Waste batteries: appropriate measures for permitted facilities

4. Waste storage and handling appropriate measures

The appropriate measures for waste storage and handling at regulated facilities with an environmental permit for the treatment or transfer of waste batteries.

4.1 General waste storage and handling

The following appropriate measures are applicable, where relevant, to the storage of waste batteries and other wastes, including wastes resulting from battery treatment activities.

1. You must have waste storage and handling procedures. You must store and handle waste in a way that makes sure you prevent and minimise pollution risks by using appropriate measures. Waste handling must be carried out by competent staff using appropriate equipment.

2. You should design and operate your facility in a way that minimises the handling of waste, for example, by storing waste in locations that minimise waste handling and using mechanical loading and unloading technologies and conveyors where it is safe and practicable to do so.

3. Where possible, you should locate storage areas away from watercourses and sensitive perimeters (for example, those close to public rights of way, housing or schools).

4. You must store all waste within the secure area of your facility to prevent unauthorised access and vandalism.

5. Where relevant, you must conform to Health and Safety Executive (HSE) guidance and standards, for example:

• HSG51 The storage of flammable liquids in containers
• HSG71 Chemical warehousing: The storage of packaged dangerous substances
• HSG76 Warehousing and storage
• HSG140 Safe use and handling of flammable liquids
• HSG176 The storage of flammable liquids in tanks
• HSG85 Electricity at work: Safe working practices
• HSG258 Controlling airborne contaminants at work: A guide to local exhaust ventilation (LEV)
• INDG139 Using electric storage batteries safely
• L138 Dangerous Substances and Explosive Atmospheres Regulations (DSEAR) Approved Code of Practice

6. You must clearly document the maximum storage capacity of your site and designated storage areas. You must not exceed these maximum capacities. You should define capacity in terms of, for example, maximum tank or vessel capacities, tonnage, numbers of skips, pallets or containers. You must regularly monitor the quantities of stored waste on site and designated areas and check against the allowed maximum capacities. You must also monitor the quantities of relevant wastes against limits set out in your management plans, for example, fire prevention plan.

7. You must clearly mark waste storage areas and provide signs showing the maximum quantity and types of waste (including any hazardous properties) that can be stored there.

8. The design and arrangement of storage areas must provide and maintain appropriate separation distances to prevent fire spreading and access for fire-fighting measures, considering the use of other measures such as fire walls and bays, in accordance with an agreed fire prevention plan.

9. You must maintain adequate access and separation distances between and within storage areas to allow for easy inspection. You must maintain safe access, with a gap of at least 0.7m between rows of containers or palletised wastes.

10. You must not accumulate waste unnecessarily and should prioritise the oldest waste for treatment or transfer. If you accept mixed loads of waste batteries for sorting, they should be moved to a dedicated area of a building and sorted as soon as it is practicable to do so, especially if they contain lithium batteries.

You must treat wastes, or transfer them from your site, as soon as possible and within the timescales provided in the table below. If you have a shorter time period as a permit condition or one is specified in a management plan (for example, your fire prevention plan) you must comply with that condition or plan. Where a waste is stored longer than otherwise allowed you must inform the Environment Agency.

Waste type	Maximum storage duration
Dry cell batteries (including alkaline, zinc-carbon, Ni-Cd, Ni-MH, mercury and silver oxide batteries), excluding lithium, lead acid and electric vehicle batteries	12 months
Lead acid, lithium, electric vehicle batteries, other batteries not listed above, and mixed loads that may contain these batteries	6 months
Other battery wastes (including battery components or fractions, scrap or off-spec products from manufacturers, electrolytes)	6 months

The repackaging or bulking of waste should not change (that is, extend or restart) the maximum duration that it is stored on-site.

11. Up-to-date records must be kept of the on-site storage duration and inventory of waste. Storage duration and inventory should be minimised, for example, by ensuring that they are transferred or treated once a viable load has been established and managed on a first-in first-out basis to prevent the accumulation of aged stock.

12. You must not handle waste or its packaging in a way that might damage its integrity. You must not, for example, walk on, throw or drop waste or waste packages or cause damage from the use of mobile machinery or vehicles.

13. You must train forklift drivers in the handling of palletised goods, to minimise forklift truck damage to the integrity of containers and infrastructure.

