Resource Conservation and Recovery Act Compliance for Forklift Fleets

What does your forklift fleet have to do with federal waste disposal laws? It could be more than you think. If you run a fleet of electric forklifts, you probably also follow a detailed maintenance plan for your batteries.

That plan should include regular washing, and the water you use to wash your batteries is a form of hazardous waste. In 1976, Congress passed the Resource Conservation and Recovery Act; that law has a lot to say about how you deal with your battery wastewater. Here are the basics.

  • The RCRA considers waste to be "hazardous" if it has certain characteristics, including ignitability, corrosivity, reactivity, and/or toxicity. It's that last one that forklift fleet managers should be concerned about. Water picks up excessive amounts of lead and sulfuric acid on contact with forklift batteries; used wash water is almost certain to meet the EPA's definition of hazardous waste.

  • If two or more parties have equal responsibility for the creation of hazardous waste, the EPA considers them co-generators, with one exception: If one of the entities agrees to take the full responsibility of a generator, the EPA will recognize that designation.

  • Under Subtitle C of the RCRA, the EPA limits the volume of hazardous waste that can accumulate at a facility, as well as the length of time waste can sit untreated. If your plan is to fill up that empty storeroom with barrels of contaminated water and deal with them next year, it's time for a new plan.

  • The EPA's "Cradle-to-Grave" system tracks hazardous waste from its moment of generation, through transportation, treatment, and disposal. The RCRA established precise regulations for each step of the process, and the generator remains responsible for the ultimate fate of the harmful substances. When multiple co-generators contribute to the production of hazardous waste, the EPA can hold them all responsible unless one of the parties claims the role of sole generator.

  • A number of RCRA standards only apply to facilities that create more than 220 lbs (100 kg) of hazardous waste per calendar month. Smaller forklift fleets may not use that much water for battery washing — but even light producers of hazardous waste are required to provide proper treatment on- or off-site.

RCRA Compliance With On-Site Water Treatment

One of the best ways to ensure RCRA compliance when you dispose of forklift battery wash water is to install a BHS Wastewater Recycling System (WRS). In addition to allowing you to purify wastewater on-site, purchase of the WRS includes free lab testing and documentation to make sure that liquid waste is ready for disposal. That improves safety for the groundwater and your company's bottom line.

Upon installation, specialists research your municipality's specific allowable levels for the contents of your used wash water to guarantee that your WRS is configured to meet all local regulations, as well as the rules set out by the RCRA. For reliable RCRA compliance, the WRS delivers clean results.


RCRA Orientation Manual 2014.” EPA. U.S. Environmental Protection Agency, 2014. PDF. 28 Oct. 2015.