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#1 Posted : 11 May 2004 10:16:00(UTC)
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Posted By Geoff Dicker My council is about to establish a scheme to collect waste batteries from householders, this will mean anything from an AAA to a car battery. The main questions are: whether carrying batteries would come under the carriage of Dangerous Goods by Road legislation; and if so what markings should go on the vehicles, and what training should the drivers have; what are the best types of containers, and would this type of consignment also be classed as Special Waste under the regulations? I am hoping that other "OSH chatters" have had similar experience with this, as the information sources that I have consulted so far have confused rather than clarified. Any information or pointers in the right direction would be most appreciated.
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#2 Posted : 11 May 2004 14:21:00(UTC)
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Posted By Danny Swygart Our company (Scrap Dealer) deals with large quantities of Car Batteries. Car Batteries (Lead Acid batteries) are classified as Special Waste (soon to be changed to Hazardous Waste Regulations in early 2004? - which should be simpler to understand and implement). Car Batteries transported by road do come under the Carriage of Dangerous Goods by Road Regs. Waste carriers Registration is required. A Duty of Care Waste Transfer note will need to be completed. The Driver will need to be ADR qualified and Corrosive warning signs need to be displayed on vehicles. Car Batteries can be transported in special plastic Battery bins with lids or in double skinned bulker lorries. Further Guidance should be available from the Environment Agency. A large buyer of car batteries is Enthovens of Darley Dale Nr Matlock. Hope this helps (please bear in mind I am talking about large quantities). Danny (European Metal Recycling Ltd).
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#3 Posted : 12 May 2004 12:39:00(UTC)
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Posted By Richard Fisher Geoff, With regards the waste side, the batteries may not be classed as Special Waste as within the Special Waste Regulations 1996 (as amended) the phrase is "Household Waste is not special waste". It probably would be best to get in touch with your local Environment Agency office and have a chat to them as they may have other requirements in terms of a disposal point or transfer point. I hope this helps. Richard Fisher Waste Technician
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#4 Posted : 13 May 2004 01:20:00(UTC)
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Posted By Mark Dixon Geoff Where are they going and who is collecting them? Is it a contractor like SITA and are they going on to a transfer station or straight off to recyclers? I do a bit of work with Bristol CC and know that we take them on the CA sites but I'd have to find out about household collections - that's all done by SITA in any case - South Glos is the same - SITA run that as well.
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#5 Posted : 14 May 2004 14:02:00(UTC)
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Posted By Geoff Dicker Many thanks to those who have replied both on "OSH chat" and privately. The batteries in question will be picked up by a private recycling contractor on my Council's behalf and taken into the CA (civic amenity) site for onwards disposal. I suppose that the issue has highlighted the somewhat complex inter-relationship between health & safety and environmental legislation which don't always seem to dovetail very well.
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#6 Posted : 17 May 2004 14:36:00(UTC)
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Posted By George Wedgwood Here are some guidlines for conveyance of acid filled batteries; Batteries are classified as a dangerous substance for the purposes of the Carriage of Dangerous Goods by Road Regulations 1999,and the Carriage of Dangerous Substances by Road and Rail (Classification, Packaging and Labelling) Regulations 1996 as amended Batteries are given United Nations Substance Identification Number (UNNO) 2794 2795 2800 dependant upon the composition all are subject to guide 154. And are classified as Transport category 3 Batteries, wet filled with acid, electric storage United Nations Number (UNNO) 2794. Class 8: Corrosive Emergency Action Code (EAC): 2R: Fine spray, chemical protective clothing Packing Group 111: Minor danger Batteries wet, non-spillable, electric storage UNNO 2800 Class 8 EAC: 2X fine spray, chemical PPE, contain Special Provision: There are sets of complicated and detailed tests for this provision, pertaining to new batteries therefore not applicable Batteries currently shipped to Recyclers must be contained within purposely-constructed containers as Danny rightly states. Weights and amounts of batteries collected can vary; Size of Load If the dangerous goods (DG) are carried in packages, and the size of the load and size of individual packages are below specified thresholds, the regulations do not apply. See table below - sorry about the formatting; Transport Cat. Mass in lt./kg of dangerous goods in each receptacle Total mass or volume of packaged dangerous goods 0 No lower limit No lower limit 1 1 20 2 10 200 3 25 500 4 Unlimited Unlimited There are two sets of quantity thresholds; these are set out in Cols 2&3 above Use these to calculate if the requirements apply. If the mass or volume of Dangerous Goods in each receptacle (i.e. each IBC - special container) is above the threshold in Col. 2 then it must be determined if the total mass or volume is above the threshold in Col.3 If the individual IBCs` weight when full of batteries, are less than 25kg each then any number can be transported, without the requirements applying Next if the receptacle contains more than the threshold in Col 2 and the subsequent total weight of batteries exceeds 500kg, then the requirements of the regulations will apply. Note that a Dangerous Goods Safety adviser must carry out a risk assessment prior to transportation by a carrier/operator as well as; • a training plan for drivers employed to carry these goods be implemented. • procedures for the safe movement and all its component parts be implemented. • all vehicles used in the operation are suitable for the purpose • all vehicles are marked and labelled as required. I hope this helps - regards, George
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#7 Posted : 17 May 2004 14:54:00(UTC)
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Posted By CHRISTOPHER HAYWARD Unfortunately neither the 1996 or 1999 regulations mentioned in the previous post apply any longer. The Carriage of Dangerous Goods and Use of Tranpsortable Pressure Equipment Regulations 2004 came into force on 10/5/2004. These now refer directly to ADR and so the 1996 tables are no longer relevant. Instaead refer to those in ADR 2003. Get a copy of "Working with ADR" by the Department and Transport of the HSE (also downloadable on their site) and buy a set of ADR 2003. Chris, Dangerous Goods Safety Advisor (having sat and passed the necessary exams)
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