defra batteries

7/21/2019 Defra Batteries

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Advisory Note on the storage and transportof waste portable batteries

Version 1

July 2009

www.defra.gov.uk


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Storage and transport of portable batteries

Table

of

Contents

Part 1 - Introduction ......................................................................................................... 3

Part 2 Duty of Care and Waste Carrier Registration ..................................................... 4

Part 3 Environmental Permitting ................................................................................... 6

Part 4 Carriage of Dangerous Goods ........................................................................... 6

Part 5 - Hazardous Waste ............................................................................................... 9

Part 6 Safe Storage of Batteries ................................................................................. 14

Part 7- Scotland and Northern Ireland ........................................................................ 156

Part 8 - Practical Examples:

Back Hauling................................................................................................ 17

In store take-back........................................................................................ 19

Postal Returns............................................................................................. 19

Annexes ............................................ ........................................ ................... 20

Authorisation 214 for the transport of up to 333kg of waste portablebatteries.......................................................................................................... 20

Mock Consignment Note................................................................................. 21

General Awareness Training for the handling of waste portable batteries..... 23


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Part1- Introduction

1. The Waste Batteries and Accumulators Regulations 2009 came into force

on 5th May 2009. These regulations will lead to an increase in the

collection of waste portable batteries for recycling very few are collected

currently. From 1 February 2010, retailers who sell 32kg or more ofportable batteries in a year will have to accept waste portable batteries

back from members of the public. There are also likely to be collections in

public buildings, such as libraries. This means that people who have not

previously been involved in storing and transporting waste (used batteries

are classified as waste) will be in the future.

2. We (Defra) organised a workshop on 13thMay 2009 to help those

collecting batteries under the new system understand the range of

legislation which applies to this activity. The main areas are the controls on

Hazardous Waste and the movement of Dangerous Goods. The

presentations from the 13thMay workshop are online at:

http://www.defra.gov.uk/environment/waste/topics/batteries/batteries-

implement.htm

3. The aim of this document is to summarise the information presented at the

workshop and to help those storing and transporting waste batteries

understand what they must do to comply with current legislation. We hope

that it will be of particular interest to those who were unable to attend the

workshop.

4. This note does not replace existing guidance on the individual pieces of

legislation and those who require more detail should refer to that guidance.

However, the note summarises the various requirements and points to

where more detailed help can be found. It covers the first part of the

collection system, from collection points (i.e. where the end-user disposes

of the batteries for recycling) to the bulking-up point or waste treatment

facility (if the waste is transported there directly). The note covers the

position in England and Wales and summarises the different rules applied

in Scotland and Northern Ireland.

5. For more detail on the Waste Batteries and Accumulators Regulations

2009, please refer to:-

Guidance note on the Batteries Regulationshttp://www.berr.gov.uk/files/file51268.pdf

The Environment Agencys battery pageshttp://www.environment-agency.gov.uk/business/regulation/101529.aspx
http://www.defra.gov.uk/environment/waste/topics/batteries/batteries-implement.htmhttp://www.defra.gov.uk/environment/waste/topics/batteries/batteries-implement.htmhttp://www.defra.gov.uk/environment/waste/topics/batteries/batteries-implement.htmhttp://www.berr.gov.uk/files/file51268.pdfhttp://www.environment-agency.gov.uk/business/regulation/101529.aspxhttp://www.environment-agency.gov.uk/business/regulation/101529.aspxhttp://www.berr.gov.uk/files/file51268.pdfhttp://www.defra.gov.uk/environment/waste/topics/batteries/batteries-implement.htmhttp://www.defra.gov.uk/environment/waste/topics/batteries/batteries-implement.htm


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Who should read this note?

6. This note will be of interest to anyone who stores waste batteries after they

have been deposited by end-users, transports the waste batteries or

receives them at a bulking-up point, Civic Amenity Site or treatment

facility.

Why does Hazardous Waste and Dangerous Goods legislation apply tobatteries?

7. Members of the public will return waste batteries of mixed sizes and

chemistries (e.g. alkaline, lithium, nickel cadmium, nickel metal hydride,

etc.). The battery chemistry cannot be identified simply from the shape or

size of a battery.

8. For instance, some AA batteries have an alkaline chemistry whilst others

may be of lithium or nickel cadmium chemistries. Batteries containing

lithium are classified as dangerous under the Carriage of DangerousGoods Act, while nickel cadmium batteries meet the definition of

hazardous under the Hazardous Waste Regulations.

9. Dangerous goods (not just waste) are those that pose a risk to people,

property and the environment. These types of goods can range from those

that are obviously dangerous (such as explosives, flammables and fuming

acids) to everyday products such as paints, solvents and pesticides found

in the home and at work. When transported, these goods need to be

packaged correctly as laid out in the various international and national

regulations for each mode of transport to ensure that they are carriedsafely to minimise the risk of an incident.

10. As Dangerous Goods, lithium batteries can normally only be transported

by road and sea under certain restrictions. Transport of lithium batteries by

air is banned. To help the collection of waste batteries, the Department for

Transport has introduced simplified rules for the transport by road of up to

333 kilogrammes of mixed waste batteries. There is more information on

this in Part 4 of this note.

