55 days: Today Let’s Start Talking About Batteries…

SARA 312 Tier 2: 54 Days until deadline & counting down

What? Batteries aren’t articles and therefore exempt? Sorry, not for Tier 2.

“Confidence is knowing you are prepared for the unthinkable ” Ray Hunt, Horseman

Arguably another time-sensitive step is collecting your battery inventory.

Boring history that nobody cares about: for the first couple of years of Tier2 reporting, batteries were considered articles and were exempt from threshold determinations.

In the current instruction book from the Michigan Environment, Great Lakes, Energy EGLE website,

That sounded like batteries to us at the time.

Then the determination was made that “normal conditions of use” could include the battery rupturing in some way, and batteries, especially lead acid batteries, were pulled into the Tier2 universe.

This includes (typically quite large) forklift batteries, batteries in golf carts (each golf cart typically contains 4-6 car-sized batteries); and car batteries in vehicles driven on-site such as security vehicles.

When you see a few of the images below, this suddenly makes more sense. Especially considering that battery charging operations typically generate hydrogen gas, which is flammable and can be explosive.

Some forklifts are now using lithium batteries, which can be even more reactive if damaged.

The requirement to include lead acid batteries in your threshold determinations probably also includes Uninterrupted Power Sources UPSs in your server and switching rooms since they are typically banks of car or marine batteries.

Assuming you exceed threshold determinations for sulfuric acid and lead based on the larger items, depending on your state, you may even be required to include the locations of even individual sized UPSs under your employee workstations. Check with your state.

You may also be required to include UPS’s that only contain 1 car battery. These are frequently used in switching rooms for telephony and other electronic functions.  Again, check with your state.

You will also want to check with your state for whether gel cell batteries, also known as maintenance free batteries need to be included. Here’s a link to info about gel cell batteries.

You will need to consider batteries in 2 ways:

1) in your threshold determinations.

2) on your report if you exceed the threshold for non-exempt batteries.

Remember that even though Lead is not an Extremely Hazardous Substance EHS, it would be required to be reported on the Tier2 report if you have more than 10,000 pounds on site at any given time during the year. It doesn’t take long to hit that threshold with your forklifts and possibly with your banks of UPS batteries.

Speaking of checking with your state agency, many are holding Tier2 Training webinars soon, here’s the link to Michigan’s, (or search EGLE Tier2 if that doesn’t work) all 3 sessions are just $25.

This topic will get more than one additional blog post, one about some ideas for collecting your inventory of batteries, and at least one other about threshold determinations for batteries.

In the meantime, start figuring out how you will collect your battery information.

This is an area where a survey form sent out to departments (with tight deadlines for response) might be a good approach.

Call to Action: Share your method of collecting your battery inventory. Whose is the least burdensome?

More tomorrow, here’s to March 2nd!