Lead acid batteries must be transported in accordance with various federal & state regulations including dangerous goods, hazardous waste, road transport and workplace safety. The road transport requirements for New & Used Lead Acid Batteries is very similar except in addition to being a dangerous good, used lead acid batteries (ULAB) are also classified as a Hazardous Waste.
If you are conducting a business or undertaking at a workplace whereby you are a consignor of either new or used lead acid batteries, then you need to ensure that when you or your subcontracted transport company are complying with these regulations. Many companies are unaware of all the regulatory requirements controlling lead acid batteries and the “Duty of Care” and “Chain of Responsibility” provisions which can make Companies and its Executives personally liable.
Below I have provided a general guide which hopefully will fast track your research and understanding of the regulations that govern the safe and regulation compliant transportation of used lead acid batteries.
Follow this link, if you are more concerned with lead acid battery storage regulations.
If you are looking for a “regulation compliant”, safe and environmentally sustainable battery collection and recycling service, please visit our home page
So What Are The Various Regulations Governing the Transportation of Lead Acid Batteries?
Firstly I am going to assume that your business / organisation does not directly transport the lead acid batteries yourselves and that you have engaged a third party to do this. From a regulation perspective this makes you the consignor.
I am also going to assume that you are not having used batteries transported interstate to a battery recycler and receiving payment from the recycler. If you are you will need to be aware of the national agreement that controls movement of controlled waste, such as used lead acid batteries, between states. I am not going to cover this here but if this is relevant please refer to “Useful Links Regarding New & Used Lead Acid Battery Transport Regulations” section below.
The key regulations that govern the transport of both new & used lead acid batteries, include;
- The Australian Dangerous Goods Code (ADG Code), specifically the “Australian Code for the transportation of Dangerous Goods By Road and Rail”, sets out the requirements for transporting dangerous goods by road or rail. The code has been implemented in each State and Territory’s dangerous goods transport laws. The local transport laws provide important information such as supply chain member duties, including consignors, licensing requirements, penalties and competent authority panel powers. Further details can be found here on the National Transport Commission’s website. These regulations apply to both new and used or waste lead acid batteries.
- Regulations for the transport of regulated or hazardous waste within your state. These regulations only apply to waste or used lead acid batteries. Unfortunately there is no national regulatory model for the transportation of hazardous waste and consequently each state has it’s own set of regulations. While they have many similarities they are also different. The controlled waste regulations will usually be incorporated within your State’s environmental regulations. You can find links to this, in the section below, “Useful Links Regarding New & Used Lead Acid Battery Transport Regulations”.
- National Transport Commission‘s “Heavy Vehicle National Law”. The HVNL, is currently in force in Queensland, New South Wales, Australian Capital Territory, Victoria, Tasmania, and South Australia. The HVNL is underpinned by four regulations:
- Heavy Vehicle (General) National Regulation
- Heavy Vehicle (Fatigue Management) National Regulation
- Heavy Vehicle (Mass, Dimension and Loading) National Regulation
- Heavy Vehicle (Vehicle Standards) National Regulation
Further details can be found at NTC’s website. Western Australia & the Northern Territory haven’t implemented the HVNL and use their own heavy vehicle transport regulations.
What are the Australian Dangerous Good Code requirements for transporting lead acid batteries?
You can download the current version of the ADG Code from the “Useful Links For Used Battery Transport Regulations” below. See Chapter 4.1.4 for a list of Packing Instructions including P801 for used lead acid batteries, Chapter 5.2 for Marking & Labeling requirements for Packages, Chapter 5.3 Placarding and Marking of Transport Units and Part 8 for Stowage & Restraint requirements.
Packaging Requirements for New & Used Lead Acid Batteries when using a wood pallet
The Packaging Requirements for new and used lead acid batteries are contained in the ADG Code’s P801 Packing Instruction.
In 2017, the Australian Battery Recycling Initiative (ABRI) published the following recommended best practices, when using wood pallets to transport used batteries “Guidance for packing used lead acid batteries for recycling”. The Australian Battery Recycling Initiative (ABRI) was formed by a group of battery manufacturers, recyclers, retailers, government bodies and environment groups to promote the collection, recycling and safe disposal of all batteries.
If you are using wood pallets, referred to as an overpack in the ADG Code, then your packaged automotive batteries should appear like the example below;
What are the alternatives to using a wood pallet?
