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Advisory Note on the storage and transport


of waste portable batteries

Version 1
July 2009

Storage and transport of portable batteries

TableofContents
Part 1 - Introduction ......................................................................................................... 3
Part 2 Duty of Care and Waste Carrier Registration ..................................................... 4
Part 3 Environmental Permitting ................................................................................... 6
Part 4 Carriage of Dangerous Goods ........................................................................... 6
Part 5 - Hazardous Waste ............................................................................................... 9
Part 6 Safe Storage of Batteries ................................................................................. 14
Part 7- Scotland and Northern Ireland ........................................................................ 156
Part 8 - Practical Examples:
Back Hauling................................................................................................ 17
In store take-back........................................................................................ 19
Postal Returns............................................................................................. 19
Annexes ....................................................................................................... 20
Authorisation 214 for the transport of up to 333kg of waste portable
batteries.......................................................................................................... 20
Mock Consignment Note................................................................................. 21
General Awareness Training for the handling of waste portable batteries..... 23

Part1Introduction
1. The Waste Batteries and Accumulators Regulations 2009 came into force
on 5th May 2009. These regulations will lead to an increase in the
collection of waste portable batteries for recycling very few are collected
currently. From 1 February 2010, retailers who sell 32kg or more of
portable batteries in a year will have to accept waste portable batteries
back from members of the public. There are also likely to be collections in
public buildings, such as libraries. This means that people who have not
previously been involved in storing and transporting waste (used batteries
are classified as waste) will be in the future.
2. We (Defra) organised a workshop on 13th May 2009 to help those
collecting batteries under the new system understand the range of
legislation which applies to this activity. The main areas are the controls on
Hazardous Waste and the movement of Dangerous Goods. The
presentations from the 13th May workshop are online at:
http://www.defra.gov.uk/environment/waste/topics/batteries/batteriesimplement.htm
3. The aim of this document is to summarise the information presented at the
workshop and to help those storing and transporting waste batteries
understand what they must do to comply with current legislation. We hope
that it will be of particular interest to those who were unable to attend the
workshop.
4. This note does not replace existing guidance on the individual pieces of
legislation and those who require more detail should refer to that guidance.
However, the note summarises the various requirements and points to
where more detailed help can be found. It covers the first part of the
collection system, from collection points (i.e. where the end-user disposes
of the batteries for recycling) to the bulking-up point or waste treatment
facility (if the waste is transported there directly). The note covers the
position in England and Wales and summarises the different rules applied
in Scotland and Northern Ireland.
5. For more detail on the Waste Batteries and Accumulators Regulations
2009, please refer to:Guidance note on the Batteries Regulations
http://www.berr.gov.uk/files/file51268.pdf
The Environment Agencys battery pages
http://www.environment-agency.gov.uk/business/regulation/101529.aspx
3

Who should read this note?


6. This note will be of interest to anyone who stores waste batteries after they
have been deposited by end-users, transports the waste batteries or
receives them at a bulking-up point, Civic Amenity Site or treatment
facility.
Why does Hazardous Waste and Dangerous Goods legislation apply to
batteries?
7. Members of the public will return waste batteries of mixed sizes and
chemistries (e.g. alkaline, lithium, nickel cadmium, nickel metal hydride,
etc.). The battery chemistry cannot be identified simply from the shape or
size of a battery.
8. For instance, some AA batteries have an alkaline chemistry whilst others
may be of lithium or nickel cadmium chemistries. Batteries containing
lithium are classified as dangerous under the Carriage of Dangerous
Goods Act, while nickel cadmium batteries meet the definition of
hazardous under the Hazardous Waste Regulations.
9. Dangerous goods (not just waste) are those that pose a risk to people,
property and the environment. These types of goods can range from those
that are obviously dangerous (such as explosives, flammables and fuming
acids) to everyday products such as paints, solvents and pesticides found
in the home and at work. When transported, these goods need to be
packaged correctly as laid out in the various international and national
regulations for each mode of transport to ensure that they are carried
safely to minimise the risk of an incident.
10. As Dangerous Goods, lithium batteries can normally only be transported
by road and sea under certain restrictions. Transport of lithium batteries by
air is banned. To help the collection of waste batteries, the Department for
Transport has introduced simplified rules for the transport by road of up to
333 kilogrammes of mixed waste batteries. There is more information on
this in Part 4 of this note.
11. Hazardous waste 1 has properties that may make it harmful to human
health or the environment. The EU has legislation on:

the management of hazardous waste (Directive 91/689/EEC);and


the definition of hazardous waste the List of Wastes Decision
(Commission Decision 2000/532/EC as amended).

In Scotland, hazardous waste is referred to as special waste.

