Transport Regulations Non-Spillable Lead Acid Batteries

What are the transport regulations for non-spillable lead acid batteries?

There are 2 major types of lead acid batteries, spillable and non-spillable, both are classified as dangerous goods, however their transport regulations are different. There are however some non-spillable batteries that are not a dangerous good but more on this later.

In Australia, the transport requirements for dangerous goods is set out in the “Australian Code for the Transportation of Dangerous Goods by Road & Rail” (ADGC). The National Transport Commission‘s (NTC) maintains and updates the code and a copy of the current edition can be found and downloaded for free at their webpage.

Photo showing bank of sealed lead acid batteries (non-spillable) for solar bank application
Sealed Lead Acid Batteries for Solar Bank

Spillable or flooded batteries have liquid electrolyte and are classified as, “BATTERIES, WET, FILLED WITH ACID, electric storage” referred to as the Proper Shipping Name, in the ADGC, with the corresponding UN Number 2794. For a detailed summary of the transport regulations for spillable (wet) lead acid batteries.

Non-spillable lead acid batteries are often referred to valve regulated lead acid (VRLA) or sealed lead acid (SLA) batteries. They are also sometimes referred to as industrial batteries as they are often used for industrial applications such as solar & UPS backup.

There are two main types of VRLA batteries, absorbent glass mat (AGM) and gel cell. The majority are classified as “BATTERIES, WET, NON-SPILLABLE, electric storage”, referred to as the Proper Shipping Name with the corresponding UN Number 2800.

ADGC Packing Instructions for Non-Spillable Lead Acid Batteries

The ADGC Packing Instruction P003, specifies the packing requirements for transporting these batteries. Below is an excerpt of this packing instruction showing the requirements that are applicable to non-spillable batteries.

   P003                                                                            PACKING INSTRUCTION                                                                            P003  
Dangerous goods must be placed in suitable outer packagings. The packagings must meet the provisions 4.1.1.1, 4.1.1.2, 4.1.1.4, 4.1.1.8 and 4.1.3 and be so designed that they meet the construction requirements of 6.1.4. Outer packagings constructed of suitable material, and of adequate strength and design in relation to the packaging capacity and its intended use, must be used. Where this packing instruction is used for the transport of articles or inner packagings of combination packagings the packaging must be designed and constructed to prevent inadvertent discharge of articles during normal conditions of transport.

 Special packing provisions:

PP16 For UN 2800:

(a) batteries must be protected from short circuit within the packagings

Unless you are remarkably familiar with the ADGC the above packing instruction probably isn’t going to make much sense. So, what does it mean? Batteries are defined as an article under the ADGC, so the requirement is essentially “the packaging must be designed and constructed to prevent inadvertent discharge of articles during normal conditions of transport”. Thus, the use of wood pallets & crates (defined as an overpack in the ADGC) and plastic bins would all be acceptable options.

What are the other ADGC requirements?

When transporting Non-spillable batteries other ADGC requirements such as labelling, dangerous goods documentation, load restraint, emergency information and vehicle placarding, have to also be met. These are similar to the requirements for spillable or flooded batteries, classified as “BATTERIES, WET, FILLED WITH ACID, electric storage” UN Number 2794 under the ADGC.

You can find here a detailed summary of the transport requirements for spillable lead acid batteries.  The Proper Shipping Name and UN Number should be substituted where appropriate.

How do I determine if my battery is non-spillable?

The simplest method is to examine the labelling on the battery itself. You should find somewhere word to the effect “non-spillable” “seal lead acid battery” “seal valve regulated lead acid battery” “valve regulated”. If you are still unsure consult the battery manufacture’s safety data sheet.

When is a non-spillable battery not a dangerous good?

So, when is a non-spillable battery not classified as a dangerous good? Firstly, batteries must pass a vibration and pressure test to be classified as a non-spillable battery. These requirements are laid out in the ADGC under the UN Special Provision 238. This provision includes an additional test to determine that there will be no free flow of the electrolyte at 55 degrees C, from a rupture or cracked battery case.

If the battery has passed this test, it is not classified as a dangerous good and hence its transportation is not covered by the provisions of the ADGC. The simplest way to determine if your battery has met this requirement is to refer to the manufacturer’s safety data sheet. Which should include a section titles “Transport Information”, where you will find if the battery has been classified as a dangerous good, UN Number 2800 “BATTERIES, WET, NON-SPILLABLE, electric storage”.

What other regulations control the transport of non-spillable lead acid batteries?

Used or waste Lead acid batteries are classified as a hazardous and controlled waste in most States. Regulations governing the transport of hazardous waste have been enacted by each State or Territory. These controlled hazardous waste regulations do not distinguish between different types of lead acid batteries. In other words, all lead acid batteries are a controlled hazardous waste.

You can find the link to your state or territories hazardous waste regulations.

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