From: Curt Schmidt (Curt.C.Schmidt@westgroup.com)
Date: Thu, 9 May 2002 12:09:25
I believe that you can ignore the lead and the sulfuric acid in forklift batteries entirely from SARA 313. Check out page B-22 of (in Appendix B) of this EPA Guidance Document: http://www.epa.gov/triinter/guide_docs/2001/lead_doc.pdf where it says:
Motor Vehicle Exemptions: The use of "products containing toxic chemicals for the purpose of maintaining vehicles operated by the facility" is exempt from threshold determinations and release and other waste management reporting under Section 313. This exemption includes toxic chemicals found in gasoline, diesel fuel, brake and transmission fluids, oils and lubricants, antifreeze, batteries, cleaning solutions, and solvents in paint used for touch up, as long as the products are used to maintain the vehicle operated by the facility. Motor vehicles include cars, trucks, some cranes, forklifts, locomotive engines, and aircraft.
Although power dollies are not specifically mentioned, I would think they're close enough to being a forklift to include. My thoughts only.