14. Storage area drainage infrastructure must:

• contain all possible contaminated run-off
• prevent incompatible wastes coming into contact with each other
• make sure that fire cannot spread

15. You must:

• contain wash waters within an impermeable area and either discharge them to foul sewer under a trade effluent consent or dispose of them appropriately off site.
• prevent run-off into external areas or to surface water drains

16. Any liquids removed from waste must be collected and stored in lidded, leakproof containers or dedicated tanks provided with appropriate secondary and tertiary containment. Containers must be kept closed when not being filled and must be stored within a dedicated area that will contain any leakage or spillage. Containers and tanks must be chemically resistant to the liquids stored in them.

17. Secondary and tertiary containment systems of waste storage areas must conform to CIRIA guidance C736 Containment systems for the prevention of pollution.

18. You must store wastes that are sensitive to air, light, heat, moisture or extreme ambient temperatures under appropriate weatherproof covering protected from such ambient conditions (for example, waste lithium metal must be protected from exposure to water, including the moisture in air or other substances) The type of covering will depend on the types and quantities of waste. It could be as simple as a lid or cover over a container for small items but in other cases may require the construction of a roofed building. Covered areas must have good ventilation. This includes containers:

• held in general storage, reception storage (pending acceptance) or quarantine
• being emptied, repackaged or otherwise managed

For example, waste held in fibre or cardboard primary or secondary packaging must be stored:

• in a cool, dry and well-ventilated area of a building and not exposed to rain or moisture
• be kept off the floor to prevent damage caused by damp

19. Wherever practicable you should store all other wastes under cover. Covered areas must have good ventilation. Under cover storage provides better protection for containers than open air storage and minimises the generation of contaminated water. Covered storage also:

• lowers temperature fluctuations that wastes are subjected to
• reduces the degradation of containers through weathering

20. You must not store hazardous chemical wastes (for example, produced from battery treatment activities) in open-topped containers. Empty open-topped containers should be kept in a building or under cover to prevent rainwater ingress. Wastes that have the potential for self-heating or self-reactivity must be stored in sealed metal containers under cover and monitored for heat build-up.

21. All containers used for the storage and handling of waste must be assessed to ensure they are suitable for the waste stored within them and their intended storage configuration and are used in accordance with the manufacturer guidelines and safe working loads.

21. All waste storage containers and packages must remain fit for purpose and:

• in sound condition
• undamaged
• not corroded
• suitable for the contents (for example, its mass and other physical or chemical properties)
• have well-fitting lids, where relevant
• with caps, valves and bungs in place and secure, where relevant

22. You must check the condition of containers and the pallets they may be stored on as part of routine site inspections and record non-conformances. Non-compliant containers and pallets must be made safe. You must immediately and appropriately manage any unsound, poorly labelled or unlabelled containers (for example, by relabelling, over drumming or transferring the container’s contents). You must risk assess, approve and record the use of storage containers, tanks or vessels:

• beyond their specified design life
• where you use them for a purpose, or substances, other than the ones they were designed for

23. All containers must be clearly labelled with relevant information, including their contents, date of filling or receipt and relevant hazards. They should keep the labelling they had at acceptance unless they have been repackaged and relabelled. If the label is damaged or no longer legible you should replace the label with the same information. You must handle and store containers of waste so that the label is easily visible and continues to be legible.

24. Containers must be held in designated areas of the site marked with maximum stack footprint and minimum separation distances. The containers should be stored in rows and must be arranged in a way that ensures they can be safely and easily accessed for inspection or retrieval at all times without having to move others that may be blocking access, other than those in the same row.

25. All containers must be stored on a pallet (unless they have an integral pallet at the base). Containers of waste that are designed for stacking (for example, heavy duty battery boxes) must not be stacked more than 2.4m high. All other containers must not be stacked more than 1m high. Palletised containers must not be stacked more than 2 pallets high, except for empty containers which can be stacked 3 high.

26. Stacked containers must be stable. They must be secured, for example, with banding or shrink-wrap, if required. The containers must not extend beyond (over-hang) the sides of the pallet. If shrink-wrap is used, it must be clear or transparent so that you can identify waste types, damaged containers, leaks or spillages and incorrectly stacked containers. You must be careful not to damage any packages during stacking.

27. If wastes are stored in flexible intermediate bulk containers (FIBCs) (subject to appropriate measure 8 of section 4.2 ‘Additional measures for the storage and handling of waste batteries’, on this page), they must not be handled or stored in way that could cause damage to the container or its contents (for example, from being dropped, lifted or lowered too quickly, or impacted by machinery or sharp edges) or that would exceed its safe working load or carrying capacity. They must only be moved using equipment designed to lift and handle FIBCs and which do not have any sharp edges or protrusions that could damage the container. They must be stored inside a building (if containing waste batteries) or under cover, and in a cool, dry location away from direct sunlight. All FIBCs must be stored in a way that means they can be accessed safely and easily for inspection or retrieval. They must be inspected regularly to identify and address any signs of damage (for example, including loss of containment, fraying, splits, leaks, or signs of chemical contamination).