11. Hazardous waste1 has properties that may make it harmful to human

health or the environment. The EU has legislation on:-

the management of hazardous waste (Directive 91/689/EEC);and

the definition of hazardous waste the List of Wastes Decision

(Commission Decision 2000/532/EC as amended).

1In Scotland, hazardous waste is referred to as special waste.


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12. The Hazardous Waste Directive will be replaced by the revised Waste

Framework Directive in December 2010, however, the new Directive

contains many similar provisions.

13. Hazardous waste regulations and their equivalent in Scotland are enforced

by the environment agencies. Further details can be found on the

agencies websites:-

Environment Agency for England and Wales: (http://www.environment-agency.gov.uk/business/topics/waste/32180.aspx),Scottish Environment Protection Agency (SEPA) in Scotland:(http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx)Northern Ireland Environment Agency in Northern Ireland: (http://www.ni-environment.gov.uk/wasthome/regulation/regulations_hw.htm)

14. Not all batteries fall under these classifications (hazardous and

dangerous). The most popular type of portable battery Alkaline - is not

classed as hazardous or dangerous. However, a container full of mixed

waste batteries is almost certain to contain a small proportion that are

deemed to be dangerous and/or hazardous. Therefore all mixed waste

batteries must be transported and stored appropriately. Anyone

considering separating out lithium and nickel cadmium batteries (and this

is not an easy task, even for experts) should bear in mind that, when

concentrated, lithium batteries present a greater risk than when dispersed

among other batteries and the controls on movement are more stringent.

Consideration should therefore be given to whether it is easier to keep

waste batteries mixed.

Part2DutyofCareandWasteCarrierRegistration

What is the Duty of Care?

15. If you are in possession, or have control of waste, you have a legal 'Duty

of Care' to store it safely without causing pollution or harm and to only

transfer it to someone who is legally allowed to take it. The Duty of Careapplies to everyone who handles waste; from the person who produces

the waste to the person who finally recycles or disposes of it. The Duty of

Care is one of the main ways to combat flytipping.

16. If you are responsible for controlled waste (all batteries are likely to fall

within this definition) you must ensure that the waste is stored safely,

managed properly, recovered or disposed of safely, does not cause harm

to human health or pollution of the environment, is only transferred to

someone who is authorised to receive it and, when transferred, is
http://www.environment-agency.gov.uk/business/topics/waste/32180.aspxhttp://www.environment-agency.gov.uk/business/topics/waste/32180.aspxhttp://www.sepa.org.uk/waste/waste_regulation/special_waste.aspxhttp://www.ni-environment.gov.uk/wasthome/regulation/regulations_hw.htmhttp://www.ni-environment.gov.uk/wasthome/regulation/regulations_hw.htmhttp://www.ni-environment.gov.uk/wasthome/regulation/regulations_hw.htmhttp://www.ni-environment.gov.uk/wasthome/regulation/regulations_hw.htmhttp://www.sepa.org.uk/waste/waste_regulation/special_waste.aspxhttp://www.environment-agency.gov.uk/business/topics/waste/32180.aspxhttp://www.environment-agency.gov.uk/business/topics/waste/32180.aspx


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described in sufficient detail to allow subsequent holders to handle it

safely.

Waste Carrier Regist ration

17. If you intend to carry waste produced by others you must be registered as

a Waste Carrier with the relevant environment agency. At present this

registration costs 152 (157 in Scotland and 120 in Northern Ireland) forthe first three years and 102 (108 in Scotland and 60 in Northern

Ireland) for renewals. Renewals last for three years. Carrying waste

without a relevant authorisation is an offence.

18. Following a review of the waste carrier system conducted last year, it is

possible that businesses who only carry waste they produced themselves

will, in the future, have to register with the Environment Agency. If and

when the registration system changes, the requirements will be

communicated to businesses. We consulted on these proposals in June

2008:

http://www.defra.gov.uk/environment/waste/legislation/duty.htm#12

19. In practical terms, the person who has delivered waste batteries to a

collection point is the waste producer, so even under the current

regulations all movement of waste batteries from a collection point must

be made by a registered waste carrier. From time to time, you will be

asked by those responsible for the collection point for proof that you are

properly registered.

20. As well as being registered, you must carry the waste correctly and deliver

it to someone allowed to take it. So, when delivering the waste batteries,

the collector should make sure that the site is authorised to take them. In

most cases, this will mean that the site has an environmental permit or is

covered by a properly registered exemption (see below).

Part3EnvironmentalPermitting(EnglandandWales)

(see Part 7 for Scotland and Northern Ireland requirements)

21. Under existing regulations, all collection points for waste batteries must

have an environmental permit but the Environment Agency has adopted a

low risk waste position which covers portable battery collection points

accessible to the public. Low risk waste positions (in this case LRW 006)

reflect the environmental risk posed by certain activities that do not

currently benefit from an exemption from permitting.
http://www.defra.gov.uk/environment/waste/legislation/duty.htm#12http://www.defra.gov.uk/environment/waste/legislation/duty.htm#12http://www.defra.gov.uk/environment/waste/legislation/duty.htm#12


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22. LRW 006 allows the storage of up to 80kg of waste dry cell batteries

(portable batteries), provided that the operator (e.g. retailer, person in

charge of waste in a school, public building etc.) ensures that the activity

does not cause pollution or harm to human health. It requires no

notification and involves no fee.

