May 17, 2021

Lithium or Not, Recycle Your Batteries

One reason for the growing number of fires in the waste management industry is improper battery management. In response, EPA recently uploaded three new webpages on battery handling: Used Household Batteries, Used Lithium-ion Batteries, and FAQs on Lithium-ion Batteries. With few exceptions, batteries should not be placed in the trash, whether at a facility or residence. Instead, batteries should be managed through recycling programs. Additionally, many batteries contain critical minerals that are economically and strategically important to the United States. Recycling batteries allows these materials to be available for future generations.

Many batteries contain RCRA toxic metals or may be reactive; thus, when discarded, they become hazardous waste. These include, but are not limited to, lithium-metal batteries, lead-acid batteries, and nickel-cadmium batteries. Whether ultimately sent for disposal or recycling, probably the best way to manage hazardous batteries is via the universal waste program in Part 273.

Lithium batteries, in particular, have been known to catch fire and cause catastrophic accidents during storage and transportation. Used batteries containing lithium should 1) have their terminals taped or be individually placed in their own plastic bag, 2) be stored at room temperature and not be exposed to long periods of hot or cold temperatures, and 3) be recycled rather than disposed in a landfill. There are no regulations in RCRA specifically pertaining to lithium batteries. However, DOT’s hazardous material transportation regulations do contain special shipment requirements. DOT provides additional resources for transporting lithium batteries, and the shipping/packaging instructions for these batteries can be found in 49 CFR 173.185.

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Disclaimer

Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.

This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.