12. The Hazardous Waste Directive will be replaced by the revised Waste
Framework Directive in December 2010, however, the new Directive
contains many similar provisions.
13. Hazardous waste regulations and their equivalent in Scotland are enforced
by the environment agencies. Further details can be found on the
agencies websites:Environment Agency for England and Wales: (http://www.environmentagency.gov.uk/business/topics/waste/32180.aspx),
Scottish Environment Protection Agency (SEPA) in Scotland:
(http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx )
Northern Ireland Environment Agency in Northern Ireland: (http://www.nienvironment.gov.uk/wasthome/regulation/regulations_hw.htm )
14. Not all batteries fall under these classifications (hazardous and
dangerous). The most popular type of portable battery Alkaline - is not
classed as hazardous or dangerous. However, a container full of mixed
waste batteries is almost certain to contain a small proportion that are
deemed to be dangerous and/or hazardous. Therefore all mixed waste
batteries must be transported and stored appropriately. Anyone
considering separating out lithium and nickel cadmium batteries (and this
is not an easy task, even for experts) should bear in mind that, when
concentrated, lithium batteries present a greater risk than when dispersed
among other batteries and the controls on movement are more stringent.
Consideration should therefore be given to whether it is easier to keep
waste batteries mixed.

Part2DutyofCareandWasteCarrierRegistration
What is the Duty of Care?
15. If you are in possession, or have control of waste, you have a legal 'Duty
of Care' to store it safely without causing pollution or harm and to only
transfer it to someone who is legally allowed to take it. The Duty of Care
applies to everyone who handles waste; from the person who produces
the waste to the person who finally recycles or disposes of it. The Duty of
Care is one of the main ways to combat flytipping.
16. If you are responsible for controlled waste (all batteries are likely to fall
within this definition) you must ensure that the waste is stored safely,
managed properly, recovered or disposed of safely, does not cause harm
to human health or pollution of the environment, is only transferred to
someone who is authorised to receive it and, when transferred, is
5

described in sufficient detail to allow subsequent holders to handle it


safely.
Waste Carrier Registration
17. If you intend to carry waste produced by others you must be registered as
a Waste Carrier with the relevant environment agency. At present this
registration costs 152 (157 in Scotland and 120 in Northern Ireland) for
the first three years and 102 (108 in Scotland and 60 in Northern
Ireland) for renewals. Renewals last for three years. Carrying waste
without a relevant authorisation is an offence.
18. Following a review of the waste carrier system conducted last year, it is
possible that businesses who only carry waste they produced themselves
will, in the future, have to register with the Environment Agency. If and
when the registration system changes, the requirements will be
communicated to businesses. We consulted on these proposals in June
2008:
http://www.defra.gov.uk/environment/waste/legislation/duty.htm#12
19. In practical terms, the person who has delivered waste batteries to a
collection point is the waste producer, so even under the current
regulations all movement of waste batteries from a collection point must
be made by a registered waste carrier. From time to time, you will be
asked by those responsible for the collection point for proof that you are
properly registered.
20. As well as being registered, you must carry the waste correctly and deliver
it to someone allowed to take it. So, when delivering the waste batteries,
the collector should make sure that the site is authorised to take them. In
most cases, this will mean that the site has an environmental permit or is
covered by a properly registered exemption (see below).

Part3EnvironmentalPermitting(EnglandandWales)
(seePart7forScotlandandNorthernIrelandrequirements)
21. Under existing regulations, all collection points for waste batteries must
have an environmental permit but the Environment Agency has adopted a
low risk waste position which covers portable battery collection points
accessible to the public. Low risk waste positions (in this case LRW 006)
reflect the environmental risk posed by certain activities that do not
currently benefit from an exemption from permitting.

22. LRW 006 allows the storage of up to 80kg of waste dry cell batteries
(portable batteries), provided that the operator (e.g. retailer, person in
charge of waste in a school, public building etc.) ensures that the activity
does not cause pollution or harm to human health. It requires no
notification and involves no fee.
23. This will only apply until February 2010 for retailers and April 2010 for
other collection points. From 1 February 2010 there will be a formal
exemption from the need for an environmental permit for retailers and any
other distributors of portable batteries who are obliged to provide takeback facilities (that is, those selling 32kg of batteries or more per year).
24. Defra plans to introduce in April 2010 an exemption from environmental
permitting for other battery collection points (e.g. those in public buildings).
25. Collection points other than those which are accessible to end users, such
as bulking-up points 2 , will also benefit from an exemption from
environmental permitting the details of the exemptions are being
developed as part of the review of waste permitting exemptions.

