October 19, 2020
By:
Walter G. Wright
Category:
Arkansas Environmental, Energy, and Water Law
Arkansas Environmental, Energy, and Water Law
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Three trade associations announce the issuance of a guidance document titled:
Guide for Developing Lithium Battery Management Practices at Materials Recovery Facilities (“Guidance”)
The three trade associations include:
- Institute of Scrap Recycling Industries
- Solid Waste Association of North America
- National Waste & Recycling Association (Collectively “ISRI”)
ISRI states the purpose of the Guidance is to assist materials recovery facilities (“MRFs”) in developing appropriate practices to properly manage and dispose of lithium batteries. Included are precautions to be undertaken in case of a fire and to manage a fire if one breaks out.
Fire incidents at waste and recycling facilities are stated to be increasing. This is stated to be due to the increase in the use of lithium-ion batteries (“LIB”). Their popularity is increasing because of their decrease in cost.
The Guidance expresses concern that:
- Labeling is not standardized
- Labeling can be confusing
- Lithium batteries are appearing more frequently in wastes streams
- Batteries may unknowingly catch fire
Sections of the Guidance include:
- Contractual Language
- Key suggestions include:
- Clear language that LIB are not accepted in a residential waste or recycling
- Responsibility and ownership for batteries found during the unloading of trucks and the protocols for proper management and removal
- A material classification system for LIB found in inbound recyclables
- Responsibilities for the removal and proper recycling/disposal of LIB found in inbound recyclables (including who will bear the cost)
- Roles and responsibilities for a curbside education program and inclusion of LIB as unacceptable and/or handled separately
- Requiring a monthly report on batteries found, in inventory and disposed
- Inbound Material Control
- Developing operational procedures and controls
- Battery Recovery Locations
- Based on industry and experience, batteries are most often recovered at MRFs from locations specified in Guidance
- Battery Identification: Soft-sided Battery
- Noting certain batteries produce their own oxygen
- Removal
- Once identified, frontline employees should inspect and extract any batteries from the inbound material stream
- Damaged Battery Protocol
- Damaged batteries should not be stored with other undamaged batteries
- Material Storage
- At the end of each day, batteries should be moved to a long-term storage location from their temporary location
- Facility Inspections and Maintenance
- Fire Suppression
- Housekeeping
- Facility Operations
- Response Plan: Properly Labeled Storage Location
- Consumer Awareness Messaging
- Batteries are not safe in residential solid waste or recycling systems
- Power comes with responsibility
- Spent batteries aren’t dead and can be dangerous
- Don’t remove non-removable batteries
- Tape or bag
A copy of the Guidance can be downloaded here.
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