Welcome Guest! The IOSH forums are a free resource to both members and non-members. Login or register to use them

Postings made by forum users are personal opinions. IOSH is not responsible for the content or accuracy of any of the information contained in forum postings. Please carefully consider any advice you receive.

Notification

Icon
Error

Options
Go to last post Go to first unread
CdC  
#1 Posted : 26 March 2021 16:23:21(UTC)
Rank: Forum user
CdC

Dear Forum,

can somebody point me in COMAH where the limits are for storing of lithium ion batteries (industrial type)? Someone quoted 100tonnes, but I want to confirm this myself.

Anybody know?

Ian Bell2  
#2 Posted : 26 March 2021 16:59:07(UTC)
Rank: Super forum user
Ian Bell2

Look it up in the Schedule table in the HSE COMAH guide, that gives the material quantities before COMAH kicks in.

CdC  
#3 Posted : 26 March 2021 17:10:05(UTC)
Rank: Forum user
CdC

Originally Posted by: Ian Bell2 Go to Quoted Post

Look it up in the Schedule table in the HSE COMAH guide, that gives the material quantities before COMAH kicks in.


Hi Ian, yes I did, but I couldn't find it. It's not a flammable gas, solid or liquid, but a mixture of all. And is not included by name, so struggling to identify the correct limit.
Ian Bell2  
#4 Posted : 27 March 2021 14:07:55(UTC)
Rank: Super forum user
Ian Bell2

If lithium isn't listed as a named substane in Table 2 of the COMAH Schedule 1 Dangerous substances.

The next step is to revert to Table 1 and identify if the lithium fits into any of the general hazard classes - toxic, environmental hazards, explsive hazards etc.

Before you can do that you will need to identify the CLP classification and the physio-chemical properties of the lithium you have. 

THen if you fall into 1 of the COMAH hazard categories based on chemical properties of the lithium you have, calculate the quantity of lithium to see if you exceed the COMAH limits for either lower or upper tier sites. Is it pure lithium or an alloy?

Afraid nobody can do it for you, as readers don't know what storage inventory you might have of lithium.

Lithim is classified as flammable and corrosive (elemental / metallic form)

https://echa.europa.eu/substance-information/-/substanceinfo/100.028.274

peter gotch  
#5 Posted : 28 March 2021 10:24:32(UTC)
Rank: Super forum user
peter gotch

CdC - have you asked the suppliers who should know the answer?

Their Safety Data Sheet should give you some clues as to how to classify the batteries, but the SDS would probably be written with a view to those storing/using batteries in quantities well below any COMAH threshold.

Edited by user 28 March 2021 10:25:36(UTC)  | Reason: Minor edit

CdC  
#6 Posted : 29 March 2021 09:49:11(UTC)
Rank: Forum user
CdC

Dear all, thank you for all replies and advice so far.

The problem I think is that it is not Lithium in its pure form we are storing, but Li-Ion batteries, and these are not classified as dangerous or hazardous according to Regulation (EC) no. 1272/2008.

"This product contains dangerous ingredients however, there is no expected release during
use of the product and there is a barrier preventing exposure of the user and the environment."

Ian Bell2  
#7 Posted : 29 March 2021 10:33:38(UTC)
Rank: Super forum user
Ian Bell2

Sounds like COMAH won't apply then

stevedm  
#8 Posted : 30 March 2021 07:01:05(UTC)
Rank: Super forum user
stevedm

...it depend on how much of the battery is actually Lithium so you can do a calculation based on the actual %age of the mass being lithium and go from there but it can still apply...and if that contributed to the 2% rule..there will be other issues if you are charging as well...and ensure that Env Waste permitting is up to date or considered in you planning if not already...drop me a note if you need any more

Users browsing this topic
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.