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Managing used batteries.
Most used batteries exhibit one or more hazardous characteristics [Part 261, Subpart C] and would be hazardous waste if disposed of. Under the federal hazardous waste regulations, three options are provided for managing hazardous used batteries. Most of us are familiar with two of them.
First, they may be managed as hazardous waste, which is the least preferable option. Second, they may be managed as universal waste under the Part 273 regulations. The universal waste program makes it easy to collect and manage batteries outside of full RCRA regulation. In addition, EPA allows management of nonhazardous batteries (e.g., alkaline batteries) as universal waste to promote their recycling.
But did you know that for lead acid batteries, a third option is provided? Before the universal waste program was created, EPA knew lead acid batteries merited a special program to make it easy to recycle them. So they added the Part 266, Subpart G regulations for reclaiming lead acid batteries. The requirements are very simple, and we have been told that this program is often preferable if you generate a lot of used lead acid batteries. That said, if you generate only a few, it’s probably easier to manage all of them as universal waste. For more compliance morsels, visit our website.
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