23. This will only apply until February 2010 for retailers and April 2010 forother collection points. From 1 February 2010 there will be a formal

exemption from the need for an environmental permit for retailers and any

other distributors of portable batteries who are obliged to provide take-

back facilities (that is, those selling 32kg of batteries or more per year).

24. Defra plans to introduce in April 2010 an exemption from environmental

permitting for other battery collection points (e.g. those in public buildings).

25. Collection points other than those which are accessible to end users, such

as bulking-up points2, will also benefit from an exemption fromenvironmental permitting the details of the exemptions are being

developed as part of the review of waste permitting exemptions.

Part4CarriageofDangerousGoods

26. This section assumes that you are transporting less than 333 kilogrammes

of used portable cells or batteries. If so you can benefit from the specialprovisions the Department for Transport have put in place for such cases.

27. Carriers and drivers must be able to assess whether the amount of used

cells or batteries they are carrying will exceed that amount. If you carry

more than 333 kilogrammes you will need to comply with the full ADR

regulations.

Who needs to comply with the Dangerous Goods legislation ( ADR )

28. ADR identifies 3 roles:

The Consignor is the person consigning the used cells or batteries for

transport i.e. whoever collects and stores batteries (e.g. retailer, someone in

a public building, school etc).

2Batteries can be stored at a bulking point for a period of up to 6 months after which they will need to

be moved to a Treatment Facility.


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The Carrier is the person that collects the used cells or batteries from the

Consignor and packs them appropriately for transport. ADR has a role for the

packer as well, i.e. the person ensuring that the used cells or batteries are

packed and put in appropriate containers ready for their transport. However,

in practice the carrier and the packer are the same person. Often these

functions are covered by the Driver.

The Driver is the person that drives the vehicle which will take the used cellsor batteries to the intermediate bulking- up point.

29. When the collection box is full, the operator of the collection point - the

Consignor - will arrange to have it collected by a carrier.

30. The Consignor must ensure that those used cells or batteries are taken

away from the premises by a trained Carrier. The Consignor must be

aware of the correct way of packing the used cells or batteries so that

when the collector comes to take them away he/she can be satisfied that

the Carrier is properly trained. The packing requirements are

straightforward and are explained in the following section.

31. The Consignor, Carrier and the Driver need to receive training to ensure

that they know their responsibilities. The training, which can be with a

trainer or through written guidance, should also be straightforward. An

example of the type of written guidance that could be used is at Annex 3.

When training is complete, the consignor will needs to keep the guidance

or another document certifying that he/she received the training and this

needs to be kept for 3 years for inspection.

32. The training needs to be done every three years.

33. Once correctly packed, the Driver will take the load to a bulking-up point or

treatment facility. No Dangerous Goods can be kept in a vehicle overnight

so all waste batteries must be taken to such a place by the end of the day.

This means that if a driver has several pick-ups to undertake he must

complete them all within one day and get the batteries to a bulking-up

point or treatment facility before the end of that day.

How to pack and transport waste portable batteries

Authorisation 214

34. To help encourage the collection of used cells or batteries for recycling

while continuing to manage the risks posed by lithium batteries, the

Department for Transport have issued an authorisation permitting the

transport of used cells or batteries from consumer collection points to the


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bulk up point by road without the need to comply with the FULL ADR

regulations. These provisions, which apply until 30 June 2015, are

contained in the Department for Transports Authorisation 214 which is

available at:- http://www.dft.gov.uk/426155/425450/300/auth214.pdf

The Authorisation requires that:

35. The lithium cells or batteries shall be packed with other battery types (i.e.mixed with other chemistries, so lithium-only loads are not permitted under

Authorisation 214) in a closed plastic liner within a metal or plastic drum or

box to prevent undue movement. Each plastic liner shall only be used

once.

36. Each drum or box shall be marked on the outside with the words USED

LITHIUM CELLS in capital letters which are a minimum of 12mm high on a

contrasting background.

37. The maximum total quantity of mixed used cells or batteries per transport

unit shall not exceed 333kg.

38. All personnel involved in the transport of the cells or batteries must

undergo appropriate general awareness training commensurate with their

responsibilities.

39. The 333 kg limit applies to the weight of all the used cells or batteries not

just lithium ones i.e. you must not carry mixed batches of used cells or

batteries weighing more than 333 kg. If you wish to carry more than 333kgthen you will have to comply with the full ADR regulations.

40. Finally, as already covered, all parties involved need to undertake general

awareness training. This can be given by a trainer or by providing written

guidance. A copy of the general awareness training (see Annex 3) must be

kept for a period of 3 years.

Special cases

41. The transport of lithium batteries by air is banned. As it will not be possible

to identify which are lithium batteries and which are not, you should not

transport used cells or batteries by air. Consignment by sea would need to

comply with the requirements in the International Maritime Dangerous

Goods (IMDG) code. In view of the air restrictions and the full

requirements of ADR and IMDG Code, the Department for Transport does

not recommend that you use postal returns as it would be too difficult in

practice to comply with the legislation.


