From: Doreen Monteleone (firstname.lastname@example.org)
Date: Thu, 9 May 2002 12:00:02
Regarding Jeff's comments...here's a follow-up from someone I've been in touch with regarding reporting (or lack of) for lead batteries. Any additional follow-up? Doreen
My member's comment... Interesting - Does he not realize that sulfuric acid is only reportable as an aerosol (under 313) and that the sulfuric acid in batteries, even if handled outside the article exemption is still not an aerosol and therefore not subject to reporting? Hydrochloric Acid is also only reportable as an aerosol under 313.
In response to Jeff's message... Incidentally, the lead in lead acid batteries (for forklifts and power dollies) is exempt under the "article provision", but one must remember to account for the electrolyte solution (sulfuric acid/water) contained in the batteries which is not exempt, assuming you have enough batteries to meet the threshold for reporting.