Battery Regulations: Noncompliance Can Cost You
The boom in telecommunications services and the electronics industry
over the past decade has given rise to a concurrent increase in the
number of stationary lead-acid battery (SLAB) installations, which provide
power for telecommunication distribution centers, UPS systems, and other
applications. Along with the proliferation of these units comes tighter
scrutiny of safety and environmental hazards associated with battery
containment failure. While regulations governing installation and safe
operation are in place at local, state, and federal levels, many companies
find compliance is complex, frustrating, and expensive — while
noncompliance is dangerous, inefficient, and even more expensive.
While batteries are a proven source of clean, efficient power, SLAB
installations can pose safety and environmental threats when they spill
or leak. Leakage of the lead and sulfuric acid found in SLABs, including
flooded-cell and valve-regulated lead-acid (VRLA) types, might contribute
to worker injuries, fire, hydrogen explosions, and groundwater and soil
contamination — not to mention the attendant fines, lawsuits and
loss of insurance. But proper spill containment is not a requirement
for safety and environmental reasons alone. It also is sound business
practice.
Yet many facility managers and engineers remain unaware of or are confused
by battery safety codes and guidelines. Some opt for makeshift containment
solutions, hoping to meet minimum compliance requirements with the minimum
amount of money and training. Still others ignore battery containment
procedures and regulations altogether.
Today, education on the safety hazards and financial consequences of
noncompliance is proving to be an effective tool. Large telecommunication
providers have been turning to firms that supply SLAB containment systems
for solutions to their compliance issues. And the leaders in standby
power system compliance and safety are listening.
Safety and Environmental Laws
Not surprisingly, state and local governments require battery containment
compliance. These codes require liquid-tight containment, neutralization,
signage, ventilation, personal protection, and eyewash stations in most
battery rooms (see Compliance Codes for SLABS, above).
Federal regulations also abound. The EPA enforces the Code of Federal
Regulations (CFR), which stems from the Resources Conservation Recovery
Act (RCRA) and the Right to Know Act. The Right to Know Act requires
businesses to report the storage of any hazardous materials exceeding
500 lb — including batteries. The RCRA states that any materials
exceeding 500 lb (10 lb equals 1 gal of electrolyte) must have liquid-tight,
secondary containment systems.
There also is an OSHA regulation, which addresses worker safety issues
in the presence of flooded-cell batteries, that requires neutralization,
sealed floors, personal protection, and eyewash stations. In addition,
recent amendments to Article 64 of the Uniform Fire Code (UFC) have
expanded spill containment requirements. The new requirements include
VRLA batteries if the minimum electrolyte-capacity thresholds of battery
systems are greater than 50 gal and individual jars are greater than
20 gal. In addition, legislation currently under review by the National
Fire Protection Association (NFPA) and the National Electrical Code
(NEC) would further increase the scope of enforcement.
Noncompliance Repercussions
If you think the effects of noncompliance on operations are minimal,
think again. The EPA classifies sulfuric acid as extremely hazardous,
so grandfather clauses that might otherwise mitigate fines and penalties
for noncompliance won't protect older installations. SLAB spills and
disasters also are subject to the legal implications of “chain
of possession.” Under EPA regulations, this means every business
involved with the battery — from the manufacturer, to the delivery
company, to the installer — is potentially liable if something
goes wrong. If leakage requires deployment of an OSHA-ordered HAZMAT
team, costly clean-up fees apply and the potential for liability increases
sharply. Furthermore, groundwater or soil contamination severely devalues
a company's real property.
Failure to comply with state and local regulations can lead to construction
and operation delays and exorbitant fines. Local fire departments are
known to inflict some of the most drastic penalties for noncompliance.
Fire inspectors in parts of California, Washington, New York, and Arizona
perform 24-hr, liquid-tight tests, filling containment systems with
water for one full day to test for leaks.
Improper Containment
The number of companies aiming for near-100% operation uptime, and the
UPS systems they employ to guarantee that, is steadily increasing. Cities
are rejuvenating downtown areas by selling and leasing old buildings
to telecommunications enterprises, which fill large battery rooms with
SLABs. Many of these new companies remain ill informed about intricate
compliance codes and battery issues.