Part4CarriageofDangerousGoods
26. This section assumes that you are transporting less than 333 kilogrammes
of used portable cells or batteries. If so you can benefit from the special
provisions the Department for Transport have put in place for such cases.
27. Carriers and drivers must be able to assess whether the amount of used
cells or batteries they are carrying will exceed that amount. If you carry
more than 333 kilogrammes you will need to comply with the full ADR
regulations.
Who needs to comply with the Dangerous Goods legislation (ADR)
28. ADR identifies 3 roles:

The Consignor is the person consigning the used cells or batteries for
transport i.e. whoever collects and stores batteries (e.g. retailer, someone in
a public building, school etc).

Batteries can be stored at a bulking point for a period of up to 6 months after which they will need to
be moved to a Treatment Facility.

The Carrier is the person that collects the used cells or batteries from the
Consignor and packs them appropriately for transport. ADR has a role for the
packer as well, i.e. the person ensuring that the used cells or batteries are
packed and put in appropriate containers ready for their transport. However,
in practice the carrier and the packer are the same person. Often these
functions are covered by the Driver.
The Driver is the person that drives the vehicle which will take the used cells
or batteries to the intermediate bulking- up point.
29. When the collection box is full, the operator of the collection point - the
Consignor - will arrange to have it collected by a carrier.
30. The Consignor must ensure that those used cells or batteries are taken
away from the premises by a trained Carrier. The Consignor must be
aware of the correct way of packing the used cells or batteries so that
when the collector comes to take them away he/she can be satisfied that
the Carrier is properly trained. The packing requirements are
straightforward and are explained in the following section.
31. The Consignor, Carrier and the Driver need to receive training to ensure
that they know their responsibilities. The training, which can be with a
trainer or through written guidance, should also be straightforward. An
example of the type of written guidance that could be used is at Annex 3.
When training is complete, the consignor will needs to keep the guidance
or another document certifying that he/she received the training and this
needs to be kept for 3 years for inspection.
32. The training needs to be done every three years.
33. Once correctly packed, the Driver will take the load to a bulking-up point or
treatment facility. No Dangerous Goods can be kept in a vehicle overnight
so all waste batteries must be taken to such a place by the end of the day.
This means that if a driver has several pick-ups to undertake he must
complete them all within one day and get the batteries to a bulking-up
point or treatment facility before the end of that day.

How to pack and transport waste portable batteries


Authorisation 214
34. To help encourage the collection of used cells or batteries for recycling
while continuing to manage the risks posed by lithium batteries, the
Department for Transport have issued an authorisation permitting the
transport of used cells or batteries from consumer collection points to the
8

bulk up point by road without the need to comply with the FULL ADR
regulations. These provisions, which apply until 30 June 2015, are
contained in the Department for Transports Authorisation 214 which is
available at:- http://www.dft.gov.uk/426155/425450/300/auth214.pdf
The Authorisation requires that:
35. The lithium cells or batteries shall be packed with other battery types (i.e.
mixed with other chemistries, so lithium-only loads are not permitted under
Authorisation 214) in a closed plastic liner within a metal or plastic drum or
box to prevent undue movement. Each plastic liner shall only be used
once.
36. Each drum or box shall be marked on the outside with the words USED
LITHIUM CELLS in capital letters which are a minimum of 12mm high on a
contrasting background.
37. The maximum total quantity of mixed used cells or batteries per transport
unit shall not exceed 333kg.
38. All personnel involved in the transport of the cells or batteries must
undergo appropriate general awareness training commensurate with their
responsibilities.
39. The 333 kg limit applies to the weight of all the used cells or batteries not
just lithium ones i.e. you must not carry mixed batches of used cells or
batteries weighing more than 333 kg. If you wish to carry more than 333kg
then you will have to comply with the full ADR regulations.
40. Finally, as already covered, all parties involved need to undertake general
awareness training. This can be given by a trainer or by providing written
guidance. A copy of the general awareness training (see Annex 3) must be
kept for a period of 3 years.
Special cases
41. The transport of lithium batteries by air is banned. As it will not be possible
to identify which are lithium batteries and which are not, you should not
transport used cells or batteries by air. Consignment by sea would need to
comply with the requirements in the International Maritime Dangerous
Goods (IMDG) code. In view of the air restrictions and the full
requirements of ADR and IMDG Code, the Department for Transport does
not recommend that you use postal returns as it would be too difficult in
practice to comply with the legislation.

Part5HazardousWaste
Consigning the waste
42. This section covers the regulations which apply in England and Wales to
track hazardous waste from where it is disposed of to where it is treated.
As explained earlier, mixed loads of batteries are considered to be
hazardous waste.
43. There is a slightly different system in Scotland where hazardous waste is
referred to as special waste and in Northern Ireland.
44. SEPA has produced guidance on consigning special waste which is
available on the SEPA website:http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx
45. The NIEA has produced guidance on consigning hazardous waste which is
available on the NIEA website:http://www.ni-environment.gov.uk/wastehome/regulation/regulations_hw.htm
46. A consignment note needs to be completed for each batch of waste batteries
being moved. A standard consignment note is made up of five parts, each
must to be completed by a specific person acting under a specific role, in a
similar way to the ADR regulations.
47.

