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Waste batteries: appropriate measures for permitted facilities

From:
Environment Agency
Published
21 May 2026
Updated:
21 May 2026 - See all updates

2. General management appropriate measures

The appropriate measures for the general management of a regulated facility with an environmental permit for the treatment or transfer of waste batteries.

2.1 Management system

  1. You must have and follow an up-to-date, written management system. It must incorporate the following.

You must have:

  • management commitment, including from senior managers
  • an environmental policy that is approved by senior managers and includes the continuous improvement of the facility’s environmental performance

You must plan and establish the resources, procedures, objectives and targets needed for environmental performance alongside your financial planning and investment.

You must implement your environmental performance procedures, paying particular attention to:

  • staff structure and relevant responsibilities
  • staff recruitment, training, awareness and competence
  • communication (for example, of performance measures and targets)
  • employee involvement
  • documentation and records
  • effective process control
  • maintenance programmes
  • the management of change (including legislative changes and waste classification changes)
  • emergency preparedness and response
  • making sure you comply with environmental legislation

You must check environmental performance and take corrective action paying particular attention to:

  • monitoring and measurement
  • learning from incidents, near misses and mistakes, including those of other organisations
  • records maintenance
  • independent (where practicable) internal or external auditing of the management system and operations to confirm it has been properly implemented and maintained

Senior managers must review the management system at least annually to check it is still suitable, adequate and effective.

You must review the development of cleaner and more efficient technologies and their applicability to site operations.

When designing new plant, you must make sure that you assess the environmental impacts from the plant’s operating life and eventual decommissioning.

You must consider the risks a changing climate poses to your operations. You must have appropriate plans in place to assess and manage future risks.

You must compare your site’s performance against relevant sector guidance and standards on a regular basis, known as sectoral benchmarking.

You must have and maintain the following documentation:

If required, you must have and maintain the following documentation:

2.2 Staff competence

  1. Your site must be operated at all times by an adequate number of staff with appropriate qualifications and competence.

2. The design, installation and maintenance of infrastructure, plant and equipment must be carried out by competent people.

3. You must have appropriately qualified managers for your waste activity who are either:

4. Non-supervisory staff must be reliable and technically skilled in the activities they are responsible for and in emergency response procedures. Their skills may be based on experience and relevant training.

2.3 Accident management plan

  1. As part of your management system you must have a plan for dealing with any incidents or accidents that could result in pollution.

2. The accident management plan must identify and assess the risks the facility poses to human health and the environment. Particular areas to consider may include:

  • waste types and the risks they pose
  • robust waste acceptance procedures to avoid receiving unwanted waste types
  • transferring substances, for example filling (including overfilling) or emptying of vessels and containers
  • preventing incompatible substances coming into contact with each other
  • failure of plant and equipment (for example, storage tanks and pipework, blocked drains, over-pressure of vessels)
  • failure of containment (for example, bund failure, or drainage sumps overfilling)
  • damaged batteries, for example, lithium-ion batteries and fire risk
  • making the wrong connections in drains or other systems
  • failure to contain firefighting water
  • failure of abatement systems
  • hazardous atmospheres in confined spaces
  • failure of main services, for example, loss of power or water
  • checking the composition of an effluents before their emission
  • vandalism and arson
  • operator error
  • accessibility of control equipment in emergency situations
  • extreme weather conditions, for example, flooding or very high winds

3. You must assess the risk of accidents and their possible consequences. Risk is the combination of the likelihood that a hazard will occur and the severity of the impact resulting from that hazard. Having identified the hazards, you can assess the risks by addressing 6 questions:

  • how likely is it that the accident will happen?
  • what may be emitted and how much?
  • where will the emission go – what are the pathways and receptors?
  • what are the consequences?
  • what is the overall significance of the risk?
  • what can you do to prevent or reduce the risk?