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Part5- HazardousWaste

Consigning the waste

42. This section covers the regulations which apply in England and Wales to

track hazardous waste from where it is disposed of to where it is treated.

As explained earlier, mixed loads of batteries are considered to be

hazardous waste.

43. There is a slightly different system in Scotland where hazardous waste is

referred to as special waste and in Northern Ireland.

44. SEPA has produced guidance on consigning special waste which is

available on the SEPA website:-

http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx

45. The NIEA has produced guidance on consigning hazardous waste which isavailable on the NIEA website:-

http://www.ni-environment.gov.uk/wastehome/regulation/regulations_hw.htm

46. A consignment note needs to be completed for each batch of waste batteries

being moved. A standard consignment note is made up of five parts, each

must to be completed by a specific person acting under a specific role, in a

similar way to the ADR regulations.

47.

Figure 1 A consignment note divided into 5 parts.

(N.B.This is a diagrammatic representation. See Annex 2 for a more realistic sample).

48. The roles are as follows:

- Producer

- Carrier

- Consignee

10
http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspxhttp://www.ni-environment.gov.uk/wastehome/regulation/regulations_hw.htmhttp://www.ni-environment.gov.uk/wastehome/regulation/regulations_hw.htmhttp://www.ni-environment.gov.uk/wastehome/regulation/regulations_hw.htmhttp://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx


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49. Under the batteries regulations a producer is the person who puts batteries

on the market. However, in the context of the hazardous waste

regulations, a Producer is the operator of the first premises collecting the

waste batteries (e.g. retailers, public buildings, etc), with the exclusion, as

always, of domestic premises. All premises in England and Wales where

more than 500kg of hazardous waste is collected (or produced) per year(apart from domestic waste from domestic premises) must be notified to

the Environment Agency.(This is not the case for premises located in

Scotland or Northern Ireland). Information on how to notify premises can

be found on the Agency website at:-

http://www.environment-agency.gov.uk/business/topics/waste/32198.aspx.

50. We expect that many battery collection points will collect less than 500 kg

of batteries and other hazardous waste and therefore will not have to be

notified. However, please note that the 500kg limit includes all hazardous

waste collected at the premises, not just batteries So, for example, if your

premises collects 100 kilogrammes of batteries and 450 kilogrammes of

other types of hazardous waste (for example, CRT televisions if you are an

EEE retailer), you will need to complete a notification.

51. The Carrier is the person collecting and transporting the hazardous waste

(e.g. collecting from a store).

52. The Consignee is the person receiving the waste (e.g. the operator of a

bulking up point). They will, in turn, be the Producer for any onward waste

movement, for example where hazardous waste is moved from a bulking-

up point to a treatment facility. (NB A bulking-up point will almost certainly

have to be notified as a site where hazardous waste is produced).

53. The consignee (if located in England or Wales) must make quarterly

returns to the Environment Agency of the amount of hazardous waste they

have received in the format specified by the Agency. This will include a

summary of every consignment received at their site. The Environment

Agency makes a charge of 10 per quarterly report for dealing with thisinformation. For waste originating from Scotland or Northern Ireland the

consignee is required to send a copy of the completed consignment note

to SEPA or NIEA respectively. The Consignee must also make quarterly

returns to producers to confirm receipt of the waste.

54. Each person must fill-in the relevant section of a consignment note and

keep a copy of it.
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Single and Multiple collections Consignment Notes

55. Consignment notes can be of two types, either for single journeys or

multiple journeys. For collections from premises in England and Wales the

consignment note can be downloaded free of charge from the Environment

Agencys website:-

http://www.environment-agency.gov.uk/business/topics/waste/32196.aspx, or

if you prefer, you can print your own, provided they contain space for all therequired information.

56. In Scotland and Northern Ireland consignment notes must be purchased

from the respective Agencies. For details of fees in each jurisdiction and

guidance on the completion of consignment notes please see websites:

http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx and

http://www.ni-environment.gov.uk/waste-

home/regulation/regulations_hw.htm

57. In the case of a single journey, there is one producer (usually also the

consignor), one carrier and one consignee. This will happen when a

vehicle is sent out to collect from one collection point and to transport the

batteries to a bulking-up point or treatment facility.

58. It is much more common that a vehicle will collect from a number of

collection points. For such multiple collections, there will be a number of

producers, but only one carrier and one consignee. Guidance on

consignment notes for multiple collections in England and Wales is at:-

http://www.environment-agency.gov.uk/static/documents/GEHO0507BMSJ-e-e.pdf

59. To simplify the job for all parties involved, consignment notes can be pre-

printed with any information which does not change from one trip to the

next. This only applies to England and Wales. They can also be completed

electronically see:-

http://www.environment-agency.gov.uk/business/topics/waste/34867.aspx.

Life of a Consignment Note

60. The responsibility for filling-in the consignment note starts with the

producer of hazardous waste (e.g. retailer) although in practice this is

often done by the carrier (the producer must still sign it as being correct).