Figure 1 A consignment note divided into 5 parts.


(N.B.This is a diagrammatic representation. See Annex 2 for a more realistic sample).

48. The roles are as follows:


- Producer
- Carrier
- Consignee
10

49. Under the batteries regulations a producer is the person who puts batteries
on the market. However, in the context of the hazardous waste
regulations, a Producer is the operator of the first premises collecting the
waste batteries (e.g. retailers, public buildings, etc), with the exclusion, as
always, of domestic premises. All premises in England and Wales where
more than 500kg of hazardous waste is collected (or produced) per year
(apart from domestic waste from domestic premises) must be notified to
the Environment Agency.(This is not the case for premises located in
Scotland or Northern Ireland). Information on how to notify premises can
be found on the Agency website at:http://www.environment-agency.gov.uk/business/topics/waste/32198.aspx.
50. We expect that many battery collection points will collect less than 500 kg
of batteries and other hazardous waste and therefore will not have to be
notified. However, please note that the 500kg limit includes all hazardous
waste collected at the premises, not just batteries So, for example, if your
premises collects 100 kilogrammes of batteries and 450 kilogrammes of
other types of hazardous waste (for example, CRT televisions if you are an
EEE retailer), you will need to complete a notification.
51. The Carrier is the person collecting and transporting the hazardous waste
(e.g. collecting from a store).
52. The Consignee is the person receiving the waste (e.g. the operator of a
bulking up point). They will, in turn, be the Producer for any onward waste
movement, for example where hazardous waste is moved from a bulkingup point to a treatment facility. (NB A bulking-up point will almost certainly
have to be notified as a site where hazardous waste is produced).
53. The consignee (if located in England or Wales) must make quarterly
returns to the Environment Agency of the amount of hazardous waste they
have received in the format specified by the Agency. This will include a
summary of every consignment received at their site. The Environment
Agency makes a charge of 10 per quarterly report for dealing with this
information. For waste originating from Scotland or Northern Ireland the
consignee is required to send a copy of the completed consignment note
to SEPA or NIEA respectively. The Consignee must also make quarterly
returns to producers to confirm receipt of the waste.
54. Each person must fill-in the relevant section of a consignment note and
keep a copy of it.

11

Single and Multiple collections Consignment Notes


55. Consignment notes can be of two types, either for single journeys or
multiple journeys. For collections from premises in England and Wales the
consignment note can be downloaded free of charge from the Environment
Agencys website:http://www.environment-agency.gov.uk/business/topics/waste/32196.aspx, or
if you prefer, you can print your own, provided they contain space for all the
required information.
56. In Scotland and Northern Ireland consignment notes must be purchased
from the respective Agencies. For details of fees in each jurisdiction and
guidance on the completion of consignment notes please see websites:
http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx
and
http://www.ni-environment.gov.uk/wastehome/regulation/regulations_hw.htm
57. In the case of a single journey, there is one producer (usually also the
consignor), one carrier and one consignee. This will happen when a
vehicle is sent out to collect from one collection point and to transport the
batteries to a bulking-up point or treatment facility.
58. It is much more common that a vehicle will collect from a number of
collection points. For such multiple collections, there will be a number of
producers, but only one carrier and one consignee. Guidance on
consignment notes for multiple collections in England and Wales is at:http://www.environment-agency.gov.uk/static/documents/GEHO0507BMSJ-ee.pdf
59. To simplify the job for all parties involved, consignment notes can be preprinted with any information which does not change from one trip to the
next. This only applies to England and Wales. They can also be completed
electronically see:http://www.environment-agency.gov.uk/business/topics/waste/34867.aspx .
Life of a Consignment Note
60. The responsibility for filling-in the consignment note starts with the
producer of hazardous waste (e.g. retailer) although in practice this is
often done by the carrier (the producer must still sign it as being correct).
The producer (or the carrier on their behalf) must complete parts A, B and
D and retain a copy.
61. On collection, the collector must complete part C and take the batteries to
the consignee. He retains part C and the consignee fills out part E and
keeps a copy and gives a copy to the carrier. The consignee will return a
12

fully completed copy of the consignment note to the producer. and the
NIEA or SEPA for waste arising in Northern Ireland or Scotland
respectively.
62. The Environment Agency has further guidance on using consignment
notes in England and Wales that can be found at:http://www.environment-agency.gov.uk/hazwaste
.

