home.gif search3.gif vendbutton.GIF sheets.gif listervsbutton.gif compicon2.gif

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


New Message Reply About this list Date view Thread view Subject view Author view

From: Jeff Adrian (jeffadrian@johnroberts.com)
Date:23 Jan 2002 10:25:12


There are two possible items in question regarding lead acid batteries: the lead content and the sulfuric acid content. Taking them one at a time:

 The lead issue falls under the exemption for an "item" under the PBT reporting rule. The operative descriptor for lead to fall under the "item" exemption is that the lead is not in any way modified, reshaped, melted or reformed from its original shape. 

The sulfuric acid issue is definitely a reportable item under SARA 302, 311 and 312 because sulfuric acid (battery electrolyte) is classified as an Extremely Hazardous Substance with a 1000 pound reporting threshold. 

As a practical matter, the 1000 pound threshold is very easy to reach with just a few power hand trucks or forklifts.



New Message Reply About this list Date view Thread view Subject view Author view