead-Acid Batteries are Reportable:

• If sulfuric acid is present in the batteries and other forms, it should be reported separately in the Tier 2 Report, and the lead-acid batteries should be listed as a chemical with sulfuric acid as a component of the mixture.

Reporting Examples

Example 1:

Your facility has 100 lead-acid batteries weighing 55 pounds each (total 5,500 pounds) with no other sulfuric acid sources.

• Sulfuric Acid: The weight of sulfuric acid in the batteries is:

  • 5,500 pounds x 22% (from the SDS) = 1,210 pounds.

  • This exceeds the 500-pound threshold, so you must report 1,210 pounds of sulfuric acid.

• Lead-Acid Batteries: Since the total weight of the batteries does not exceed 10,000 pounds, the batteries themselves are not reportable.

In this case, you can either:

1. Report sulfuric acid as an EHS chemical, or

2. Report the lead-acid batteries, listing sulfuric acid as a component of the mixture.

Example 2:

Your facility has 210 lead-acid batteries, each weighing 55 pounds (total 11,500 pounds), and stores 150 pounds of pure sulfuric acid.

• Sulfuric Acid: The total sulfuric acid weight is:

  • Batteries: 11,500 pounds x 22% = 2,530 pounds.

  • Pure sulfuric acid: 150 pounds.

  • Total sulfuric acid = 2,680 pounds, which exceeds the 500-pound threshold.

• Lead-Acid Batteries: The total weight of the batteries exceeds 10,000 pounds, so the batteries must also be reported.

In this case, both sulfuric acid and lead-acid batteries should be reported.

Contact Us for Expert Assistance

Need help navigating Tier 2 reporting for lead-acid batteries? Watkins Group, LLC specializes in providing tailored solutions to ensure your business remains fully compliant with environmental regulations. Contact us today for guidance on reporting and maintaining compliance.