How and why is Tier II reporting applicable to batteries?

Owners or operators of facilities storing lead-acid batteries are required to determine whether Tier II reporting thresholds are exceeded for batteries stored at their facility. The chemicals of concern are lead and sulfuric acid. It is important to note that sulfuric acid is also an EHS and the reporting threshold is 500 lbs. Lead is a hazardous substance and the reporting threshold is 10,000 lbs.

Although it would appear that a manufactured battery would meet the definition of an exempt “article,” OSHA specifically excluded lead-acid batteries from the Article Exemption in a 1997 letter from the Acting Director of the Office of Health Compliance Assistance to the Texas Department of Health. The Deputy Project Director stated that, “Because - workers service batteries, which leads to exposure - an MSDS would be required and the facility owner or operator would need to report the sulfuric acid at 500 pounds, the lead at 10,000 pounds, and any other chemicals to which the worker is exposed to at the applicable threshold.”

The following information is necessary in completing this Tier II report (image).

As facility owners or operators, you must survey all facility equipment and systems containing reportable batteries to determine whether the reporting thresholds are exceeded for the total weight of pure sulfuric acid and the total weight of lead contained in all of the reportable batteries on site.

To determine if the thresholds are exceeded, you will need to know the type of batteries and then consult your Discover dealer. If you do not know the model number of the batteries or you can not contact a dealer, then you must estimate the weight of batteries and then multiply this by 18% (a battery is estimated to contain 18% of its weight as pure sulfuric acid) and this will provide the estimated total weight of pure sulfuric acid at your facility.

Note that if the threshold is exceeded at any time during the year, you must report the materials that exceed the threshold on a Tier II by March 1 of the following year.

Companies in the United States of America should visit the following web site for more information on Tier II reporting:
Chemical Name                                     Lead                                   Sulfuric Acid
EHS                                                            No                                            Yes
CAS No.                                           007439-91-1                             07664-93-9
Reporting Threshold                        10,000 lbs.                                 500 lbs.
Pure or Mixture                                       Pure                                      Mixture
Physical State                                        Solid                                       Liquid
Physical or Health Hazard   Delayed Health Hazard         Immediate Health Hazard

http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/lr-other.htm