4. In particular, you must identify any fire risks that may be caused, for example by:

  • damage, shorting or over-heating of batteries
  • self-combustion, for example, from the self-heating of lithium batteries (thermal runaway), the finer fractions of shredded materials and their residues,
  • arson or vandalism
  • plant or equipment failure and electrical faults
  • naked lights and discarded smoking materials
  • hot works (for example welding or cutting), industrial heaters and hot exhausts
  • neighbouring site activities
  • sparks from metal machinery or equipment, for example, forklifts or loading buckets
  • hot loads deposited at the site

You must have a fire prevention plan that identifies the risks at your site and meets the requirements of our fire prevention plan guidance.

5. The depth and type of accident risk assessment you carry out will depend on the characteristics of the activities undertaken, including their location and any plant or equipment involved. The main factors to consider include:

  • scale and nature of the accident hazards presented by the activities
  • risks to the environment, including human health (the receptors)
  • nature and complexity of the activities undertaken, including plant and equipment involved
  • the availability of appropriate risk control techniques and measures

6. Through your accident management plan, you must also identify the roles and responsibilities of the staff involved in managing accidents. You must provide them with clear guidance on how to manage each accident scenario, for example, whether to use containment or dispersion to extinguish fires, or let them burn.

7. Your facility must have an emergency co-ordinator who will take lead responsibility for implementing the plan. You must train your employees so they can perform their duties effectively and safely and know how to respond to an emergency.

8. You must also:

  • establish how you will communicate with relevant authorities, emergency services and neighbours (as appropriate) both before, during and after an accident
  • have appropriate emergency procedures, including for safe plant shutdown and site evacuation
  • have post-accident procedures that include assessing the harm that may have been caused by an accident and the remediation actions you will take
  • consider the impact of accidents on the function and integrity of plant and equipment
  • have contingency plans to relocate or remove waste from the facility, and suspend incoming waste
  • test the plan by carrying out emergency drills and exercises

9. Your accident management plan must identify and assess the risks the facility poses from the storage or treatment of waste batteries, including but not limited to:

  • risks associated with the different types or chemistries of batteries that may be received
  • storage and handling of any damaged batteries
  • potential short-circuiting of batteries
  • any charging or discharging of batteries undertaken at the site
  • storage and handling of any wastes or residues resulting from the treatment of batteries (for example, battery electrolyte, black mass, plastics, metals)

2.4 Accident prevention measures

  1. You must take the following measures, where appropriate, to prevent events that may lead to an accident.

Segregating waste

2. You must keep incompatible wastes apart. This includes, for example, keeping damaged batteries away from other batteries or wastes, storing batteries of different chemistries separately once sorted from mixed loads (for example, in separate containers), segregating batteries that have been tested or discharged from those awaiting testing or discharging.

Preventing accidental emissions

3. You must make sure you contain the following for off-site disposal or route to the sealed drainage system as appropriate:

  • process waters
  • site drainage waters from operational areas
  • emergency firefighting water
  • oil or chemical contaminated waters
  • spillages, for example, of oils and chemicals

4. You must be able to contain surges and storm water flows. You must provide enough buffer storage capacity to make sure you can achieve this. You can define this capacity using a risk-based approach, for example, by considering the:

  • nature of the pollutants
  • effects of downstream waste water treatment
  • sensitivity of the receiving environment

5. You can only discharge waste water from this buffer storage after you have taken appropriate measures, for example, to control, treat or reuse the water. Discharges to ground, surface water or sewer must be lawful and must comply with any consents or permissions that are required.

6. You must have spill contingency procedures to minimise the risk of an accidental emission of raw materials, products and waste materials, and to prevent their entry into water.

7. Your emergency firefighting water collection system must take account of additional firefighting water flows or firefighting foams. You may need emergency storage lagoons to prevent contaminated firefighting water reaching a receiving water body. This should be considered as part of your fire prevention plan.

8. You must consider and, if appropriate, plan for the possibility that you need to contain or abate accidental emissions from:

  • overflows
  • vents
  • safety relief valves
  • bursting discs

If this is not advisable on safety grounds, you must focus on reducing the probability of the emission.