The producer (or the carrier on their behalf) must complete parts A, B and

D and retain a copy.

61. On collection, the collector must complete part C and take the batteries to

the consignee. He retains part C and the consignee fills out part E and

keeps a copy and gives a copy to the carrier. The consignee will return a
http://www.environment-agency.gov.uk/business/topics/waste/32196.aspxhttp://www.sepa.org.uk/waste/waste_regulation/special_waste.aspxhttp://www.ni-environment.gov.uk/waste-home/regulation/regulations_hw.htmhttp://www.ni-environment.gov.uk/waste-home/regulation/regulations_hw.htmhttp://www.environment-agency.gov.uk/static/documents/GEHO0507BMSJ-e-e.pdfhttp://www.environment-agency.gov.uk/static/documents/GEHO0507BMSJ-e-e.pdfhttp://www.environment-agency.gov.uk/static/documents/GEHO0507BMSJ-e-e.pdfhttp://www.environment-agency.gov.uk/business/topics/waste/34867.aspxhttp://www.environment-agency.gov.uk/business/topics/waste/34867.aspxhttp://www.environment-agency.gov.uk/static/documents/GEHO0507BMSJ-e-e.pdfhttp://www.environment-agency.gov.uk/static/documents/GEHO0507BMSJ-e-e.pdfhttp://www.ni-environment.gov.uk/waste-home/regulation/regulations_hw.htmhttp://www.ni-environment.gov.uk/waste-home/regulation/regulations_hw.htmhttp://www.sepa.org.uk/waste/waste_regulation/special_waste.aspxhttp://www.environment-agency.gov.uk/business/topics/waste/32196.aspx


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fully completed copy of the consignment note to the producer. and the

NIEA or SEPA for waste arising in Northern Ireland or Scotland

respectively.

62. The Environment Agency has further guidance on using consignment

notes in England and Wales that can be found at:-

http://www.environment-agency.gov.uk/hazwaste .
http://www.environment-agency.gov.uk/hazwastehttp://www.environment-agency.gov.uk/hazwaste


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Figure 2 Life of a consignment noteSource: Environment Agency

Household

Household Collection Point(Haz waste Producer)

Producer RegisterMust store producer copies ofconsignment notes, andproducer returns fromconsignee for 3 years.

Hold at notified premises.

If exempt hold at principalplace of business OReachproducer can ask the EA toagree to let them hold it inanother place.

Consignee must send ProducerReturn. Either copy of consigneeconsignment note ORQuarterlyreturn from from Regs.

Site RegisterMust store consignee copiesconsignment notes for wastereceived.

Must also store their outgoingproducer notes and producerreturns from final disposal sit

Duration depends on activitywill be a minimum of three ye(see guidance)

Waste Carrier

Carriage ofDangerousGoods applies

Carrierregistrationrequired

CMa

o

Consignmentnote required

Premises NotificationRequired if 500kg+ of more ofall hazardous waste producedin any 12 month period at thatpremises.

Separately collecteddomestic fraction noconsignment notes required

Household

14


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Part6SafeStorageofBatteries

63. There are no specific health and safety requirements for storing batteries,

but normal health and safety rules apply. This includes that the responsible

person should assess health and safety risks. In a workplace, the

responsible person is the employer or person who occupies or owns thepremises. In all other premises the responsible person will be the person

or people in control of the premises.

64. Health and Safety Executive considers the risks from storing small

quantities of portable batteries to be very low if sensible common sense

precautions are taken. But these should be taken into account in a

businesss health and safety risk assessment.

The five steps of risk assessment

65. The basic five steps in a risk assessment are:-

a. Identify the hazards.The hazards from batteries are mainly leakage of

chemicals and fire.

b. Identify the people at risk if there is an incident. This may include both

people who use the premises and those nearby. Particular attention

should be paid to people who may be especially at risk such as:

employees who work alone, e.g. cleaners, security staff; unaccompanied children and young people;

people who are unfamiliar with the premises, e.g. visitors;

customers; and contractors.

people with disabilities or those who may have some other

reason for not being able to leave the premises quickly;

and

people with language difficulties.

c. Evaluate the risk to people if an incident occurs and take any

necessary measures to ensure the risk to their health and safety is as

low as is reasonably practicable. The specific circumstances will dictate

the appropriate measures to prevent or reduce the risk of an incident,

but for batteries may include:

Using a collection box which limits the size of objects that

may be inserted and minimises the possibility of leakage;

Locating the collection box where it can be readilymonitored;


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To regularly check the contents of the collection box andmove to a secure and safe storage area when deemednecessary;

To locate collection boxes where they are unlikely to beexposed to fire or sources of heat; interfere with normalaccess routes, or emergency escape routes.

d. Prepare a plan and provide instruction and training of what to do in the

event of an incident. This should include who is to inform the

emergency services if necessary.

e. If you employ five or more people, the significant findings of the risk

assessment should be recorded in compliance with other Health and

Safety (and Fire Safety) Legislation.

f. Keep the assessment under review and revise where necessary; for

example, if conditions change, or following an incident to prevent

recurrence.