Frankly at Battery Rescue we are not big fans of wood pallets for the transport of used batteries. Yes we have a vested interest with our collection service that uses the purposely designed Battery Transport & Storage Container, however we have very good reasons for believing that wood pallets should not be used when transporting used batteries. See our article “Why the Wood Pallet should be banned for Used Lead Acid Battery Storage & Transport”.
What are the packaging requirements if I am using a steel or plastic box?
The ADG Code’s P801 Packing Instruction includes a clause “Used storage batteries may also be transported loose in stainless steel or plastics battery boxes capable of containing any free liquid”. This is provided they meet the provision 4.1.1, except 184.108.40.206, and 4.1.3 in the ADG Code. There is some debate as to whether the P801 Addition Requirements apply for used lead acid batteries when transported using these methods. This is due to the contradiction between Additional Requirements 2 & 4 and the definition of “transported loose”. Most Australian companies do not apply the additional requirements when transporting used batteries in containers or boxes.
In recognition of the ambiguity caused by the inclusion of this clause and the impractical and unnecessary “Additional Requirements” for this mode of transport, the European’s adopted a new packing instruction, specifically for transporting used batteries in stainless steel or plastic battery boxes and removed this clause from the P801 instructions. The new P801a packing instructions were included in the European Agreement for the International Carriage of Dangerous Goods by Road (ADR) and came into effect in 2011.
The P801 Packing Instruction is being reviewed by the UN Committee for Dangerous Goods in June 2018, with the view to clarify this issue. These changes if passed will possibly be updated in future versions of the ADG Code.
What are the Controlled Waste requirements for transporting waste / used lead acid batteries?
As mentioned previously regulations governing the transport of hazardous waste have been enacted by each State or Territory as part of their Environmental regulations. You will need to review the regulations specific to you state, which you can find links to this in the section below, “Useful Links Regarding New & Used Lead Acid Battery Transport Regulations”.
In general these regulations will require that you only use a transport company that has a controlled waste license for used lead acid batteries. The provisions of a waste carrier license typically includes requirements such as;
- Marking the vehicle with the appropriate controlled waste signage.
- Vehicle must carry the appropriate spill containment equipment.
- Have an emergency response plan for the Driver
- Use of suitable containers to prevent leakage of fluid and waste into the environment (doesn’t that rule out wood pallets for transporting batteries?)
What are the common examples of non compliant used battery transportation?
The most common compliance breaches that we have identified are:
- Failing to adequately wrap and strap the batteries when using wood pallets.
- Failing to use a 30mm, non conductive separator between each layer of batteries, as required when using an over-pack such as wood pallets.
- ULAB container / over-pack not labelled as “Class 8 Corrosive”.
- ULABs not packed adequately (e.g. loose batteries on a pallet or truck tray).
- Non-existent primary restraint of pallets onto the vehicle .
- Sides and gates not utilised for secondary restraint.
- Absence of transport documentation detailing quantity and type of dangerous goods.
- Placard load requirements ignored – segregation, safety equipment & placarding.
- Operators carting ULABs without the state / territory controlled waste licence.
Below are some examples on non-compliant waste / used lead acid battery transport
Hopefully I have helped you on your journey to understanding your obligations with regards to regulation compliant transportation of lead acid batteries. If you have any questions you can contact me on 0414 646 321.
Please note that the information I have provided here is general in nature. Companies must do their own research to understand their legal obligations in each jurisdiction and to ensure that they are fully compliant with transportation regulations for new & used lead acid batteries.
Useful Links Regarding New & Used Lead Acid Battery Transport Regulations
- Century Batteries, Safety Data Handling Sheet for Lead Acid Batteries.
- Australian Code for the transportation of Dangerous Goods By Road and Rail, edition 7.5 (ADGC) – See Chapter 4.1.4 for a list of Packing Instructions including P801 for batteries, Chapter 5.2 for Marking & Labeling requirements for Packages, Chapter 5.3 Placarding and Marking of Transport Units and Part 8 for Stowage & Restraint requirements. The ADGC includes the P801 Packing Instruction for new and used lead acid batteries.
- Each State or Territories Environmental Protection Regulations stipulate requirements for transporting and disposing of controlled hazardous waste, such us used / waste lead acid batteries, and the waste holder’s obligations. You can find the link to your state or territories hazardous waste regulations here.
- The interstate transportation of ULAB is governed by a national agreement, National Environmental Protection (Movement of Controlled Waste Between States And Territories) Measure, which is administered by State Environmental Authorities.
- The National Transport Commission‘s (NTC) “Heavy Vehicle National Law” and look up your State’s implementation (not applicable for WA and NT).