Security measures

9. You must have security measures in place (including staff) to prevent:

  • entry by vandals and intruders
  • damage to plant and equipment
  • theft
  • fly-tipping
  • arson

10. Facilities must use an appropriate combination of the following measures:

  • security guards
  • total enclosure (usually with fences)
  • controlled entry points
  • adequate lighting
  • warning signs
  • 24-hour surveillance, such as closed-circuit television (CCTV)

Fire prevention

11. There are 3 fire prevention objectives. You must:

  • minimise the likelihood of a fire happening
  • aim for a fire to be extinguished within 4 hours
  • minimise the spread of fire within the site and to neighbouring sites

12. You must have a fire prevention plan that meets the requirements of our fire prevention plan guidance.

13. In accordance with our fire prevention plan guidance, you must maintain appropriate separation distances between and within waste battery storage areas to prevent a fire from spreading. You must also maintain appropriate separation distances between combustible or flammable wastes (including waste batteries and other wastes in containers) and, where relevant:

  • potential sources of ignition (for example, naked flames, space heaters, furnaces)
  • the site perimeter, waste quarantine or isolation areas, any buildings, or other combustible or flammable materials

Separation distances will depend upon the nature and quantity of wastes stored and may be reduced by using fire walls, bays or other physical barriers if they provide sufficient fire resistance.

14. Areas where waste batteries are stored, handled or treated must be provided with appropriate fire detection and suppression systems. Selection and location of appropriate fire detection systems and fire-fighting materials, methods and equipment should be based upon a site-specific fire risk assessment and consultation with the local fire and rescue service. Fire detection and warning systems (for example, using smoke, gas, heat or thermal detectors), must be appropriately designed, tested and maintained to provide early detection and alarm.

A wide range of potential firefighting substances and methods are available (for example, using water, foam, gas, sand, aqueous vermiculite, vermiculite fire blankets, sprinklers, deluge systems, water cannons, portable fire extinguishers, or a water-filled container for the submersion of batteries). The most appropriate method of fire suppression is likely to depend on a range of factors, including the type and quantities of batteries or other combustible or flammable materials involved and the location and scale of the fire. One of the primary aims should be to prevent a fire from spreading and escalating to other waste batteries and combustible wastes or materials stored on-site, for example, by preventing heat transfer or through cooling.

British Standard ISO3941:2026 classifies fires by the nature of the fuel, including category Class L for lithium-ion battery fires. Reference to this standard may be useful when considering equipment for fire protection and firefighting.

Where Li-ion batteries are stored, appropriate gas detection systems may help to provide an early warning of battery thermal runaway and release of associated off-gases. The gases released from Li-ion batteries can be heavier or lighter than air and therefore high- and low-level gas detection should be considered. The potential reignition of fires involving lithium batteries should also be considered in fire risk assessments.

15. All fire detection, suppression and fighting equipment must be subject to regular inspection, testing and maintenance in line with the recommendations of the equipment manufacturer and installer. You must keep records of their inspection, testing and maintenance.

Other accident prevention measures

16. You must maintain plant control in an emergency using one or a combination of:

  • alarms
  • process trips and interlocks
  • automatic systems
  • manual interventions

17. You must:

  • make sure all the measurement and control devices you would need in an emergency are easy to access and operate in an emergency situation
  • maintain the plant so it is in a good state through a preventive maintenance programme and a control and testing programme
  • use techniques such as suitable barriers to prevent moving vehicles damaging equipment
  • have procedures in place to avoid incidents due to poor communication between operating staff during shift changes and following maintenance or other engineering work
  • where relevant, use equipment and protective systems designed for use in potentially explosive atmospheres

18. Areas of the site where explosive atmospheres could occur must be assessed and, where appropriate, classified into hazardous zones in line with the Dangerous Substances and Explosive Atmospheres Regulations (DSEAR) and, where necessary, marked with signs at their points of entry and on relevant site plans. Plant and equipment used in these zones must be ATEX compliant and operated by appropriately trained staff.