28. FIBCs must not be stacked on top of each other unless designed and approved for stacking and they are stacked in a manner that is secure and stable and in accordance with the manufacturer’s guidelines, including safe working loads, and other relevant industry guidance (for example, from the FIBCA and the HSE). FIBCs must not be stacked more than 2 high or if it could cause damage to the containers or their content, including, for example, waste at the base of a container.

29. You must keep incompatible chemical wastes segregated so that they cannot come into contact with one another. You must store flammable wastes apart from other wastes to prevent fire spreading between them and other materials. You must use sealed drainage systems to prevent leaks and spillages contaminating other wastes.

30. You should, where applicable and based on a recorded risk assessment, make inert the atmosphere of tanks containing liquid waste with a flashpoint less than 21°C (for example, tanks containing flammable waste solvents). This can be done, for example, by using nitrogen gas.

31. You should pay particular attention to avoid the build-up of static electricity when you are storing or handling flammable wastes and materials. You should use leak detection systems and alarms (for example volatile organic compound (VOC) alarms) and automatic fire suppression equipment based on a recorded risk assessment.

32. You must not store or hold wastes on site in vehicles or vehicle trailers unless you are receiving them or preparing them for imminent transfer (meaning that you will remove them from site within 24 hours, or 72 hours if over a weekend).

33. Waste storage areas, containers and infrastructure must be subject to daily inspection to make sure that any leaks, spillages of liquids, dust or loose material are identified and managed appropriately, and fire breaks are maintained. You must keep written records of the inspections. You must rectify and log any spillages of waste.

34. Any spillage or leakage resulting from the storage or handling of waste must be collected without delay using equipment and procedures appropriate to the type of spillage. The collected residues must be stored in an appropriate lidded, leakproof container. Any containers or surfaces affected by the spillage must be cleaned. Sand or neutralising granules, or other equivalent materials, must be available to deal with any leaks or spills.

35. You must not carry out activities that represent a clear fire risk within waste storage areas. Examples include:

• hot works, including grinding, welding, or brazing of metalwork, unless risk assessed and approved, for example, under a permit to work scheme
• smoking
• parking normal road vehicles, except while unloading or loading
• pressure washing
• recharging forklift truck or power tool batteries
• recharging or discharging batteries

36. All waste storage areas must have an impermeable surface which is resistant to the materials being stored. Outdoor waste storage areas must have a sealed drainage system to collect all surface water run‑off and channel it to a blind sump unless it may be lawfully discharged. Indoor waste storage areas must be provided with appropriate spillage collection facilities.

37. You must keep clean water (for example, uncontaminated rainwater) separate from wastes and waste waters.

38. You must use weatherproof covering in areas used for the storage of waste containing hazardous material or fluids where this is necessary to avoid contamination of surface water, including, for example, shredded waste or plastic containing fractions that may contain persistent organic pollutants (POPs). The type of covering will depend on the types and quantities of waste but must ensure the waste is protected from the weather. It could be as simple as a lid or cover over a container for small items but in other cases may require the construction of a roofed building.

39. If racking systems are used to store waste, their design and construction must be in accordance with HSG76 Warehousing and storage and consider the need for:

• waste separation and segregation (including separation distances for fire prevention)
• the inspection and retrieval of waste
• fire prevention and suppression measures

Where racking systems are used for the storage of combustible or flammable wastes (for example, Li-ion batteries or wastes resulting from the treatment of Li-ion batteries), they should be made of non-combustible materials, with solid fire-resistant barriers in place to prevent the spread of fire (horizontally and vertically). The use of in-rack sprinkler systems and anti-static measures should also be considered, where appropriate.

40. Bulk storage systems (for example, used for liquids and powders), including tanks and silos, must meet the relevant requirements for Bulk storage provided in section 4 of Chemical waste: appropriate measures for permitted facilities.

41. You must manage waste in a way that prevents pests or vermin. You must have specific measures and procedures in place to deal with wastes that are identified as causing pests or vermin.

4.2 Additional measures for the storage and handling of waste batteries

The following appropriate measures apply to the storage of waste batteries, in addition to the relevant measures from section 4.1 on this page.