13

Figure 2 Life of a consignment note


Source: Environment Agency

Waste Carrier
Household

Separately collected
domestic fraction no
consignment notes required
Consignment
note required

Household

Carriage of
Dangerous
Goods applies

Carrier Register
Must store carrier copies of note
at principal place of business for
one year.

Carrier
registration
required

Destination
Site
(consignee)

Collection Point
(Haz waste Producer)
Consignee must send Producer
Return. Either copy of consignee
consignment note OR Quarterly
return from from Regs.

Household
Premises Notification
Required if 500kg+ of more of
all hazardous waste produced
in any 12 month period at that
premises.

Producer Register
Must store producer copies of
consignment notes, and
producer returns from
consignee for 3 years.

Site Register
Must store consignee copies of
consignment notes for waste
received.

Hold at notified premises.

Must also store their outgoing


producer notes and producer
returns from final disposal site.

If exempt hold at principal


place of business OR each
producer can ask the EA to
agree to let them hold it in
another place.

Duration depends on activity, but


will be a minimum of three years.
(see guidance)

14

Site Return to EA
Provide Quarterly returns
to EA.
Specific guidance on
reporting of battery
movements reduces
associated charges.

Part6SafeStorageofBatteries
63. There are no specific health and safety requirements for storing batteries,
but normal health and safety rules apply. This includes that the responsible
person should assess health and safety risks. In a workplace, the
responsible person is the employer or person who occupies or owns the
premises. In all other premises the responsible person will be the person
or people in control of the premises.
64. Health and Safety Executive considers the risks from storing small
quantities of portable batteries to be very low if sensible common sense
precautions are taken. But these should be taken into account in a
businesss health and safety risk assessment.
The five steps of risk assessment
65. The basic five steps in a risk assessment are:a. Identify the hazards. The hazards from batteries are mainly leakage of
chemicals and fire.
b. Identify the people at risk if there is an incident. This may include both
people who use the premises and those nearby. Particular attention
should be paid to people who may be especially at risk such as:
employees who work alone, e.g. cleaners, security staff;
unaccompanied children and young people;
people who are unfamiliar with the premises, e.g. visitors;
customers; and contractors.
people with disabilities or those who may have some other
reason for not being able to leave the premises quickly;
and
people with language difficulties.
c. Evaluate the risk to people if an incident occurs and take any
necessary measures to ensure the risk to their health and safety is as
low as is reasonably practicable. The specific circumstances will dictate
the appropriate measures to prevent or reduce the risk of an incident,
but for batteries may include:
Using a collection box which limits the size of objects that
may be inserted and minimises the possibility of leakage;

Locating the collection box where it can be readily


monitored;
15

To regularly check the contents of the collection box and


move to a secure and safe storage area when deemed
necessary;

To locate collection boxes where they are unlikely to be


exposed to fire or sources of heat; interfere with normal
access routes, or emergency escape routes.

d. Prepare a plan and provide instruction and training of what to do in the


event of an incident. This should include who is to inform the
emergency services if necessary.
e. If you employ five or more people, the significant findings of the risk
assessment should be recorded in compliance with other Health and
Safety (and Fire Safety) Legislation.
f. Keep the assessment under review and revise where necessary; for
example, if conditions change, or following an incident to prevent
recurrence.

Part7ScotlandandNorthernIreland
This section explains the main differences between the regulations in England and
Wales compared to those in Scotland and NI.

Scotland
Waste Management Licensing
66. Paragraph 17 of Schedule 3 to the Waste Management Licensing
Regulations 1994, as amended, provides an exemption for battery
collection points. This can be registered on-line through the SEPA website
and is free of charge:
http://www.sepa.org.uk/wmxreg/pages/welcome.aspx
67. It covers the storage of up to 5 cubic metres of mixed municipal batteries
for up to 12 months in a secure place.
Special Waste
68. The main differences between the system in England & Wales and in
Scotland are:
-

producers do not need to register as producers of special waste


all movements of special waste must be prenotified, except successions
and movements of only lead acid batteries.

16

69. The consignment note system is similar in Scotland with a similar five part
note to be completed for each movement. SEPA has produced guidance
on consigning special waste which is available on the SEPA website:
http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx

Northern Ireland
Waste Management Licensing
70. Regulation 16A of the Waste Management Licensing Regulations
(Northern Ireland) 2003 (as amended) provides an exemption for battery
collection points where collection point is a place where end users are
able to deposit waste portable batteries or accumulators , i.e. the premises
of a distributor, thus fulfilling its duty of care take back responsibilities.
71. Collection points other than those which are accessible to end users such
as a bulking-up points, will be required to register for an exemption under
paragraph 52 of Schedule 2 to the Waste Management Licensing
Regulations (Northern Ireland) 2003 (as amended). The exemption, which
presently has an annual fee of 530, will allow up to 5 tonnes of
automotive batteries and accumulators and 10 tonnes for portable
batteries and accumulators to be stored for a period of up to 6 months
after which they will need to be moved to a Treatment Facility.
Hazardous Waste
72. Similar to the system in Scotland, hazardous waste producers are not
required to register with the NIEA. All movements, with few exceptions,
must be pre notified prior to movement with the NIEA.

