Rolls Surrette Lead Acid Battery Safety Data Sheet

SAFETY DATA SHEET – FLOODED LEAD-ACID BATTERY

15. REGUL ATORY INFORMATION

This product has been classi ed in accordance with the hazard criteria of the Controlled Products regulations

(CPR) and the SDS contains all information required by Controlled Products Regulations.

Distribution within Canada to follow Canadian Controlled Product Regulations (CPR) 24(1) and 24(2).

Industrial lead-acid batteries, such as those used in forklifts, do NOT meet the OSHA de nition of an ‘article’

(US EPA, Oct 1998). Therefore, the lead and acid that compose these batteries must be included when determining

the various thresholds for these EPCRA (Emergency Planning & Community Right-to-Know Act) section regulations.

The acid in lead-acid batteries is sulfuric acid, which is an Extremely Hazardous Substance (EHS). The following table

outlines the applicable EPCRA sections and their respective thresholds for sulfuric acid:

* The reporting threshold for sulfuric acid is ≥ the designated TPQ (Threshold Planning Quantity) or 500 lbs, whichever is less.

EPCRA SECTIONS THRESHOLDS

302 – Emergency Planning Notification TPQ ≥ 1000 lbs

304 – Emergency Release Notification RQ ≥ 1000 lbs

311 – MSDS Reporting *TPQ ≥ 500 lbs

312 – Chemical Inventory Reporting (i.e. Tier II) *TPQ ≥ 500 lbs

The lead used in lead-acid batteries does not qualify for any OSHA or EPCRA exemptions. Lead is not an EHS

and the following table outlines the applicable EPCRA sections and their respective thresholds for lead:

EPCRA SECTIONS THRESHOLDS

311 – MSDS Reporting ≥ 10,000 lbs

312 – Chemical Inventory Reporting (i.e. Tier II) ≥ 10,000 lbs

EPCRA Section 313:

The reporting of lead and sulfuric acid (and their releases) in lead-acid batteries used in cars, trucks, most cranes,

forklifts, locomotive engines and aircraft for the purposes of EPCRA Section 313 is not required. Lead-acid batteries

used for these purposes are exempt for section 313 reporting per the “Motor Vehicle Exemption”. See page B-22 of

the US EPA Guidance Document for Lead and Lead Compound Reporting under EPCRA Section 313 for additional

information of this exemption.