That's why changing the “reactive” approach to battery containment
and compliance is more critical than ever. This traditional approach
generates an ineffective cycle of code regulation and compliance that
goes something like this:
Despite safety and monetary risks, a company fails to address secondary
battery systems' containment until faced with code inspections. But
this plan of action often backfires because, as the rate of containment
breaches increases, local authorities step up the frequency of their
code inspections. The facility's staff then responds by hastily installing
containment systems that meet minimal requirements as inexpensively
as possible.
Installation Problems
A careless installation can render a containment solution useless in
the case of a spill or leakage. But until recently, no agency existed
to guarantee or code-certify battery containment installations. Enviroguard,
a Los Angeles-based manufacturer of SLAB containment systems and safety
products, found this lack of oversight troubling. In 1998, the vendor
toured the country inspecting battery rooms and discovered the majority
of companies using SLABs lacked effective, standardized containment
facilities and procedures. Many were shoddy at best.
One common installation problem Enviroguard discovered was the improper
use of epoxy. Using epoxy effectively is difficult because its application
requires seven correctly performed steps. One time, they found epoxy
that was literally thrown in the garbage can. Other problems included
containment spill trays installed with gaps between seams, liners left
unsealed inside the trays, and absorbent pillows placed in trays with
spaces between them. Photos 1 and 2 highlight the difference between
a proper and improper installation.
Certification Solution
Threats of safety and regulatory backlash have prompted many telecommunications
companies to pressure SLAB containment system manufacturers for answers.
Motivated by both customer and internal battery containment concerns,
Enviroguard consulted a battery industry expert about a certification
program. As a result, an organization to develop training and certification
of SLAB containment system installers began (see Origins of Certification,
on page 16).
Companies participating in the certification program may receive training
for personnel or contact certified installers referred through the organization.
Certified installations provide certificates for facility personnel
to post on-site. This document assures building code inspectors of proper
installation and certification.
As the number of facilities using stationary lead-acid batteries continues
to increase, the industry will see more monetary and safety problems
from improper containment. In the past, many facilities disregarded
compliance, either from lack of code knowledge or careless solutions.
In today's litigious environment, small and large companies are seeking
protection from serious safety problems and liability by requiring certification
and battery containment system installation. That makes for a win-win
situation for everyone.
Compliance Codes for SLABs
Many local, state, and federal agencies publish codes or standards on
battery compliance solutions. For more information, check out A National
Resource of Global Standards at www.nssn.org and search by agency or
document. The following agencies address stationary lead-acid battery
containment:
ANSI: American National Standards Institute (www.ansi.org)
ASSE: American Society of Safety Engineers (www.asse.org)
ASTM: American Society for Testing Materials (www.astm.org)
BOCA: Building Officials and Code Administrators International Inc.
(www.bocai.org)
CFR: Code of Federal Regulations (www.access.gpo.gov/nara/cfr/index.html)
CSI: Construction Specification Institute (www.csinet.org)
FMERC: Factory Mutual Research Corporation (www.factorymutual.com)
ICBO: International Conference of Building Officials (www.icbo.org)
IEEE: Institute of Electrical and Electronics Engineers (www.ieee.org)
NFPA: National Fire Protection Agency (www.nfpa.org)
OSHA: Occupational Safety and Health Administration (www.osha.gov)
SBCCI: Southern Building Code Congress International Inc. (www.sbcci.org)
UL: Underwriters Laboratory (www.ul.com)
Origins of Certification
Last year, the Electrical Environmental Compliance
and Certification Organization (E2 CCO) was established in Boca Raton,
Fla. This membership-driven organization offers certification in the
stationary battery market and courses in general facility maintenance,
telecommunications installation, and UPS switching.
Course curriculum includes lectures, videos, and hands-on training.
Those who successfully complete a written exam and hands-on evaluation
receive certification for one year, and certifications are renewed annually.
E2 CCO is forming industry-specific advisory boards composed of experienced
field personnel and manufacturers. These boards will develop course
outlines and procedures for each specialization within the field.
Developed as an independent organization, E2 CCO does not affiliate
with or endorse specific products and manufacturing techniques. Its
goal is to remain impartial and open to all suggestions and recommendations.
Article By Kenneth Cotton
Mar 1, 2001
Go
to original article
Related Dawg® Products
Battery
Spill Containment Pad
Personal
Protection Products |