Part7- ScotlandandNorthernIreland

This section explains the main differences between the regulations in England andWales compared to those in Scotland and NI.

Scotland

Waste Management Licensing

66. Paragraph 17 of Schedule 3 to the Waste Management Licensing

Regulations 1994, as amended, provides an exemption for battery

collection points. This can be registered on-line through the SEPA website

and is free of charge:

http://www.sepa.org.uk/wmxreg/pages/welcome.aspx

67. It covers the storage of up to 5 cubic metres of mixed municipal batteries

for up to 12 months in a secure place.

Special Waste68. The main differences between the system in England & Wales and in

Scotland are:

- producers do not need to register as producers of special waste

- all movements of special waste must be prenotified, except successions

and movements of only lead acid batteries.
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69. The consignment note system is similar in Scotland with a similar five part

note to be completed for each movement. SEPA has produced guidance

on consigning special waste which is available on the SEPA website:

http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx

Northern Ireland

Waste Management Licensing70. Regulation 16A of the Waste Management Licensing Regulations

(Northern Ireland) 2003 (as amended) provides an exemption for battery

collection points where collection point is a place where end users are

able to deposit waste portable batteries or accumulators , i.e. the premises

of a distributor, thus fulfilling its duty of care take back responsibilities.

71. Collection points other than those which are accessible to end users such

as a bulking-up points, will be required to register for an exemption under

paragraph 52 of Schedule 2 to the Waste Management LicensingRegulations (Northern Ireland) 2003 (as amended). The exemption, which

presently has an annual fee of 530, will allow up to 5 tonnes of

automotive batteries and accumulators and 10 tonnes for portable

batteries and accumulators to be stored for a period of up to 6 months

after which they will need to be moved to a Treatment Facility.

Hazardous Waste72. Similar to the system in Scotland, hazardous waste producers are not

required to register with the NIEA. All movements, with few exceptions,

must be pre notified prior to movement with the NIEA.

Part8- PracticalExamples

73. This section provides some examples of how businesses could carry out the

storage, collection and transport of batteries in compliance with the

regulations referred to in this guidance. These examples must not be read in

isolation, but together with the rest of this note as there are cross-referencesto the relevant parts of the guidance.

Back Hauling

Back-hauling is the transport of batteries within an existing supply chain via the

suppliers vans or lorries. In other words, the same vehicles that deliver goods will

take away the waste batteries deposited in the store.
http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspxhttp://www.sepa.org.uk/waste/waste_regulation/special_waste.aspxhttp://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx


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1) Batteries are safely collected in the store see Part 6 for advice on how toassess that you are collecting safely.

2) The company delivery lorry comes the driver has received awarenesstraining on handling lithium batteries in accordance with Authorisation 214 andhas a document confirming this in the lorry.

3) The retailer will also have received the training so that they can assess that

the batteries are packed correctly for transport. They will also have a signeddocument to show that they have done the awareness training. NB This willlast 3 years. (See Part 4)

4) The driver must establish the weight of the batteries. He must be able todemonstrate that he is not carrying more than 333kg of waste batteries. Thiscan be done by having a container which cannot take more than 333 kg ofbatteries (Part 4)

5) The supplying company (not the individual driver) needs to be a registeredWaste Carrier and the retailer can (and should if not familiar with the driver)

ask the driver for proof. (Part 2)

6) The lorry driver has a pre-printed block of consignment notes with him.(Part 5)

7) The driver puts the weight of batteries on the consignment note and asks theretailer to sign and keep his copy of the consignment note for 3 years. Thedriver signs his own copy and keeps it for filing in the company system (alsofor 3 years). (Part 5)

8) The driver puts the batteries in the safe container with the lining and closesthe lid. (The retailer needs to ensure its done correctly). The driver puts the

container in the lorry and makes sure its well placed so it doesnt move duringthe journey. (Part 4)

9) By no later than the end of the day the driver takes the batteries to a locationwhere they will be bulked-up. (Part 4)

10) The driver asks the responsible person at the bulking-up site to sign hissection of the consignment note and leaves him the bottom section for thereturns.NB If the bulking-up site is located in England or Wales the operator mustmake a quarterly report of the amount of batteries collected to theEnvironment Agency and to the store. (Part 5) If the site is located inScotland or Northern Ireland the operator must send a copy of the completednote to the respective Agencies.

11) The person responsible for the bulking-up site in England or Wales must keepall the consignment notes given to him by all the drivers in the company andevery quarter send a return to the EA on the batteries that they have received.He pays a fee of 10 per return. (Part 5)


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Collections from Shops selling more than 32 kilogrammes of batteries per year

Such shops will need to be ready to take back waste portable batteries on 1stFebruary 2010. Before then we recommend that you contact one or more BatteryCompliance Schemes to discuss collection of waste portable batteries from yourstore for recycling. You have a right to have the waste portable batteries taken awayby any of the compliance schemes free of charge.

Schemes will arrange collection dates to minimise the environmental impact of thetransport involved. Retailers should discuss collection dates with complianceschemes. We do not recommend that you move the waste portable batteriesyourself.

1) Batteries are safely collected in the store see Part 6 for advice on how to

assess that you are collecting safely.