Part8PracticalExamples
73. This section provides some examples of how businesses could carry out the
storage, collection and transport of batteries in compliance with the
regulations referred to in this guidance. These examples must not be read in
isolation, but together with the rest of this note as there are cross-references
to the relevant parts of the guidance.
Back Hauling
Back-hauling is the transport of batteries within an existing supply chain via the
suppliers vans or lorries. In other words, the same vehicles that deliver goods will
take away the waste batteries deposited in the store.

17

1) Batteries are safely collected in the store see Part 6 for advice on how to
assess that you are collecting safely.
2) The company delivery lorry comes the driver has received awareness
training on handling lithium batteries in accordance with Authorisation 214 and
has a document confirming this in the lorry.
3) The retailer will also have received the training so that they can assess that
the batteries are packed correctly for transport. They will also have a signed
document to show that they have done the awareness training. NB This will
last 3 years. (See Part 4)
4) The driver must establish the weight of the batteries. He must be able to
demonstrate that he is not carrying more than 333kg of waste batteries. This
can be done by having a container which cannot take more than 333 kg of
batteries (Part 4)
5) The supplying company (not the individual driver) needs to be a registered
Waste Carrier and the retailer can (and should if not familiar with the driver)
ask the driver for proof. (Part 2)
6) The lorry driver has a pre-printed block of consignment notes with him.(Part 5)
7) The driver puts the weight of batteries on the consignment note and asks the
retailer to sign and keep his copy of the consignment note for 3 years. The
driver signs his own copy and keeps it for filing in the company system (also
for 3 years). (Part 5)
8) The driver puts the batteries in the safe container with the lining and closes
the lid. (The retailer needs to ensure its done correctly). The driver puts the
container in the lorry and makes sure its well placed so it doesnt move during
the journey. (Part 4)
9) By no later than the end of the day the driver takes the batteries to a location
where they will be bulked-up. (Part 4)
10) The driver asks the responsible person at the bulking-up site to sign his
section of the consignment note and leaves him the bottom section for the
returns.
NB If the bulking-up site is located in England or Wales the operator must
make a quarterly report of the amount of batteries collected to the
Environment Agency and to the store. (Part 5) If the site is located in
Scotland or Northern Ireland the operator must send a copy of the completed
note to the respective Agencies.
11) The person responsible for the bulking-up site in England or Wales must keep
all the consignment notes given to him by all the drivers in the company and
every quarter send a return to the EA on the batteries that they have received.
He pays a fee of 10 per return. (Part 5)

18

Collections from Shops selling more than 32 kilogrammes of batteries per year
Such shops will need to be ready to take back waste portable batteries on 1st
February 2010. Before then we recommend that you contact one or more Battery
Compliance Schemes to discuss collection of waste portable batteries from your
store for recycling. You have a right to have the waste portable batteries taken away
by any of the compliance schemes free of charge.
Schemes will arrange collection dates to minimise the environmental impact of the
transport involved. Retailers should discuss collection dates with compliance
schemes. We do not recommend that you move the waste portable batteries
yourself.
1) Batteries are safely collected in the store see Part 6 for advice on how to
assess that you are collecting safely.
2) A retailer contacts a Battery Compliance Scheme to arrange collection.
3) The scheme arranges for a professional waste company to collect the
batteries. The scheme must ensure that the collector knows the rules for
collecting waste according to Duty of Care, Waste Carriers, Hazardous waste
and transport of Dangerous Goods.
4) The remaining steps are the same as for back-hauling. The retailer must have
had the basic dangerous goods training to ensure that they know how
batteries should be packed for transport. (Part 4) They must ensure the
person collecting is that sent by the compliance scheme. The retailer must
sign and receive consignment notes from the collector (Part 5).
Postal Returns
We do not advise postal return as a way to collect batteries from consumers
because it is not possible to identify the quantity of batteries being posted, drivers
might not know that they are carrying batteries and therefore what action they need
to take to carry the batteries safely. It would also be difficult to ensure that batteries
are not sent via air. The Department for Transports rules for the carriage of batteries
are clear - they must be carried by road or by sea. This is because the risk level is
heightened when batteries are being flown.