Record keeping and procedures 

19. You must:

  • keep an up-to-date record of all accidents, incidents, near misses, changes to procedures, abnormal events, and the findings of maintenance inspections
  • carry out investigations into accidents, incidents, near misses and abnormal events and record the steps taken to prevent their reoccurrence
  • maintain an inventory of substances, which are present (or likely to be) and which could have environmental consequences if they escape – many apparently innocuous substances can damage the environment if they escape
  • have procedures for checking raw materials and wastes to make sure they are compatible with other substances they may accidentally come into contact with
  • make sure that any documents that may be needed in the event of an incident are accessible

2.5 Contingency plan and procedures

  1. You must have and implement a contingency plan and management procedures to make certain you comply with all your permit conditions and operating procedures during maintenance or shutdown at your site.

2. Your contingency plan must also contain provisions and procedures to make sure that you:

  • do not exceed storage limits in your permit and you continue to apply appropriate measures for storing and handling waste
  • stop accepting waste unless you have a clearly defined method of recovery or disposal and enough permitted storage capacity
  • as far as possible, know in advance about any planned shutdowns at waste management facilities where you send waste

Your contingency plan must include plans and procedures for circumstances where you cannot send your wastes to other sites (including exports to sites outside of the UK) due to their planned or unplanned shutdown.

3. If you produce an end-of-waste material at your facility, your contingency planning must consider issues with storage capacity for end-of-waste products and materials that fail end-of-waste specification.

4. You must make your customers aware of your contingency plan, and of the circumstances in which you would stop accepting waste from them.

5. You must consider whether the sites or companies you rely on in your contingency plan:

  • can take the waste at short notice
  • are authorised to do so in the quantities and types likely to be needed – in addition to carrying out their existing activities

6. Where circumstances mean you could exceed your permitted storage limits or compromise your storage procedures, you must look for alternative disposal or recovery options. You must not discount alternative disposal or recovery options based on extra cost or geographical distance.

7. You must not include unauthorised capacity in your contingency plan. If your contingency plan includes using temporary storage for additional waste on your site, then you must:

  • make sure your site is authorised for this storage
  • have the appropriate infrastructure in place

8. Your management procedures and contingency plan must:

  • identify known or predictable malfunctions associated with your technology and the procedures, spare parts, tools and expertise needed to deal with them
  • include a record of spare parts held, especially critical spares – or state where you can get them from and how long it would take
  • have a defined procedure to identify, review and prioritise items of plant which need a preventative regime
  • include all equipment or plant whose failure could directly or indirectly lead to an impact on the environment or human health
  • identify ‘non-productive’ or redundant items such as tanks, pipework, retaining walls, bunds, reusable waste containers (for example wheeled carts), ducts, filters and security systems
  • make sure you have the spare parts, tools, and competent staff needed before you start maintenance

9. Your management system must include procedures for auditing your performance against all these contingency measures and for reporting the audit results to the site manager.

2.6 Plant decommissioning

  1. You must consider the decommissioning of the plant at the design stage and make suitable plans to minimise risks during later decommissioning.

2. For existing plant, identify potential decommissioning risks and take steps to address these. Make changes and design improvements as and when plant is upgraded, or when construction and development works are carried out at your site. Examples of design improvements could include avoiding using underground tanks and pipework. If it is not economically possible to replace them, you must protect them by secondary containment or a suitable monitoring programme.

3. You must have and maintain a decommissioning plan to demonstrate that:

  • plant will be decommissioned without causing pollution
  • the site will be returned to a satisfactory condition

4. Your decommissioning plan should include details on:

  • whether you will remove or flush out pipelines and vessels (where appropriate) and how you will empty them of any potentially harmful contents
  • site plans showing the location of all underground pipes and vessels
  • how asbestos or other potentially harmful materials will be removed, unless we have agreed it is reasonable to leave such liabilities to future owners
  • methods for dismantling buildings and other structures, and for protecting surface water and groundwater during construction or demolition at your site
  • any soil testing needed to check for any pollution caused by the site activities, and information on any remediation needed to return the site to a satisfactory state when you cease activities, as defined by the initial site condition report
  • the measures proposed, once activities have definitively stopped, to avoid any pollution risk and to return the site of operation to a satisfactory state (including, where appropriate, measures relating to the design and construction of the plant)
  • the clearing of deposited residues, waste and any contamination resulting from the waste treatment activities

5. You should make sure that equipment taken out of use is decontaminated and removed from the site.

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