Recycle Your Batteries: It’s the Law

By complying with the Battery Act, health care organizations can avoid hefty fines by ensuring that batteries are properly recycled.

Every year batteries are being used in more applications in the hospital. Used batteries pose a threat to our environment and their disposal should be managed properly.

The Battery Act
To prevent the release of hazardous substances into the environment, the Battery Act (The Mercury-Containing and Rechargeable Battery Management Act) was signed into law by President Clinton on May 13, 1996. The law serves two purposes: 1) to phase out the use of mercury in batteries and 2) to provide for the efficient and cost-effective collection and recycling or proper disposal of used nickel cadmium (Ni-Cd) batteries, used, small sealed lead acid (SSLA) batteries, and certain other regulated batteries.

Among other requirements, the Battery Act also establishes national, uniform labeling requirements for regulated batteries and for rechargeable consumer products that are manufactured domestically or imported and sold for use in the United States.

Almost 80% of municipal solid waste is either landfilled or incinerated. Neither of these methods are suited for the disposal of rechargeable batteries. In landfills, heavy metals from rechargeable batteries can leach slowly into the soil and ground and surface waters. Eventually they can make their way into the food chain and cause serious health consequences. When incinerated, the heavy metals can enter the air through smokestack emissions and can concentrate in the ash produced by the combustion.

Recycling programs for Ni-Cd and SSLA rechargeable batteries can significantly reduce the dangers these batteries pose to human health and the environment by diverting them from landfills and incinerators. Once the rechargeable batteries arrive at the recycling facility, the heavy metals are recovered and the remainder of the product is recycled or discarded safely.

Certificate of Reclamation: Essential Proof
The Environmental Protection Agency (EPA) can issue orders to violators of the Battery Act. The orders can assess a civil penalty of not more than $10,000 for each Battery Act violation. The agency can also impose a $10,000 penalty for failure to take timely corrective action required under an order. A certificate of reclamation should be available from a certified waste handler or recycler. This certificate is essential proof that fully documents the processing and handling of each battery shipment. Hospitals are urged have these certificates of reclamation on file, in the event that the EPA reviews the hospital’s site and program.

There are many benefits for a hospital once it starts or improves its current battery recycling program. Some of these include:

    •    compliance with current local, state, and federal (EPA) regulations;
    •    reduced costs, labor, and paperwork through a formal program;
    •    limited or reduced exposure to potential liabilities; and
    •    the opportunity to set a positive example in the community for promoting a safe and healthful environment.

 

 

Starting a Program at the Hospital
The first step in establishing a program is to evaluate the current costs and methods being used. An often-overlooked solution is the use of a centralized procurement system. Many hospitals end up purchasing from a variety of sources. Centralized purchasing from one or two key battery vendors can minimize waste from overpurchasing or shelf-life expiration. This is a form of source reduction that can be key to pollution prevention. Often there are additional benefits, including volume discounts and discounts on shipping costs. Some questions to ask when evaluating costs:

    •    What fees and costs are you currently paying to dispose and recycle your batteries?
    •    What are the quantities and types (by chemistry) of batteries being purchased and eventually disposed?
    •    Are hospital staff being used to transport and deliver batteries off-site?
    •    How can these costs be minimized or eliminated?

The second step in setting up the program is selecting a recycling company. This company should be a certified waste handler that is contracted with an EPA-approved treatment storage disposal facility (TSDF). Ask the company if it has the required permits or state certificates. What types of batteries will it accept? (Not all companies will accept all battery chemistry types.)

The third step is procuring and setting up collection containers. Determine how many collection containers you will need. Will you have a central collection and storage area, or will you have multiple locations? Will your recycling company allow you to collect batteries in an all-in-one container, or will you be required to sort each battery by chemistry into separate containers. It is important to know that many companies require the batteries to be sorted and will charge high fees to sort batteries. Does your hospital have staff with the time and knowledge to correctly sort these batteries? Can the collection container also serve as a shipping container? A shipping container must be approved by the Department of Transportation to be used to ship batteries to a recycling company.

The fourth step is to gain employee participation. A successful battery recycling program will involve teamwork in all areas of the hospital. The program should be easy to learn and use. Perhaps start in one area of the hospital—like the biomedical department—first; then expand the program to other areas of the hospital as the program is successfully implemented.

The decision to start or improve a hospital recycling program is an economically and environmentally sound decision.

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Charles E. Vorwaller is vice president of sales at Access Batteries Inc in Elizabeth, Colo.