Reporting Batteries in California – Encamp

In March 2022, a document was released by the California Hazardous Materials Business Plan (HMBP) Technical Advisory Group that detailed how facilities should report various types of batteries in California.

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RESOURCE: Battery Reporting Guidance for Unified Program Agencies (March 2022)

This Knowledge Base article summarizes that guidance and should help facilities determine how to report various types of batteries on their Tier II reports in California. Note that this guidance covers most scenarios (i.e., most batteries in most jurisdictions in California), but the local regulator for your facility may have additional or different requirements.

Do I Report My Battery?

The guidance document provides a flowchart (shown below) that will help you decide whether or not to include a given battery on your HMBP.

Helpful definitions:

"Consumer Product" exemption: Any "commodity used for personal, family, or household purposes, or is present in the same form, concentration, and quantity as a product prepackaged for distribution to and use by the general public”. Examples: consumer type batteries (e.g. AA batteries), lead-acid batteries in cars

"Article" exemption: Any item that “under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical and does not pose a physical hazard or health risk to employees”. OSHA has provided several interpretations specifically excluding most batteries from the definition of an article.

Important item to note from the flowchart: Even if an item normally qualifies for one of the listed exemptions, if it is determined (by your or a regulator) that a release of the battery would compromise human health, safety, or the environment, then it still must be reported.

Reporting Thresholds

The following contains guidance on specifics of how to report a qualifying battery on the Tier II report based on the physical state of materials contained within the battery.

The guidance document provides definitions of what is a "solid" and what is a "liquid" in the event that the "physical state of materials contained within the battery is unclear (e.g. some electrolytes are in gel form)".

Solid – a material that has a melting point and decomposes or sublimes at a temperature greater than 68°F (20°C).

Liquid – a material having a melting point that is equal to or less than 68°F (20°C) and a boiling point which is greater than 68°F (20°C) at 14.7 pounds per square inch absolute (psia)(101 kPa)

If the battery contains liquid hazardous material,

And the concentration of the liquid is GREATER than 1%,

AND the aggregate amount of liquid present (at all sources at your facility) is greater than or equal to 55 gallons, the battery state of matter should be reported as a LIQUID and the amount should be reported in gallons.

AND the aggregate amount of liquid present (at all sources at your facility) is less than 55 gallons, the material does not need to be reported.

If the concentration of the liquid is LESS than 1%,

The battery state of matter should be reported as a SOLID on your HMBP (provided it exceeds the threshold - see below)

If the battery contains solid hazardous material,

and the aggregate amount of that solid hazardous material present (at all sources at your facility) is greater than or equal to 500 pounds, the battery state of matter should be reported as a SOLID and the amount should be reported in pounds.

and the aggregate amount of that solid hazardous material present (at all sources at your facility) is less than 500 pounds, the material does not need to be reported.

Storage Location Name: Battery

Hazards and Mixture Components: Refer to your specific Safety Data Sheet