Most batteries meet the definition of dangerous waste, but when they are properly recycled, they are minimally regulated by the dangerous waste regulations. Mercury, lead, cadmium, and sulfuric acid can leak from batteries and pose environmental risks when they are improperly stored or disposed of. Specific rules apply for the types of batteries you handle.
Your business can manage batteries as universal waste. WAC 173-303-573, the universal waste rule, makes it easier to recycle and properly dispose of this common dangerous waste stream.
- Lead-acid batteries may use these guidelines. If you have lead-acid batteries, you may manage them as universal waste, or you can follow the special requirements for reclaiming spent lead-acid battery wastes (see below).
- You cannot put batteries in your curbside recycling bin.
Why manage batteries as universal waste or under the lead-acid battery exclusion?
For businesses, there are many benefits to managing your batteries under one of these regulations:
- They do not count toward your generator status.
- You may not need to report them on your dangerous waste annual report.
- You do not need a manifest for off-site shipment.
- You do not need a RCRA Site Identification number for off-site shipment.
- You can self-transport to an appropriate receiving facility.
Remember, non-recycled or mishandled batteries are a dangerous waste and are subject to dangerous waste regulations.
Universal waste rule for batteries
The universal waste rule can apply to all batteries that are dangerous waste. It is your responsibility to designate your batteries and determine if they are a dangerous waste. Homeowners are not required to manage their batteries as universal waste, but are strongly encouraged to take them to a household hazardous waste collection facility instead of throwing them away.
What kind of batteries can I manage as universal waste?
- Lead acid
- Button cell mercuric oxide
- Silver oxide
- Zinc air
Miniature batteries used in numerous products like toys, hearing aids, watches, calculators, and other portable devices can also be managed this way. You may also manage consumer products with difficult-to-remove batteries as universal waste.
Label, mark, and store
Label individual batteries or containers of universal waste batteries with one of the following phrases:
- "Universal waste – batteries"
- "Waste batteries"
- "Used batteries"
Mark with the date batteries were first placed in the collection container. You can accumulate batteries for up to one year from the date they are generated.
Store damaged or leaking batteries in closed containers.
If you meet the requirements of the lead-acid battery exclusion, you do not need to obtain a RCRA Site ID number, and you do not need to count the weight of the batteries towards dangerous-waste accumulation totals. However, you must follow these practices:
- Batteries must be recycled. Disposal is not an option.
- Follow proper storage and handling guidelines.
- Batteries must be protected from spillage and stored safely.
- Batteries must be stored on-site.
Find out more about the special requirements for reclaiming spent lead acid battery wastes.