Rank: Forum user 
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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?
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Rank: Super forum user
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Look it up in the Schedule table in the HSE COMAH guide, that gives the material quantities before COMAH kicks in.
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Rank: Forum user
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Originally Posted by: Ian Bell2  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.
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Rank: Super forum user
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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
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Rank: Super forum user
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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
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Rank: Forum user
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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."
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Rank: Super forum user
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Sounds like COMAH won't apply then
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Rank: Super forum user
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...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
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