2) A retailer contacts a Battery Compliance Scheme to arrange collection.

3) The scheme arranges for a professional waste company to collect the

batteries. The scheme must ensure that the collector knows the rules forcollecting waste according to Duty of Care, Waste Carriers, Hazardous waste

and transport of Dangerous Goods.

4) The remaining steps are the same as for back-hauling. The retailer must have

had the basic dangerous goods training to ensure that they know how

batteries should be packed for transport. (Part 4) They must ensure the

person collecting is that sent by the compliance scheme. The retailer must

sign and receive consignment notes from the collector (Part 5).

Postal Returns

We do not advise postal return as a way to collect batteries from consumers

because it is not possible to identify the quantity of batteries being posted, drivers

might not know that they are carrying batteries and therefore what action they need

to take to carry the batteries safely. It would also be difficult to ensure that batteries

are not sent via air. The Department for Transports rules for the carriage of batteries

are clear - they must be carried by road or by sea. This is because the risk level is

heightened when batteries are being flown.


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Annexes

1 - Authorisation 214 for the transport of up to 333kg of waste portable batteriesSource:Departmentfortransport

20


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2 - Hazardous Waste Mock Consignment Note Source Environment AgencyPART A Notification Details

1. Consignment note code: ABC123/AB001 3. Premises Code: ABC123

2. The waste described below is to be removed from: 4. The waste will be taken to:(name, address, postcode, telephone, e-mail & fax) (address and postcode)

The Collection Point, High Street ,New Town, The Shire, XX12 3YY Battery Recycling, Low Street, Old Town, The ShireTel 0123 456789, [email protected] YY12 4XX5. The waste producer was (if different from 1) (name, address, postcode, telephone, e-mail & fax)

PART B Description of waste

1. The process giving rise to the waste(s) was: Domestic waste collection point 2. SIC for the process giving rise to the waste: ??????

3. WASTE DETAILS (where more than one waste type is collected all of the information given below must be completed for each EWC identified).

Description of

Waste

List of Wastes

(EWC) code

Qty (kg) The chemical /

biological

components of the

waste, their

concentrations

Physical Form Hazard code(s) Container type,

number & size

SeparatelyCollectedMunicipal

Fractions ofunsorted Domesticbatteries. Mayinclude alkaline,mercury, Nickelcadmium, nickelmetal hydride,silver oxide,lithium, and zinccarbon batteries.(excluding lead

acid batteries)

20 01 33* 18kg Variable dependingon battery type,likely to include.

Lithium oxides ,metal oxides, andsalt electrolytes(e.g.LiCoO2,LiPF6)

Lithium, Cadmiumand Zinc metalMetal Oxides(manganese,cadmium zinc)Metal Hydroxides

(Potassium, Nickel,Cadmium, Sodium)OrganicCarbonatesMercury

Solid H3A, H4, H5, H8,

H14

1 lined rigid bin,

50L

ADR information for each EWC identified above:

EWC code Description for CarriageUN Identification number(s) Proper Shipping

Name(s) Un Class(es)

Special Handling requirements

20 01 33*

PART C Carriers certificate PART D Consignor / Holders certificate(If more than one carrier is used, please attach a schedule for subsequentcarriers. If a schedule of carriers is attached tick here)

I certify that I today collected the consignment and that the details inA2, A4 and B3 are correct & have been advised of any specifichandling requirements:

1. Carrier driver name (please PRINT) Tony Driver

2. On behalf of

(name, address, postcode, telephone, e-mail & fax)

The Local Authority, Middle Street, Old Town, The Shire, YY32 1ZZ

Tel : 0987 123456 e.mail: [email protected]

3. Carriers registration no/ exemption reason:

ABC/012345

4. Vehicle registration no: AN07 1DE

SignatureT.DriverTime 18.00 Date 29/02/2008

I certify that the information in A, B & C above is correct, that the carrier isregistered or exempt and was advised of the appropriate precautionarymeasures. All of the waste is packaged and labelled correctly & the carrier hasbeen advised of any special handling requirements.

1. 1. Consignor / Holder name (please PRINT)

Mr Alan Node

on behalf of

(name, address, postcode, telephone, e-mail & fax)The Collection Point, High Street ,New Town, The Shire, XX12 3YYTel 0123 456789, [email protected]

SignatureA.NodeTime 18.00 Date 29/02/2008

PART E Consignees Certificate (where more than one waste type is collected all of the information given below must be completed for each EWC)Individual EWC code(s) received Quantity of each EWC code

received (kg)

EWC code accepted / rejected Waste Management operation

(R or D code)


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1. I received this waste at the address given in A4 on 29/2/2008 Name: (please PRINT) BERNARD ATTERY

2. Vehicle registration no (or mode of transport if not by road): AN07 1DE On behalf of (name, address, postcode, tel, e-mail & fax):

Where waste is rejected please provide details: Battery Recycling, Low Street, Old Town, The Shire, YY12 4XXTel : 0987 654321 e.mail: [email protected]

3. I certify that the waste management licence / permit / authorised exemption no(s). Signature:Bernard Attery

Date: 18.30authorises the management of the waste described in B at the address given at A4 Time: 29/02/2008


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3 General Awareness Training for the handling of waste portable batteriesSource DfT and VCA

Carriage of Dangerous Goods by road

Advice for General Awareness Training on the Movement

of Portable Waste Batteries

If you transport dangerous goods it is a requirement that personnel involved in any

aspect of the transport chain shall be trained. Training has to be commensurate with

responsibilities and a record must be maintained.