1. Where relevant to their role, personnel must be trained in the different types, properties and chemistries of batteries that may be received at the facility, including how they can be identified and the measures that must be taken to ensure they are stored, handled and treated safely.

2. Other than unsorted mixed loads of waste batteries (for example, received from household collections), waste batteries of different chemistry and type should be stored separately from each other, for example, in separate containers and storage areas or bays. As a minimum, separate storage must be provided for lead acid and lithium batteries. You must not mix batteries of incompatible chemistries (for example lead acid batteries with nickel-metal hydride (Ni-MH) batteries) or batteries that have been sorted for treatment or recycling. This includes, for example, storing traction batteries and other large automotive or industrial batteries separately from smaller portable batteries of the same chemistry, or batteries that are known to contain POPs from those that do not.

3. To ensure waste batteries are protected and contained during storage and handling activities, they must be stored and handled in appropriate containers (for example, battery boxes, drums or other suitable packages) that are:

• non-conductive or provided with a non-conductive liner
• protected from static where necessary (for example, if containing, or stored or handled near, Li-ion batteries or other potentially flammable wastes or substances)
• waterproof and weather resistant (unless stored and handled within an enclosed building)
• resistant to chemicals contained in the waste batteries (for example, acids or other corrosive substances)
• leak-proof or provided with a strong, chemically resistant leak-proof liner
• kept closed when not being filled or emptied
• UN-approved, where relevant

Waste batteries must not be stored in cut-off intermediate bulk containers (IBCs) or loose in skips, vehicle trailers or similar large bulk containers.

4. Containers of waste batteries must be stored:

• in well-ventilated designated areas of a building or under weatherproof covering, which provide a dry and cool environment, prevents exposure to extreme temperatures and sources of heat (including direct sunlight)
• away from other relevant hazards, for example, including high voltage cables, transformer cabins, flammable or corrosive gas or liquid tanks, or other storage areas for potentially dangerous materials.

5. If waste batteries are stored under weatherproof covering (including storage tents or similar temporary structures), its design and construction must:

• be appropriate to the waste batteries being stored, considering their type, chemistry, quantity and potential hazards (for example, hazardous chemicals or fire)
• be on level ground with an impermeable surface and sealed drainage
• be secured with appropriate anchoring methods and resistant to weather conditions, for example, including direct sunlight and ultraviolet radiation, strong winds, wind-driven rain, snowfall
• provide protection needed for any sensitive or reactive wastes, for example, providing sufficient shade and thermal insulation for Li-ion batteries
• provide appropriate ventilation, for example, to minimise formation of condensation and aid dispersion of any hazardous gases that may be released from the waste batteries
• keep the storage area dry and prevent the accumulation of water, for example, from rainfall, condensation or surface water
• be subject to regular inspection and maintenance
• comply with building and planning regulations, where relevant

6. Lead acid batteries must be stored upright with terminals capped or insulated. Other batteries should have terminals and any wired connections insulated where possible, particularly lithium batteries and larger batteries and battery packs from waste electrical and electronic equipment (WEEE) and electric vehicles (EVs), and must be packed in a way that prevents shorting or damage, for example, using a suitable packing material, such as vermiculite.

7. Rigid lidded containers must be used for the storage and handling of lithium batteries, wet-cell batteries (including lead acid batteries), other vehicle batteries (for example, including Ni-MH batteries from hybrid vehicles) and unsorted or mixed loads of batteries that may contain these batteries. Such containers should also be used for the storage of other waste batteries where possible to ensure they are stored securely and protected from damage.

8. Flexible IBCs (FIBCs) must:

• not be used for the storage and handling of wet-cell batteries (including lead acid batteries), lithium batteries, vehicle batteries, or other batteries that contain flammable or corrosive substances (unless known to be chemically resistant to them), including unsorted mixed loads and other loads that may contain these batteries
• only be used for the storage and handling of other separate or sorted types of dry-cell waste batteries and following an assessment of their suitability

If other separate or sorted dry-cell batteries are received and stored in FIBCs, they must meet the requirements of appropriate measure 3 above and must be:

• stored inside a building
• stored and handled safely and carefully to protect their integrity and prevent any damage to the container or its contents, for example, from drops, falls or crushing (see appropriate measures 28 and 29 in section 4.2 ‘Additional measures for the storage and handling of waste batteries’ on this page)
• designed to keep their shape and prevent sagging and bulging when filled (for example, FIBCs that use four-panel or baffle construction)
• UN-approved, where relevant

9. Where lithium batteries are stored, these must be recognised as a fire hazard, marked, and stored accordingly. For example, with adequate fire breaks and away from potential ignition sources and other combustible material.

