From: Curt Schmidt (Curt.C.Schmidt@westgroup.com)
Date: Mon, 21 Jan 2002 13:44:41
Does anyone have an opinion regarding the possible reporting of "forklift-type" lead acid batteries under SARA 311/312 (500 LB sulfuric acid threshold)?
There has been some recent EPA activity involving several telecom firms that have begun reporting of UPS (Data Center) lead acid batteries under SARA 311/312. But I've seen no guidance or info regarding equipment such as forklifts, lift trucks, walkers, etc. that also use lead acid batteries. Even pickups, lawn equipment, etc. etc. since they may be stored inside the facility. And what about such batteries that are onsite but not in use (being stored or charged, etc.)?
Does anyone have any thoughts or history on this? Per EPA guidance reporting is required if an MSDS is required under OSHA HazCom. My gut tells me that "sealed" batteries might not need an MSDS due to the OSHA "Article Exemption" (no exposure or release under normal conditions of use); but unsealed batteries would (exposure could occur when adding water or acid). So a large plant or warehouse with lots of this type of equipment (containing unsealed batteries) could hit the 500 LB sulfuric acid threshold.