This advisory recommends ways LEPCs and owner/operators of facilities can minimize risks posed by the presence of lead-acid batteries in their communities. Due to the lead-acid battery’s unique electrochemical and chemical characteristics, the substantial quantities presence in many facilities, and the community’s general unawareness to the presence of lead-acid batteries and of their associated hazards, this advisory is being issued.

Acute effects of overexposure to lead and lead compounds are gastrointestinal upset which may be loss of appetite, diarrhea and/or constipation with cramping, difficulty in sleeping, and fatigue. Acute effects of exposure and /or contact with battery electrolyte (sulfuric acid) may lead to acute irritation of the skin, corneal damage of the eyes if not washed immediately, and irritation of the mucous membranes of the eyes and upper respiratory system including the lungs. Chronic effects to lead and its compounds may cause chronic anemia, damage to the kidneys and nervous system. Lead may also cause reproductive system damage and can affect developing fetuses in pregnant women. Chronic effects of sulfuric acid may lead to scarring of the cornea and chronic bronchitis as well as erosion of tooth enamel in mouth breathers. Sulfuric acid mist, which may be present in normal and abnormal battery system operation has been classified as a International Agency for Research on Cancer (IARC) Category 1 carcinogen, a substance that is carcinogenic to humans.

Sulfuric acid (CAS-7664-93-9) is listed by EPA as an extremely hazardous substance (EHS) under Section 302 of EPCRA (commonly known as SARA Title III). In addition OSHA regulations require that facility employees who could potentially be exposed to lead-acid hazards in any form be trained in the safe use and potential hazards posed by the chemicals.

EPA stresses that although mishandling and abnormal operation of lead-acid batteries can cause harm, there is no cause for undue alarm about its presence in the community. With the exception of the possible generation of hydrogen gas under normal conditions of battery use, internal hazardous components will not present a safety or health hazard. Lead-acid batteries are typically handled safely and without incident. Lead-acid batteries in buildings are typically used in reserve electrical energy applications for use when normal power sources, such as the electric utility, are not available. An exception to this generalization would be its use in electric forklift truck and cart applications in factories and warehouses.

RECOMMENDED STEPS FOR LEPCs

Section 302 of EPCRA requires LEPCs to develop comprehensive emergency plans to address facilities where sulfuric acid as well as other EHSs and hazardous materials are present in excess of their threshold planning quantities (1,000 pounds for sulfuric acid). Because sulfuric acid is widely used in large quantities in lead-acid batteries and poses unique and significant health and safety hazards, EPA suggests that LEPCs take the following steps:

Hazards Identification

Know where substantial quantities of lead-acid batteries can be found. Facilities that routinely use lead-acid batteries include:

1. Telephone Central Offices (Group B Occupancy)

2. Telecommunications equipment outdoor Huts/Shelters, Vaults, and Cabinets..

3. Telecommunications equipment including wireless pcs and cellular installations in public assembly (Group A) and hotel and apartment (Group R) occupancy buildings

4. Business Communications and Data Centers (Group B Occupancy)

5. Hospitals and Health Care Centers (Group I Occupancy)

6. Electric Generation, Transmission, and Distribution including substations

7. Factory and Warehouse forklift trucks and reserve energy backup systems

8. Petroleum refineries and natural gas plants including pipelines

9. General Office and High-rise Buildings.

10. Send a copy of this advisory to all such facilities in your LEPC jurisdiction, calling their attention to the recommended steps for facilities in the section below.

11. Be familiar with other names for "lead-acid batteries" Names used to describe lead-acid batteries include:

    • Storage cell/battery

    • Wet cell/battery

    • Gel cell/battery

    • Starved electrolyte cell/battery

    • Absorbed electrolyte cell/battery

    • Flooded cell/battery

    • Sealed cell/battery

    • Valve Regulated Lead-Acid (VRLA or VR) cell/battery

    • Maintenance Free cell/battery

    • Recombination or Recombinant cell/battery

    • Rechargeable cell/battery

12. Ensure that the facilities covered by Section 302, 311, and 312 of EPCRA have provided to the LEPC and local fire departments adequate information about smaller quantities of lead-acid batteries as well. (Not all facilities using or storing lead-acid batteries will meet the reporting thresholds). The LEPC can request MSDSs for lead-acid batteries present at a facility in amounts below the threshold.