19


Annexes
1 - Authorisation 214 for the transport of up to 333kg of waste portable batteries
Source:Departmentfortransport

20

2 - Hazardous Waste Mock Consignment Note Source Environment Agency


PART A Notification Details

1. Consignment note code: ABC123/AB001 3. Premises Code: ABC123


2. The waste described below is to be removed from: 4. The waste will be taken to:
(name, address, postcode, telephone, e-mail & fax) (address and postcode)
The Collection Point, High Street ,New Town, The Shire, XX12 3YY Battery Recycling, Low Street, Old Town, The Shire
Tel 0123 456789, cathode@hotmail.com YY12 4XX
5. The waste producer was (if different from 1) (name, address, postcode, telephone, e-mail & fax)

PART B Description of waste

1. The process giving rise to the waste(s) was: Domestic waste collection point 2. SIC for the process giving rise to the waste: ??????
3. WASTE DETAILS (where more than one waste type is collected all of the information given below must be completed for each EWC identified).
Physical Form
Hazard code(s)
Container type,
Description of
List of Wastes
Qty (kg)
The chemical /
number & size
Waste
(EWC) code
biological
components of the
waste, their
concentrations
Solid
H3A, H4, H5, H8,
1 lined rigid bin,
Variable depending
Separately
20 01 33*
18kg
H14
50L
on battery type,
Collected
likely to include.
Municipal
Lithium oxides ,
Fractions of
metal oxides, and
unsorted Domestic
salt electrolytes
batteries. May
(e.g.LiCoO2,
include alkaline,
LiPF6)
mercury, Nickel
Lithium, Cadmium
cadmium, nickel
and Zinc metal
metal hydride,
Metal Oxides
silver oxide,
(manganese,
lithium, and zinc
cadmium zinc)
carbon batteries.
Metal Hydroxides
(excluding lead
(Potassium, Nickel,
acid batteries)
Cadmium, Sodium
)
Organic
Carbonates
Mercury

ADR information for each EWC identified above:


EWC code

Description for Carriage


UN Identification number(s) Proper Shipping
Name(s) Un Class(es)

Special Handling requirements

20 01 33*

PART C Carriers certificate

PART D Consignor / Holders certificate

(If more than one carrier is used, please attach a schedule for subsequent
carriers. If a schedule of carriers is attached tick here)
I certify that I today collected the consignment and that the details in
A2, A4 and B3 are correct & have been advised of any specific
handling requirements:

I certify that the information in A, B & C above is correct, that the carrier is
registered or exempt and was advised of the appropriate precautionary
measures. All of the waste is packaged and labelled correctly & the carrier has
been advised of any special handling requirements.
1. 1. Consignor / Holder name (please PRINT)

1. Carrier driver name (please PRINT) Tony Driver


Mr Alan Node
on behalf of

(name, address, postcode, telephone, e-mail & fax)

2. On behalf of
(name, address, postcode, telephone, e-mail & fax)
The Local Authority, Middle Street, Old Town, The Shire, YY32 1ZZ
Tel : 0987 123456 e.mail: civiccentre@hotmail.com
3. Carriers registration no/ exemption reason:

The Collection Point, High Street ,New Town, The Shire, XX12 3YY
Tel 0123 456789, cathode@hotmail.com
Signature

A.Node

Time 18.00 Date 29/02/2008

ABC/012345
4. Vehicle registration no: AN07 1DE

Signature

T.Driver

Time 18.00 Date 29/02/2008

PART E Consignees Certificate (where more than one waste type is collected all of the information given below must be completed for each EWC)
Individual EWC code(s) received

Quantity of each EWC code


received (kg)

EWC code accepted / rejected

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Waste Management operation


(R or D code)

1. I received this waste at the address given in A4 on 29/2/2008 Name: (please PRINT) BERNARD ATTERY

2. Vehicle registration no (or mode of transport if not by road): AN07 1DE On behalf of (name, address, postcode, tel, e-mail & fax):
Where waste is rejected please provide details: Battery Recycling, Low Street, Old Town, The Shire, YY12 4XX
Tel : 0987 654321 e.mail: anode@hotmail.com

3. I certify that the waste management licence / permit / authorised exemption no(s). Signature:

Bernard Attery

Date: 18.30
authorises the management of the waste described in B at the address given at A4 Time: 29/02/2008

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3 General Awareness Training for the handling of waste portable batteries