10. Lithium batteries must always be stored and handled with caution and in a way that prevents them from:

• coming into contact with any liquids
• being damaged (for example, dropped, impacted, punctured)
• short-circuiting
• overheating or being exposed to high temperatures

11. Lithium batteries must be stored in rigid lidded containers that are non-conductive or provided with a non-conductive liner. The containers must be kept closed and stored in a dedicated area of a building or under weatherproof covering, in a cool, dry and well-ventilated location, away from sources of heating or ignition and other combustible or flammable materials (for example, including other combustible wastes or packaging materials). The batteries must have terminals or connections insulated to prevent short-circuiting or be separated by layers of vermiculite or other suitable non-conductive and non-combustible packing material. Where possible, and particularly where they are stored in significant quantities, separate collections of Li-ion batteries should be stored and handled in lined UN approved steel drums or other fire-resistant containers designed to minimise the risk of fire propagation. They should also be designed to allow the safe venting of gases that may be released from the waste batteries.

12. Batteries that are too large to be stored in appropriate containers (for example, large battery packs and battery modules from EVs or battery energy storage systems (BESS)), must be stored:

• raised off the floor in a dedicated area of a building (constructed of non-combustible materials) that is cool, dry and well-ventilated
• away from flammable or combustible materials and sources of heat or ignition
• with measures in place to protect the batteries from damage (for example, secure on pallets or in a racking system), short-circuiting (including insulation of terminals) and overheating

They should be stored following manufacturer’s guidelines and remain in the packaging provided for their transportation. They must not be stacked directly on top of each other unless they are designed to be stored in this way. Where possible, prior to storage, large battery packs should be tested and, where necessary, safely discharged to minimise electrical safety and fire risks.

13. Waste batteries must always be handled carefully to prevent damage, for example, from being dropped or other physical impact, particularly during loading and unloading activities and movement around site.

14. Waste batteries must not be tipped from containers (for example, during general storage and handling or bulking and repackaging activities) unless it has been risk assessed (for example, considering the type, chemistry and quantity of batteries) and will be carried out:

• under weatherproof covering or inside a building, and
• in a careful and controlled manner (for example, minimising tipping height and angle) that will prevent causing damage to the batteries and associated risks, including short-circuiting, fire or leakage or loss of materials.

15. Where it is necessary to transfer lead acid batteries from storage containers to a bulk vehicle trailer (or similar bulk transport container), pending imminent transport to an off-site treatment facility (such as a lead smelter), it must meet the relevant requirements of ADR (European Agreement concerning the International Carriage of Dangerous Goods by Road) for bulk carriage and be kept closed or sheeted at all times except during loading or unloading. Transfer of the batteries must be done in a careful and controlled manner to prevent damage and breakage (for example, by minimising tipping height and angle). 

16. Where tipping of waste batteries is necessary at a treatment site (for example, for the loading of a treatment process) and could cause damage, including leakage or loss of battery materials, it must be carried out inside an enclosed building using enclosed plant or equipment with appropriate measures in place to ensure that:

• any materials and liquids released (for example, battery electrolyte or other residues) are collected and contained,
• fugitive emissions to air are prevented or controlled and minimised (for example, through their containment, extraction and abatement),
• other operational risks (for example, fire, electrical hazards, chemical reactions and corrosion) are prevented or minimised

17. You must have procedures and training in place for identifying and managing damaged waste batteries in storage. Damaged waste batteries should be managed in accordance with section 3.2 ‘Waste acceptance’ appropriate measures 15, 16 and 17.

18. You must have procedures and measures in place to promptly identify, manage and, where possible, isolate any overheating Li-ion batteries in a quick and safe manner. Infrared cameras or detectors (fixed or hand-held) should be used to regularly monitor the temperature of Li-ion batteries during storage (including quarantine storage) to identify deviation from the normal expected temperature. Gas detection systems can also provide an early warning of battery thermal runaway and release of associated off-gases.

Particular attention should be given to batteries following handling, repackaging or sorting activities to ensure they are stored and monitored for a sufficient period of time to identify changes in temperature or other signs of heating (for example, releases of gas), for example, before they are moved on to the next stage of the process or transferred off-site.

Other types of waste batteries should also be monitored and managed appropriately where there is a risk of self-heating or overheating.

The method and frequency of monitoring should be informed by risk assessment, for example, considering the type and quantity of waste stored and potential for heating. The completion of these checks must be recorded.

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