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Lead Acid batteries are used throughout industry to provide power for work vehicles and uninterrupted power supplies. For example: battery-powered fork-lifts are used in warehouses; battery-powered carts are used on golf courses; telecommunications facilities use great numbers of emergency standby battery systems to maintain service during commercial power outages; electrical utilities also use many battery systems in their power generation and distribution networks. Because of their ubiquity, reliability and low-maintenance, these battery systems are often overlooked when addressing hazardous materials in the workplace.

The typical lead-acid battery electrolyte is approximately 60% water, and 40% sulfuric acid (CAS 7664-93-9); and traces of lead. Analysis of electrolyte from a new battery may contain less that 1 mg/L of lead in solution. An old, well worn battery can contain electrolyte with lead as high as 70 mg/L. Of course, lead sulfate can form as a sludge in the bottom of the battery jar.


Sulfuric acid is the highest volume chemical produced in the world. It is used in more chemical reactions and industrial processes than any other chemical

Sulfuric acid is not flammable by itself, but it can cause and support a fire by reacting with other chemicals and liberating enough heat to ignite ordinary combustibles. Sulfuric acid can also support a fire by releasing oxygen from the sulfate ion and therefore feed oxygen to the flames. The sulfuric acid will dissolve many metals, releasing hydrogen which is extremely flammable. Heat generated during this chemical reaction can ignite the hydrogen, creating an explosive environment.

Sulfuric acid is extremely dangerous when it contacts oxidizers and organic materials. This acid, in high concentrations, is also a major hazard to human life. When sulfuric acid comes in contact with flesh, it withdraws water, leaving a black charred carbon residue, in the place of living tissue. The higher the concentration, the greater the danger. If sulfuric acid comes in contact with large areas of human tissue, death can occur. If acid fumes are inhaled, serious lung and bronchial damage can occur.

Here is a quote from the NFPA fire investigation report of the Los Angeles Grand Telephone Exchange fire of March 15, 1994:

      "One of the threats was sulfuric acid (28 percent solution, similar to a car battery) that had been released from damaged batteries. The batteries were not in diked areas so the leaking acid formed pools covering the floor near the batteries. Since typical protective gear for structural fire fighters is not effective against acids, injury could have resulted had fire fighters been crawling as they approached the fire or slipped and fallen while walking through the acid pool."


Health 3
Flammability: 0
Reactivity 1
Special Properties Corrosive
Special Properties Water Reactive

Sulfuric Acid Classification by Fire Departments
(12.7 to 50% concentration)

The 1994 UFC classifies sulfuric acid hazards as:

  • Oxidizer Class 1 (Appendix VI-A
  • Water Reactive Class 1 (Appendix VI-A 2.1.9)
  • Corrosive (Appendix VI-A
  • Other Target Organ or System (216) (Appendix VI-A (MSDS)
  • Toxic (221-3) (MSDS)
  • The UFC use classification for the two major types of lead-acid batteries are:
  • Wet (Flooded) - Use, Open System (Section 222)
  • Valve Regulated (VRLA) - Use, Closed System (Section 222)

So by combining the UFC sulfuric acid hazard classifications and the Open and Closed System Use, we can approach the maximum exempt gallons per control area from several directions:





100 Gallons

400 Gallons

Water Reactive

2.5 Gallons

12.5 Gallons


100 Gallons

500 Gallons

Other Health

100 Gallons

500 Gallons


12.5 Gallons

50 Gallons

Maximum Sulfuric Acid Exempt Gallons per Control Area without Sprinklers
(Table 8001.13 A&B)


The 1994 UFC treats battery rooms as any other hazardous materials storage situation. For example, Article 80 states:

      8001.13.1 General. Exempt amounts shall be as specified in Section 8001.13.2 and Tables 8001.13-A through 8001.13-D. Storage, dispensing, use and handling of hazardous materials in quantities exceeding exempt amounts shall be in accordance with Sections 8001, 8003 and 8004.

      Storage, dispensing, use and handling of hazardous materials in quantities not exceeding exempt amounts shall be in accordance with Section 8001.

      8004.2.2.5 Spill control, drainage control and secondary containment. Rooms or areas where hazardous material liquids are dispensed into containers exceeding a 1-gallon (3.785 L) capacity or used in open containers or systems exceeding a 5-gallon (18.93 L) capacity shall be provided with spill control. Secondary containment shall be provided when the capacity of an individual container exceeds 55 gallons (208.2 L) or the aggregate capacity of multiple containers exceeds 100 gallons (378.5 L).

      8004.1.4 Spill control, drainage control and secondary containment. When required by other provisions of Section 8004, spill control, drainage control and secondary containment shall be provided in accordance with Section 8003.1.7.

      8003.1.7 Spill control, drainage control and secondary containment.

      8003.1.7.1 General. Rooms, buildings or areas used for the storage of solid and liquid hazardous materials shall be provided with a means to control spillage and to contain or drain off spillage and fire-protection water discharged in the storage area in accordance with Section 8003.1.7.

