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Recycling industrial batteries


Recently, protecting the global environment and harmonizing human activity with it so as to be able to pass on a sound environment to the next generation has become one of the most pressing issues.

Yet, all around us there are numerous industrial batteries being used for emergency and other vital power sources. These batteries are made of lead, cadmium, plastic, and other materials that, through recycling, provide material to make new batteries.
However, these storage batteries—which contain hazardous materials such as lead, cadmium, dilute sulfuric acid and alkaline electrolytes—must be properly processed and disposed of after they are used up in order to prevent adverse affects on the environment.

The Environmental Health Bureau, Industrial Waste Division ordinance 050330009 titled "Proper processing of used lead-acid storage batteries" (March 30, 2005) includes a section titled "Technological guidelines regarding the handling of used lead-acid storage batteries." This section states that electrolytes used in storage batteries fall under the category of specially controlled industrial waste that requires special handling, and thus used storage batteries must be handled as specially controlled industrial waste in accordance with the waste management and public cleansing law ("the waste management law").

In order to conform to the regulations in the waste management law, waste discharge organizations must, among other requirements, conclude contracts with certified collection and transportation companies and processors, and keep manifests as records of proper receipt and management of the batteries for five years.

The following information is intended to increase the understanding of customers and storage battery contractors on the proper processing of used storage batteries as waste, and to be useful in the proper processing of used storage batteries to ensure the proper processing and recycling of batteries in accordance with the law.

Processing used industrial storage batteries

The waste management law mandates that business organizations take responsibility for the proper processing of waste produced in the course of their business activities (article 3, paragraph 1). The law requires that the customer (waste discharge organization) should properly process used industrial storage batteries (those that have reached the end of their useful lives and are no longer needed).

Under normal circumstances, the customer does not have the required processing facilities, and thus the customer must contract the processing of these batteries to a professional processor or a wide area certified handler and defray the process cost.

Industrial storage battery manufacturers, who are members of the BAJ, are aiming to contribute to the formation of a society with an environmentally sound material cycle as part of their corporate social responsibility (CSR), and to ensure the proper processing of used storage batteries, and as a means of actively pursuing their CSR, they have sought and received certification from the Ministry of the Environment under the special ordinances for the wide area processing of industrial waste provided for in the waste management law, article 15-4-3. (Storage battery manufacturers have each individually acquired this certificate.)

The wide area certification system seeks to promote efficient reuse of the recovered materials with manufacturers involved in the system of recycling of their own products based on the concept of expanded producer responsibility. It also promotes the use of product design that makes reuse or processing easier, and ensures the proper processing or reduction of waste. It accomplishes both of these things by removing the need for the approval of local government that makes up the fundamental legal system for the waste disposal industry.

Industrial storage battery manufacturers, who are members of the BAJ, promote the recycling of industrial storage batteries through processing that complies with the wide area certification system.

Methods of processing used industrial storage batteries

  1. When using the wide area certified recycling system

    Customers or contractors may contract for battery processing with storage battery manufacturers who have acquired wide area certification. Customers or contractors, as waste discharge organizations, can conclude a contract with a storage battery manufacturer to take responsibility on the part of the customer or contractor for the removal and processing of used storage batteries. In this case, the customer or contractor does not need a direct contract with collection, transport business organizations or processors.

    However, the storage battery electrolyte is either strong acid or strong alkaline, and as such falls under the category of waste that requires special handling. Thus the waste discharge organization must designate a person responsible for the specially controlled industrial waste.

    In addition, contractors may become the waste discharge organization when contracted by a customer to renew or remove storage batteries. Storage battery sellers and other business organizations that replace used storage batteries and contract for battery collection with storage battery manufacturers may also be designated as the waste discharge organizations.

    An industrial waste manifest is also not necessary under the wide area certification system*. However, the wide area certification system does require a simplified administrative manifest when processing storage batteries.

