Why shouldn’t mine sites use wood pal­lets for trans­port­ing used lead acid bat­ter­ies?


THE lead acid bat­tery is by far the most com­mon type in use to­day, with more than 90 per cent of all bat­ter­ies (by weight) con­tain­ing lead.

How­ever lead has a dark side; it is the world’s num­ber one toxic poi­son in re­gard to the num­ber of hu­mans af­fected.

As such, it has been des­ig­nated as a Dan­ger­ous Good and Haz­ardous Waste, with the trans­porta­tion of used lead acid bat­ter­ies con­trolled by DG Trans­port and Con­trolled Waste Reg­u­la­tions.

These reg­u­la­tions con­tain “Chain of Re­spon­si­bil­ity” pro­vi­sions that place a le­gal re­spon­si­bil­ity on ULAB Pro­duc­ers to en­sure com­pli­ance by their sup­ply chain.

De­spite these re­quire­ments, we have wit­nessed sys­temic non com­pli­ance by the WA min­ing in­dus­try with how ULAB are be­ing trans­ported off site.

We be­lieve these prac­tices are in­dica­tive of what is oc­cur­ring na­tion­ally, and that one of the ma­jor con­tribut­ing fac­tors to this non com­pli­ance is the use of the wood pal­lets.

What are the trans­porta­tion re­quire­ments for ULABs?

As a Dan­ger­ous Good, the trans­porta­tion of used lead acid bat­ter­ies by ei­ther road or rail within Aus­tralia is con­trolled by the “Aus­tralian Code for the Trans­porta­tion of Dan­ger­ous Goods (ADG Code)”.

The Pack­ag­ing Re­quire­ments for new and used lead acid bat­ter­ies are con­tained in the ADG Code’s P801 Pack­ing In­struc­tion.

In Aus­tralia, the wood pal­let is the most com­mon de­vice used when trans­port­ing ULABs.

If you are us­ing wood pal­lets, re­ferred to as an over­pack in the ADG Code, then your pack­aged ULABs should ap­pear like the ex­am­ple in Fig­ure 1.

Non-com­pli­ant ULAB trans­porta­tion us­ing wood pal­lets

Com­mon ex­am­ples of non-com­pli­ance when us­ing an over­pack, such as a wood pal­let, in­clude:

1. In­ad­e­quate re­straints

Many bat­ter­ies are be­ing trans­ported from WA mine sites with the bat­ter­ies se­cured to the pal­let by plas­tics wrap­ping only.

In the event of a ve­hi­cle ac­ci­dent this would not ad­e­quately re­strain the heavy bat­ter­ies. The bat­ter­ies should also be se­cured with plas­tic strap­ping, with a hor­i­zon­tal band to se­cure each layer of bat­ter­ies and 2 ver­ti­cal over straps (Fig­ure 1).

2. No/ in­ad­e­quate sep­a­ra­tors be­tween bat­tery lay­ers

The ADG Code P801 Pack­ing In­struc­tion states that “bat­tery ter­mi­nals shall not sup­port the weight of other su­per­im­posed el­e­ments” and “bat­ter­ies stacked shall be ad­e­quately se­cured in tiers sep­a­rated by a layer of non con­duc­tive ma­te­rial”.

Many ship­ments of used bat­ter­ies have ei­ther no sep­a­ra­tor ap­plied or use an en­tirely in­ad­e­quate 5mm piece of card­board. To meet the P801 re­quire­ments the non-con­duc­tive sep­a­ra­tor should at least be 30mm to ad­e­quately pro­tect the ter­mi­nals from dam­ag­ing bat­ter­ies pack­aged on top.

3. Use of poor qual­ity pal­lets

Bat­ter­ies are heavy with a pal­let load weight up to 1.5 tonnes.

Poor qual­ity, light wood pal­lets cause is­sues dur­ing trans­port and can fail in the event of an ac­ci­dent.

4. No/ in­ad­e­quate re­straint of pal­lets to ve­hi­cle

We have ob­served sev­eral in­stances of ULABs be­ing trans­ported on wood pal­lets with­out be­ing se­cured to the ve­hi­cle.

The ADG Code re­quires “plac­ard loads” to be ad­e­quately re­strained.

5. No Class 8 Cor­ro­sive La­bels or DG doc­u­men­ta­tion

Ab­sence of Class 8 Cor­ro­sive la­bels on each over­pack and no trans­port doc­u­men­ta­tion de­tail­ing quan­tity and type of dan­ger­ous good.

Why aren’t wood pal­lets suit­able?

In Aus­tralia, the wood pal­let is cur­rently the de­fault de­vice used for trans­port­ing ULABs.

It has be­come the de­fault stan­dard for sev­eral rea­sons, in­clud­ing its low cost, wide­spread avail­abil­ity and be­cause many used bat­tery re­cy­cling fa­cil­i­ties have a stated pref­er­ence for re­ceiv­ing the bat­ter­ies de­liv­ered on wood pal­lets.

The wood pal­let how­ever has sev­eral sig­nif­i­cant draw­backs when used for trans­port­ing ULABs. These in­clude:

1. Acid leaks dur­ing stor­age and trans­porta­tion are not con­tained pos­ing sev­eral threats to hu­man health and the en­vi­ron­ment.

The sul­fu­ric acid elec­trolyte con­tains high lead lev­els and other toxic heavy me­tals. Lead is one of the most toxic sub­stances to hu­man health with the World Health Or­gan­i­sa­tion cur­rently sug­gest­ing there are no known lev­els of lead ex­po­sure that are con­sid­ered safe. The acidic elec­trolyte can also re­sult in burn in­juries, dam­age to prop­erty and the en­vi­ron­ment.

2. Poor, in­ad­e­quate and non-com­pli­ant pack­ag­ing due to:

a. Vari­a­tions in the worker’s at­ti­tude, train­ing & un­der­stand­ing of the reg­u­la­tions.

b. Time con­sum­ing, dif­fi­cult and un­safe task.

c. Re­quired ma­te­ri­als & tools not avail­able (good qual­ity wood pal­lets, plas­tic wrap, strap­ping tool, 30mm card sep­a­ra­tors).

d. Use of cheap, poor qual­ity wood pal­lets due to con­ve­nience and to save costs.

e. Bat­ter­ies of many dif­fer­ent sizes are dif­fi­cult to stack se­curely on wood pal­lets.

Sys­temic non-com­pli­ance of the pack­ag­ing re­quire­ment is in­creas­ing the risks to the pub­lic and en­vi­ron­ment in the event of an ac­ci­dent and re­sults in load shift­ing and acid spills dur­ing trans­port. And due to the “Chain of Re­spon­si­bil­ity” pro­vi­sions it is in­creas­ing the le­gal risk to min­ing com­pa­nies.

What are the al­ter­na­tives?

With the in­creased avail­abil­ity of plas­tic boxes of suit­able strength and ca­pa­ble of re­tain­ing any acid leaks, Bat­tery Res­cue be­lieve it is time the in­dus­try moved away from the use of wood pal­lets to store and trans­port used lead acid bat­ter­ies.

We be­lieve the Aus­tralian Gov­ern­ment should pro­vide reg­u­la­tory sup­port to elim­i­nate the use of wood pal­lets.

Fig­ure 1.

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