      8003.1.7.2 Spill control. Floors shall be sloped; constructed with sumps and collection systems; recessed a minimum of 4 inches (101.6 mm); provided with a liquid-tight raised sill to a minimum height of 4-inches (101.6 mm) to prevent the flow of liquids to adjoining areas; or otherwise constructed to contain a spill from the largest single container or tank. Except for surfacing, the sill shall be constructed of noncombustible material, and the liquid-tight seal shall be compatible with the material stored. When liquid-tight sills are provided, they are not required at door openings which are provided with and open-grate trench that connects to an approved drainage system.

Other limitations that seem to affect the placement of large stationary battery systems:

      Appendix VI-D Table 5B Basic allowable building heights and basic allowable floor area for buildings one story in height. This table limits the placement of flooded batteries to not over the third floor.

      Article II - Definitions and Abbreviations, Section 204-C. Control Area is a building or portion of a building within which the exempted amounts of hazardous materials are allowed to be stored, dispensed or handled.

      8001.8.2.1 Construction Requirements. Control areas shall be separated from each other by not less than a one-hour fire-resistive occupancy separation.

      8001.8.2.2. Number. The number of control areas in buildings or portions of buildings used for retail or wholesale sales shall not exceed two. The number of control areas in buildings with other uses shall not exceed four.

      102.1 Existing Conditions. The provisions of this code shall apply to conditions arising after the adoption thereof, conditions not legally in existence at the adoption of this code, and to conditions which, in the opinion of the chief, constitute a distinct hazard to life or property. See also Appendices I-A and I-B.

      103.1.2 Alternate materials and methods. The chief, on notice to the building official, is authorized to approve alternate materials or methods, provided that the chief finds that the proposed design, use or operation satisfactorily complies with the intent of this code and that the material, method of work performed or operation is, for the purpose intended, at least equivalent to that prescribed in this code in quality, strength, effectiveness, fire resistance, durability and safety. Approvals under the authority herein contained shall be subject to the approval of the building official whenever the alternate material or method involves matters regulated by the Building Code.

Article 80 places a heavy burden on facilities with lead-acid battery systems. Since these systems were not directly addressed by article 80, and treated as any other hazardous materials situation, a new section was produced to provide a common-sense approach to compliance for these stationary battery plants.

Enter Article 64

The Appendix to the 1995 Supplement to the UFC, Analysis of the Revisions for Article 64, states:

      "Requirements for the safe installation and operation of stationary lead-acid battery systems are not contained in the code. There are currently thousands of such systems in the field which have an excellent safety record over many years. A growing number of authorities are applying the requirements of Section 8003, to these installations because there is no other guidance provided by the code. However, these systems present unique hazards which are not adequately addressed by the existing provisions of Article 80. The proposal contains specific and enforceable requirements for these installations which address comments received from IFCI members and staff. The referenced standards contain detailed requirements for all phases of stationary lead-acid battery installations."


      Article 64 applies to stationary lead-acid battery systems that have a total or aggregate liquid capacity of more than 100 gallons (378.5 L) in buildings with fire suppression sprinklers ( 50 gallons (189.3 L) in non-sprinkler buildings) and are used for facility standby power, emergency power or uninterrupted power supplies. (6401.1.)

      Each rack of batteries, or group of racks, shall be provided with a liquid-tight, 4-inch (101.6 mm) spill-control barrier which extends at least 1-inch (25.4 mm) beyond the battery rack in all directions. (6404.4.)

      An approved method to neutralize spilled electrolyte shall be provided. The method shall be capable of neutralizing a spill from the largest lead-acid battery to a pH between 7.0 and 9.0. (6404.5.)

The appendix to the supplement contains an analysis of the revisions to Article 64.  It clarifies that this article applies to all battery types, including gel-cells or VRLAs.  The code writers used the definition of "lead-acid battery" to include all "electro-chemical cells interconnected to supply a nominal voltage of DC power."

The analysis goes on to explain that the revision lowers the threshold rate from 100 gallons to 50 gallons to allow more facilities to use Article 64 instead of Article 80.  It also eliminates the requirement to comply with Article 80 if any battery contains over 20 gallons of electrolyte.


Implementation of the UFC Article 64 offers a facility a way of compliance not only with the fire code, but also with the intent of Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) requirements. The potential for harm to people, equipment and the environment can be decreased without much effort or resources. It appears that this is a good idea who’s time has come.


Fire Investigation Report, Telephone Exchange Fire, Los Angeles, California, March 15, 1994, Prepared by Michael S. Isner, Fire Protection Engineer, National Fire Protection Association.

Uniform Fire Code, published by the International Fire Code Institute. Copyright by the International Conference of Building Officials and the Western Fire Chiefs Association.

1995 Supplement to the Uniform Fire Code, published by the International Fire Code Institute. Copyright by the International Conference of Building Officials and the Western Fire Chiefs Association.

The full text of the Uniform Fire Code is available from:
          The International Fire Code Institute
          5360 Workman Mill Road
          Whittier, CA 90601-2298
          phone: 310-699-8031.

Note: Supplements are excerpts and not word-for-word.

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