    *Regulation of waste management and public cleansing law

    When an industrial waste manifest is not required
    Article 8-19-5

    When contracting with certified parties as set forth in paragraph 1 of article 15-4-3 of the waste management law (including those who are contracted by such parties, and perform specified transport and processing of specified industrial waste [limited to those prescribed under paragraph 2, item 2 of the same article]) for specified transportation and processing of specified industrial waste an industrial waste manifest is not required.
    (Certificate in paragraph 1 of Article 15-4-3 of the waste management and public cleansing law is wide area certication.)

  2. When the customer directly contracts with the waste treatment company

    Even when the customer or contractor dispatch used storage batteries (waste) as waste discharge organizations, the storage batteries must be collected and transported by the method that conforms to the waste management law and that allows the batteries to be properly processed. Because the electrolyte of storage batteries is either strong acid or strong alkaline, they are classified as specially controlled industrial waste that requires special handling under the waste management law and must be handled accordingly.
    Also in accordance with the waste management law, it is specified that waste discharge organizations (customers) bear the responsibility of processing the waste generated from their own business activities.

    Obligations of waste discharge organizations

    • Must designate a person responsible for specially controlled industrial waste.
    • Must conclude contracts with collection and transportation companies and treatment companies.
    • Must issue and maintain industrial waste manifests.
    • Must file an annual report with the prefectural governor.
    • In some situations, must consult beforehand (prior consultation) with the receiving municipal government when transporting outside the prefecture.

About the manifest system

The manifest system is a system that enables the waste discharge organization to understand and manage the flow of industrial waste by recording the industrial waste type, name, condition, packaging, weight, volume, transportation company name, disposal company name, and special handling requirements when a waste discharge organization contracts the processing of industrial waste.

  1. Industrial waste manifest form
    The manifest has seven copies
    A  Waste discharge organization copy
    B1 Collection, transport company copy
    B2 Copy returned to the waste discharge organization
    C1 Treatment company copy
    C2 Collection, transport company copy
    D  Copy returned to the waste discharge organization
    E  Copy returned to the waste discharge organization

    Blank manifests can be purchased from the National Federation of Industrial Waste Management Associations or the Industrial Waste Management Association in each prefecture.

  2. Industrial waste manifest flow chart

  3. Manifest management
    Industrial waste manifests must be retained for five years.

    Note: Changes of requirements for manifest
    Originally, manifests were required only for specially controlled industrial waste that requires special handling, but since revisions to the waste management law in June 1997, they are required for all industrial waste.
    (Put into effect in December 1998).

Notices regarding safe handling
Business organizations are responsible for the proper treatment of the waste generated through their business activities. Even when contracting for the processing, the business organization is responsible for ensuring that the processing company is fully informed about the following safety issues:

  1. Storage
    Even used batteries can have some electric energy remaining. A short-circuit could cause a fire; the battery could fall over and crack resulting in an electrolyte leak; or an open flame could ignite the gas remaining inside a storage battery and cause an explosion. To prevent these incidents, batteries should be stored where they cannot be tampered with, and care should be taken to prevent their falling.
    Particularly when batteries are stacked, do not place the batteries or the pallet directly on the items sticking out of the top of the batteries—such as the terminals, vent plugs and catalyst plugs—to protect the batteries from short-circuits and damage. To prevent soil contamination, the floor should be of a waterproof construction, and the batteries should be protected from the rain. If storage batteries are already broken and are expected to leak electrolyte, they should be stored in a plastic container to prevent the electrolyte from escaping.

  2. Transportation
    The rules for transportation are basically the same as for storage, but if the batteries come loose during transportation, short-circuiting could result in a fire or explosion or electrolyte may spill, causing severe damage in a public place. All personnel must be well informed about how to prevent the batteries from falling or coming loose during transportation.

  3. Information regarding the handling in case of accidents
    All personnel must be informed in advance about what to do in the event that electrolyte gets in the eyes or on the skin, or spills on the road or on a vehicle (have neutralizing agents on hand etc.).