Washing Forklift Batteries and the Law: What You Need to Know

Washing forklift batteries is a simple maintenance task, but like so many warehouse operations, this activity is subject to serious legal regulations. Don’t let that scare you away from the job; washes extend the operating life of your batteries and lift trucks, plus they keep your workplace safer.

But it’s crucial that you obey the law when you wash batteries. There are two major pieces of legislation that govern industrial battery washing, and they’re familiar names for anyone in the warehousing business: The Occupational Safety and Health Act, which includes OSHA regulations, and the EPA’s Resource Conservation and Recovery Act (RCRA).

First, we’ll take a look at the RCRA. An RCRA violation can trigger enormous fines and possibly even criminal charges, so you must follow the law closely. Here’s what you need to know:

• The EPA considers your battery wash water to be potentially hazardous.

  The EPA regulates battery wash water as “hazardous waste,” which makes sense, considering that it almost certainly contains high levels of lead and sulfuric acid. As hazardous waste, your wastewater triggers a number of detailed legal restrictions on handling and disposal.

• The EPA requires a test called the Toxicity Characteristic Leaching Procedure (TCLP) on all potentially hazardous waste — and that includes battery wastewater.

  If, like most of us, you don’t have the equipment or experience to perform the test yourself, you can always hire an independent lab. Battery wash services themselves may be able to provide TCLP analysis, as well.

• Limit your wastewater disposal requirements by creating a closed-loop washing system.

  A BHS Battery Wash Cabinet (BWC) combined with a BHS Wastewater Recycling System (WRS) or Recirculation/Neutralization System (RNS) creates this closed-loop system to greatly limit flushing intervals. The WRS even brings water within legal limits for in-house disposal.

• When the EPA considers multiple entities to be co-generators of hazardous waste, a single party can take full responsibility for compliance with the RCRA.

  This practice allows battery wash providers to visit a site, wash batteries there, then carry away tanks of used wash water for treatment at their own facility. When the visiting company claims responsibility as sole generator, the battery user won’t be held liable for potential RCRA violations.

Before you even get to this point, though, you should be aware of the OSHA regulations that come into play when you wash forklift batteries.

OSHA Compliance During Battery Washes

OSHA maintains strict standards for handling materials related to forklifts, including forklift batteries. To avoid the risk of an OSHA violation, workers need two things: acid-resistant protective clothing and suitable battery handling equipment.

The BHS Personal Protective Kit provides a comprehensive safety solution with an acid-resistant apron, a chemical splash face shield, protective goggles, a pair of HAZ-MAT boots, and a pair of neoprene gloves. This gear complies with OSHA standard 1910.132, which requires employers to provide personal protective equipment when working with “chemical hazards.”

Another standard, 1910.178(g)(4) mandates “material handling equipment...for handling batteries.” BHS provides an extensive line of battery handling devices that comply with this regulation, while greatly increasing operational efficiency.

Complying with the EPA and OSHA may seem like a chore, but it can prevent your company from being slapped with tens of thousands of dollars in fines, possible criminal prosecution, and lost work hours. Keep your procedures in order and only trust the highest quality equipment when washing batteries. Considering the alternative, that’s a small price to pay.

References:

“40 CFR - Protection of Environment.” U.S. Government Publishing Office, n.d. Web. 8 Jan. 2016.

“Hazardous Waste – RCRA Subtitle C.” EPA. U.S. Environmental Protection Agency, n.d. Web. 28 Oct. 2015.

“Personal Protective Equipment - 1910.132.” OSHA. Occupational Safety & Health Administration, United States Department of Labor, n.d. Web 8 Jan. 2016.

“Powered Industrial Trucks - 1910.178.” OSHA. Occupational Safety & Health Administration, United States Department of Labor, n.d. Web. 8 Jan. 2016.