Emergency Planning

1. Engage in a dialogue with facilities about possibilities for reducing the amount of lead-acid batteries in their inventories while providing for adequate spill containment and spill management for the lead-acid batteries that remain in the facility.

2. Regularly exercise and review EPCRA plans to ensure that facilities using and storing lead-acid batteries are covered, and that emergency response issues concerning possible releases of lead-acid battery extremely hazardous substance and hazardous materials have been addressed.

3. Ensure that local hospitals and physicians are properly trained and prepared to treat victims of exposure to the lead-acid battery hazards.

4. Ask facility officials for copies of their emergency response plans so the LEPC and fire departments can use them to prepare pre-incident plans and ensure that facility and community plans are coordinated.

Risk Communication

1. Inform the community of the hazard, as well as methods for treating victims of exposure to the lead-acid batteries. Exposure to the community will, in all likelihood, be due to a fire directly or indirectly related to a battery fire. Once started, battery fires do not require any external source of fuel, heat, or oxidizer to continue its own exothermic consumption of itself.

2. Inform users and handlers of lead-acid batteries of the hazards related to these batteries and the need for safe use and storage. For example, valve regulated battery systems may exhibit thermal runaway under certain high temperature conditions. The amount of potential energy stored in batteries is often overlooked when considering the consequences of battery abnormal condition operation.

STEPS FOR FACILITIES

In cooperation with LEPC’s and local response officials, facilities should take the following steps:

Storage and Use

1. Refer to and conform to all applicable requirements and safety practices including:

2. ANSI/IEEE Standard 484, 937, and 1187

3. OSHA 29 CFR 1910.38, 120, 120C, 178, 268, 1200 and 1926.441

4. Applicable OSHA Interpretations

5. EPA 40 CFR 265, 300, 302, 350, 355, 370, and 372

6. Authority having jurisdiction building code

7. Authority having jurisdiction fire code

8. Reasonable and prudent safety and health practices

Employee Safety

1. Ensure that adequate training is provided to all facility employees concerning the safe handling, storage, and use of lead-acid battery systems.

2. Ensure that the proper protective equipment is easily accessible in case of a release. Train employees in the proper use of equipment.

3. Ensure adequate sulfuric acid compatible spill containment is provided with a passive means to reduce acid exposure risk through passive absorption and neutralization per 29 CFR 1910.120 Appendix C.

Hazard Awareness

1. Do NOT dilute acid with water since acid is classified as water reactive.

2. Do NOT apply bulk neutralizers directly to an acid pool since reaction can be violent.

3. Do NOT absorb acid with an organic absorbent material since exothermic reaction may ignite organic material.

4. Do NOT flush acid to sewer or directly to the environment since this is a hazardous release to the environment and may be dangerous due to exothermic reactions.

5. Do NOT flush neutralized acid to sewer or directly to the environment since neutralized battery electrolyte contains lead and lead compounds.

6. Do NOT vigorously sweep or blow battery materials since airborne materials are a health hazard and may contact the eyes or be inhaled

7. Do NOT consider a lead-acid battery as only a chemical hazard. The electrochemical characteristic hazards far exceed the traditionally thought of chemical hazards.

Risk Minimization

1. Make provisions to ensure control of hydrogen gas generation and ventilation as required.

2. Provide spill management system with integral passive absorption and acid neutralization risk reduction.

3. Post adequate warnings of battery system explosion, chemical, and electrical hazards.

4. Restrict access to battery plants to those authorized, trained, and protected with proper personnel protective equipment and safeguards.

Emergency Notification

In the event of a release, contact the National Response Center (1-800-424-8802), your SERC and LEPC, and the local fire department. When contacting these organizations, provide the following:

1. Identification of release origin being from lead-acid batteries containing sulfuric acid, lead, lead dioxide, and lead sulfate.

2. Identification of type of release and whether it is in the form of a spill only or if the release is also into the atmosphere due to a battery fire.

3. Estimated quantity of released hazardous materials.

4. Time and duration of the release.

5. Affected media.

6. List of potential health risks.

7. Name and telephone number of a contact person at the facility.

For more information, contact your EPA Regional Office or the EPCRA Hotline at (1-800-535-0202).

Robert L. Taylor, President
Morning Star Industries, Incorporated
Power Systems Solutions Division

304 Lake Terrace
Rockwall, Texas 75087
Tel: 972-618-9630   Fax: 469-757-0844
Email: msi@msi.nu