There are several regulations that govern the storage & transport of new and used or waste lead acid batteries in Australia. In general, these regulations are enacted at the state level, however increasingly many of these are based on National Model Laws & Regulations, so that there is a degree of national harmonisation that has been achieved.
Lead acid batteries are classified as a dangerous good while used or waste batteries are also classified as a hazardous waste. Below is an overview of the Australian regulations for their safe storage and transport by road & rail.
Lead Acid Battery Storage Regulations
In recent years most Australian states and territories have transitioned away from maintaining their own Work Health & Safety (WHS) Laws and Regulations and have adopted the Model WHS laws developed by Safe Work Australia in 2011. The model WHS laws have been developed to create a level of standardisation of WHS laws between states and territories. Western Australia is the only state to date that is yet to adopt the Model WHS Laws.
It is up to each state and territory to enact the laws and hence they are responsible to regulate and enforce the laws.
For NSW & Queensland, the WHS Regulations are the primary set of regulations that govern the handling and storage of dangerous goods such as lead acid batteries. While other states such as SA, Victoria, WA also maintain separate Dangerous Goods (Storage and Handling) Regulations. If you are in these states, you will need to reference both the WHS and Dangerous Goods (Storage & Handling) regulations.
You can readily find and download a copy of these regulations for your state using a search term such as “WHS Regulation {your state}” and “Dangerous Goods Storage and Handling Regulations {your state}”.
WHS Regulations (all states except WA)
There are several Chapters that that are relevant for new & used lead acid battery storage and handling requirements. These include:
- Hazardous Work, subsection “4.2 Hazardous Manual Tasks”. Due to the weight of batteries often exceeding the recommended lifting weight of 20kg, appropriate lifting precautions need to be considered.
- General Workplace Management, subsection “Hazardous Atmospheres” – Lead acid batteries, particularly new batteries, when under charge, are a potential ignition source, so appropriate steps must be taken to eliminate this risk.
- Hazardous Chemicals, contains several subsections that are relevant, including:
- Obligations relating to safety data sheets and other matters
- Register and manifest of hazardous Chemicals
- Placards
- Control of risk—obligations of persons conducting businesses or undertakings
- Health monitoring
- Induction, information, training and Supervision
Dangerous Goods (Storage & Handling) Regulations
NT, SA, Victoria & WA, currently maintain separate regulations for the storage and handling of dangerous goods. These regulations will usually include a test as to whether a site is a “small quantity dangerous goods location” or “dangerous goods site”. A “Dangerous Goods Site” must apply and be granted a license. The test criteria will be based on the volume of battery acid present* at your site plus the presence of other dangerous goods.
As a rule of thumb if the acid volume is not known, usually the case for used batteries, a nominal figure of 25% of the gross weight of the batteries may be used. For example 1000kg of batteries would contain approximately 250L of acid.
Hazardous Waste Storage Regulations
Waste or used lead acid batteries are also classified as a Hazardous (controlled waste) in every State. Unfortunately, there is no National Model Laws, and each state has developed their own regulations. This is painful if you are business with outlets in several states as the requirement do vary.
To find the regulations relevant for you state search for “Hazardous Controlled Waste Regulation {state}”.
Without having completed an assessment of each State and Territory’s regulations, under most State’s environmental regulations it’s an offence to allow hazardous waste (e.g. acid) to discharge into the environment. To prevent this Used Lead Acid Batteries should be stored in a bunded area or container and preferably undercover.
Lead Acid Battery Transport Regulations
The main regulation that governs the movement of new and used lead acid batteries are the “Australian Code for the transportation of Dangerous Goods By Road and Rail”, (ADGC). In addition general load restraint and heavy vehicle laws also apply and for waste or used batteries, State controlled hazardous waste regulations apply. A summary of these regulations can be found below:
Australian Code for the transportation of Dangerous Goods by Road and Rail (ADGC)
The ADGC sets out the requirements for transporting dangerous goods by road or rail. The code is maintained and updated by the National Transport Commission‘s (NTC) however each State has incorporated the ADGC as part of their own dangerous goods transport regulations. This means the general requirements, such as packaging, labelling, DG documentation and Vehicle placarding, are the same for transporting lead acid batteries in each state.
The State Dangerous Goods transport regulations will vary with regards to requirements such as supply chain member duties, licensing requirements and penalties.
The transport requirements for lead acid batteries were updated in the ADGC in October 2020. The changes adopted those approve by the UN Sub-Committee of Experts on the Transport of Dangerous Goods, in June 2018. For a detailed summary of the ADGC’s lead acid battery transport regulations.
Load Restraint Requirements
The National Transport Commission, develop the 2018 Load Restraint Guide, which provides the basic safety principles for the safe carriage of loads. The guide includes how to meet the performance standards for vehicle load restraint. Any person or organisation involved in packing, loading, moving or unloading a vehicle, are responsible for complying with the load restraint laws.
Note: Western Australia and Northern Territory’s Heavy Vehicle laws currently reference the NTC’s Load Restraint Guide 2004.
Heavy Vehicle National Law (NVNL)
The NVNL applies to heavy vehicles over 4.5 tonnes for most Australian States & territories. The exceptions are NT and WA. The NVHL contains 4 sets of regulations, General, Fatigue Management, “Mass, Dimension & Loading”, Vehicle Standards.
“Chain of Responsibility” provisions, mean that Consignor’s and it’s executives can be held legally liable, for failure to meet the requirements of the NVNL. Western Australia & the Northern Territory heavy vehicle regulations also include similar Chain of Responsibility provisions.
For vehicles less that 4.5 tonne gross mass, these provisions don’t apply however the load restrain requirements do.
Hazardous Waste Transport Regulations
As a controlled hazardous waste, each Australian State and Territory has developed regulations for the transport of waste or used lead acid batteries. The regulations unfortunately vary in each state so organisations with premises in multiple states need to be deal the specifics of each state’s regulations.
Some of the provisions that are typically common to all states, include:
- The provider used to transport the used batteries must have a controlled waste license for used lead acid batteries. Note there are different controlled waste license for different types of waste, so the license must be for used lead acid batteries.
- 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.
If you are also wanting to transport waste or used lead acid batteries interstate their transport will be governed by the “National Environmental Protection (Movement of Controlled Waste Between States And Territories) Measure” which has been enacted in each State. The NEPC is designed to ensure the interstate transport of controlled wastes is handled in environmentally sound ways.
Uniseg Products have designed and developed a collapsible, plastic container for the storage and transport of used lead acid batteries. The Container is marketed as the Battery Transport & Storage (BTS) Container and is patented or patent pending in a number of countries. The BTS Container delivers a safer, more convenient alternative while reducing the environmental impact of storing & transporting used lead acid batteries.