Source DfT and VCA

Carriage of Dangerous Goods by road


Advice for General Awareness Training on the Movement
of Portable Waste Batteries
If you transport dangerous goods it is a requirement that personnel involved in any
aspect of the transport chain shall be trained. Training has to be commensurate with
responsibilities and a record must be maintained.
This advice is intended to assist those organisations collecting waste batteries from
consumer sites such as shops and offices. It is not definitive and may need to be
adjusted to take account of particular distribution systems.
If you are involved in the transport of portable waste batteries, then as part of the
requirements you need to have some general awareness training which will help you
consign, pack and transport the batteries safely.
The Department for Transport has issued an authorisation allowing mixed waste
batteries to be transported by road without the full application of the ADR provisions.
If you dont comply with the conditions of the authorisation, then you need to comply
fully with the provisions of ADR which are more onerous.
A load of mixed waste portable batteries will contain various types of batteries,
probably including lithium batteries. Lithium batteries are classed as dangerous
goods in transport because, if transported incorrectly, they may catch fire and
consequently pose a hazard to people. For this reason you need to be aware that
whenever you transport a mixed load of batteries, that load is highly likely to contain
some lithium batteries.
What training do you need? Well that depends on your role in the transport chain but
it isnt complex or difficult, its quite straightforward. This note aims to give you the
training you need in order to ensure you fulfil your obligations in relation to your role.

23

A. If you are a consignor i.e. the person who allows other people to
deposit their waste batteries on their premises for future collection and
removal e.g. retailer or the responsible person in a public building,
school, library etc.

Make sure you site your collection container in suitable place so people can
easily deposit their waste batteries and that the person coming to collect the
container or its contents can get to it easily without disrupting your usual
business too much. You could put the container outside if you want provided
it can cope with the varying weather conditions.
You need to make sure that the container you provide is suitable for the
batteries. The batteries will be collected inside a plastic liner placed inside a
box or drum. Plastic liners can only be used once.
The driver will need to know the weight of the batteries in your container as
he can only carry a maximum of 333kg on his vehicle. Either your container
can be marked to indicate approximate weights or the driver can weigh the
batteries.
You need to be present to ensure the driver removes the batteries and
places them in the required box/drum for transport as per the authorisation.
The liner must be sealed shut (using a tight knot, tape or cable tie to ensure
that batteries cant move about) before being placed in the outer box or drum
which is marked with the required lettering as per the authorisation. If the box
or drum doesnt display the marking, dont allow the driver to use it. You are
the consignor and hence responsible for making sure the batteries are
packed for transport properly. You could face enforcement action if you
dont.

B. If you are the driver arriving to collect the batteries


Check what container the consignor has. You may need to tip the batteries
into a liner if the container doesnt have one so make sure you have a
supply on the vehicle. If it does have one, you may need to replace it when
you remove it and its contents of batteries. Again make sure you carry a
supply.
Check the weight of the batteries as you cant go over the 333kg limit.
You need check that the liner has been tightly closed so the batteries cant
jump about inside. If the consignor hasnt done this then you will need to.
The sealed bag needs to be put in the outer drum or box, if it isnt already.
You need to ensure the boxes or drums you put on your vehicle are marked
according to the authorisation i.e. USED LITHIUM CELLS in capital letters
which are a minimum of 12mm high on a contrasting background. Make
sure that the box or drum is tightly packed. This also ensures the batteries
and the liner dont jump about too much whilst your vehicle is on the move.
When you have finished collecting or the 333kg limit has been reached the
batteries need to be taken to the bulk up point. Make sure you empty all the
24

boxes/drums containing the waste batteries out of the vehicle as no


batteries must be left in vehicles overnight or taken or left overnight in a
location that is not designed for the collection and storage of large quantities
of waste batteries.

C. If you are the carrier supplying the driver who is going to collect the
batteries:

You may need to ensure your driver has the right boxes/drums on his
vehicle before setting off. In addition that he has a supply of liners and
suitable means of sealing them. It maybe that the consignor has all this in
place so you dont need to do anything except advise the driver only to
pick up batteries that are in the right boxes /drums.

You need to ensure that the driver knows about the 333kg limit and
doesnt exceed it on his vehicle so you need to check and agree with the
consignor how this can be achieved.

It is essential that trainees show they have understood their duties and in this
respect an assessment should be carried out. Set out below are some test questions
that could be used.

1.
2.
3.
4.
5.

Why are lithium batteries are considered dangerous in transport?


What type of liner should the batteries be put in?
What words should be marked on the outer drum or box?
How big should the letters be?
Whats the maximum amount of waste portable batteries that a driver
can carry on his vehicle?
6. Whos responsibility is it to ensure the driver only fills the correctly
marked boxes or drums?
7. A driver finishes his collection round can he take his vehicle home with
the batteries still on board?
8. Whos responsibility is it to ensure the driver has the correctly marked
boxes or drums?
9. Whos responsibility is it to ensure the maximum limit of batteries is not
exceeded.
10. What sort of things can you use to seal the liner shut?

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