This advice is intended to assist those organisations collecting waste batteries from

consumer sites such as shops and offices. It is not definitive and may need to be

adjusted to take account of particular distribution systems.

If you are involved in the transport of portable waste batteries, then as part of the

requirements you need to have some general awareness training which will help you

consign, pack and transport the batteries safely.

The Department for Transport has issued an authorisation allowing mixed waste

batteries to be transported by road without the full application of the ADR provisions.

If you dont comply with the conditions of the authorisation, then you need to comply

fully with the provisions of ADR which are more onerous.

A load of mixed waste portable batteries will contain various types of batteries,

probably including lithium batteries. Lithium batteries are classed as dangerous

goods in transport because, if transported incorrectly, they may catch fire and

consequently pose a hazard to people. For this reason you need to be aware that

whenever you transport a mixed load of batteries, that load is highly likely to contain

some lithium batteries.

What training do you need? Well that depends on your role in the transport chain but

it isnt complex or difficult, its quite straightforward. This note aims to give you the

training you need in order to ensure you fulfil your obligations in relation to your role.


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A. If you are a consignor i.e. the person who allows other people to

deposit their waste batteries on their premises for future collection and

removal e.g. retailer or the responsible person in a public building,

school, library etc.

Make sure you site your collection container in suitable place so people can

easily deposit their waste batteries and that the person coming to collect thecontainer or its contents can get to it easily without disrupting your usual

business too much. You could put the container outside if you want provided

it can cope with the varying weather conditions.

You need to make sure that the container you provide is suitable for the

batteries. The batteries will be collected inside a plastic liner placed inside a

box or drum. Plastic liners can only be used once.

The driver will need to know the weight of the batteries in your container as

he can only carry a maximum of 333kg on his vehicle. Either your container

can be marked to indicate approximate weights or the driver can weigh the

batteries.

You need to be present to ensure the driver removes the batteries and

places them in the required box/drum for transport as per the authorisation.

The liner must be sealed shut (using a tight knot, tape or cable tie to ensure

that batteries cant move about) before being placed in the outer box or drum

which is marked with the required lettering as per the authorisation. If the box

or drum doesnt display the marking, dont allow the driver to use it. You are

the consignor and hence responsible for making sure the batteries are

packed for transport properly. You could face enforcement action if you

dont.

B. If you are the driver arriving to col lect the batteries

Check what container the consignor has. You may need to tip the batteries

into a liner if the container doesnt have one so make sure you have a

supply on the vehicle. If it does have one, you may need to replace it when

you remove it and its contents of batteries. Again make sure you carry a

supply.

Check the weight of the batteries as you cant go over the 333kg limit.

You need check that the liner has been tightly closedso the batteries cantjump about inside. If the consignor hasnt done this then you will need to.

The sealed bag needs to be put in the outer drum or box, if it isnt already.

You need to ensure the boxes or drums you put on your vehicle are marked

according to the authorisation i.e. USED LITHIUM CELLS in capital letters

which are a minimum of 12mm high on a contrasting background. Make

sure that the box or drum is tightly packed. This also ensures the batteries

and the liner dont jump about too much whilst your vehicle is on the move.

When you have finished collecting or the 333kg limit has been reached the

batteries need to be taken to the bulk up point. Make sure you empty all the


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boxes/drums containing the waste batteries out of the vehicle as no

batteries must be left in vehicles overnight or taken or left overnight in a

location that is not designed for the collection and storage of large quantities

of waste batteries.

C. If you are the carrier supplying the driver who is going to collect the

batteries:

You may need to ensure your driver has the right boxes/drums on his

vehicle before setting off. In addition that he has a supply of liners and

suitable means of sealing them. It maybe that the consignor has all this in

place so you dont need to do anything except advise the driver only to

pick up batteries that are in the right boxes /drums.

You need to ensure that the driver knows about the 333kg limit anddoesnt exceed it on his vehicle so you need to check and agree with the

consignor how this can be achieved.

It is essential that trainees show they have understood their duties and in thisrespect an assessment should be carried out. Set out below are some test questionsthat could be used.

1. Why are lithium batteries are considered dangerous in transport?

2. What type of liner should the batteries be put in?

3. What words should be marked on the outer drum or box?

4. How big should the letters be?

5. Whats the maximum amount of waste portable batteries that a driver

can carry on his vehicle?

6. Whos responsibility is it to ensure the driver only fills the correctly

marked boxes or drums?

7. A driver finishes his collection round can he take his vehicle home with

the batteries still on board?

8. Whos responsibility is it to ensure the driver has the correctly marked

boxes or drums?

9. Whos responsibility is it to ensure the maximum limit of batteries is not

exceeded.

10. What sort of things can you use to seal the liner shut?


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defra batteries

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