TT Talk - US advice on carriage of batteries for recycling

  • Date: 12/03/2010
  • Source: TT Talk 128

Dr Chris Foster of Dr J H Burgoyne & Partners LLP has drawn attention to the US Department of Transportation (DOT), Pipeline and Hazardous Materials Safety Administration (PHMSA) advice issued concerning transportation of batteries for recycling and disposal following a number of serious incidents. PHMSA noted an ongoing trend of serious safety problems and non-compliance regarding the classification, packaging, marking, labelling, documentation, and transportation of spent batteries in commerce. Investigations revealed a number of safety issues, including:

1. Large numbers of used batteries, of many different types, are collected in large containers that do not adequately prevent damage to the batteries or prevent their release during transportation.

2. Outer packages are not marked and labelled as required to indicate that they contain batteries; the shipments are not described as required on accompanying shipping documents.

3. No action is being taken to prevent a short circuit, such as separating the batteries by placing each one in a separate plastic 'baggie' or taping the terminals of the battery.

The following weblink provides the complete advice.

PHMSA Battery Guide

It should be noted that PHMSA issued a final rule requiring full compliance from 1 January 2010. While this is obviously specific to US regulation, the safety principles will be valuable in other jurisdictions.

Through Transport Mutual Insurance Association Limited and TT Club Mutual Insurance Limited, trading as the TT Club. TT Club Mutual Insurance Limited, registered in the UK (Company number: 02657093) is authorised by the Prudential Regulation Authority and regulated in the UK by the Financial Conduct Authority and Prudential Regulation Authority. In Hong Kong, TT Club Mutual Insurance Limited is authorised and regulated by the Hong Kong Insurance Authority, in Singapore by the Monetary Authority of Singapore and in Australia by the Australian Prudential Regulation Authority. In the United States, TT Club Mutual Insurance Limited is approved as a surplus lines insurer in all states and is accessible through properly licensed surplus lines brokers. The registered offices are: 90 Fenchurch Street, London, EC3M 4ST.

Through Transport Mutual Insurance Association Limited, registered in Bermuda (Company number: 1750) is authorised and regulated in Bermuda by the Bermuda Monetary Authority. 

The UK VAT Identification number for Through Transport Mutual Insurance Association Limited is: GB 564 5244 35 and for TT Club Mutual Insurance Limited is: GB 564 3375 30. The Italian VAT Identification number for TT Club Mutual Ltd is: 03627210101.

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