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printreg, January, 2002
Re: Forklift Type Batteries and SARA 312


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From: Robert Fricke (rafricke@esmillennium.com)
Date: Tue, 22 Jan 2002 10:18:34


Lead-acid batteries for UPSs are reportable under Tier Two. Forklift batteries would also be reportable if the accumulated quantity of acid (not including the weight of the battery case) is over 500 lbs. At about 10.5 lbs/gal, that's not a lot of acid. 

Even sealed batteries should have an MSDS. Although exposure during normal use may be near nonexistent for users, foreseeable exposure can occur from installing and replacing or accidental leakage which is covered under the policy definition of “normal use” by OSHA. I would think a supplier would be remiss to not have an MSDS available or claim the article exemption.



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