Compliance requirement under the SOP

1. Authorization & Registration –

• • Units must secure authorization from SPCBs/PCCs under HoW Rules, 2016, along with valid CTE/CTO under the HoW (M &TM) Rules, 2016.
  • Registration on the EPR portals under Battery Waste Management Rules, 2022, and must comply with Plastic Waste Management Rules, 2022, and have to fulfill their obligation as an importer of plastic packaging material.
  • They have to comply with the ‘Guidelines on Extended Producer Responsibility for Plastic Packaging’ notified during February 2022.

     2.Facilities & Equipment –

Installation of automatic battery breaking systems, acoustic enclosures, fume/dust extraction, acid-proof flooring, ETPs, andAPCS (bag filters, scrubbers, 30m stacks, etc.). Adequate covered storage for hazardous waste, residues, and raw materials.

     3.Worker Safety & Monitoring –

Periodic blood and urine testing (twice yearly). Workers with lead levels above 42 μg/dl must be shifted to non-lead work areas and treated until levels drop below 10 μg/dl. Mandatory use of PPE and emergency kits.

     4.Transportation Requirements –

Leak-proof, labeled vehicles with compliance under the Motor Vehicles Act, 1988. Used batteries must be transported in sealed, acid-resistant containers/pallets. No manual loading/unloading allowed. Drivers must be trained, licensed for heavy vehicles, and qualified (minimum 10th pass with 5 years’ experience).

     5.Half Yearly Blood Test Report:

Any unit desirous of importing lead scrap/ used lead acid battery scraps periodically examine their workers at least twicein year for lead level in blood as well as urine. Persons with higher lead levels (greater than 42 micrograms /dl) should be shifted immediately to non-lead activity areas and given special medical treatment till the lead levels come back to acceptable level (10- micrograms /dl)

Grant of Authorization by SPCBs/PCCs

• Application process under HoW Rules, 2016 (Form 5).
• Requirement of Consent to Establish (CTE) and Consent to Operate (CTO) under Water Act, 1974 & Air Act, 1981.
• Submission of process flow sheet, equipment details, capacity proof, TSDF membership, APCS and ETP details.
• Inspection by SPCBs/PCCs before authorization.
• Authorization validity of 5 years.
• Performance evaluation of pollution control devices within 6 months.
• Maintenance of centralized list of authorized recyclers.

Minimum required facilities, operating practices and standards for secondary Lead recycling units

• Furnace type: Rotary or Mandir Bhatti with APCS.
• Air Pollution Control Devices (cyclone, bag filter, scrubber, stack height 30m, etc.).
• Separate secured storage for raw material, residues, and hazardous waste with impervious acid-proof flooring.
• Safe transportation and handling of battery scrap in sealed, leak-proof, shrink-wrapped pallets.
• Workers’ safety measures – PPE, emergency kits, medical monitoring (blood/urine lead levels).
• Automatic battery breaking system mandatory for importers.
• Effluent Treatment Plant (ETP) for wastewater/acid neutralization.
• Standards for emissions, effluents, ambient air, and blood lead levels.
• Steps to minimize fugitive lead emissions (hoods, wet floors, controlled vehicle entry/exit).

The minimum requirement for transportation of used lead acid battery scrap (Rains/Rinks batteries)

• Vehicles must comply with the Motor Vehicles Act, 1988 and be leak-proof.
• Valid authorization for transportation under HoW Rules.
• Vehicles must have Pollution Under Control Certificate (PUCC), emergency contacts, and TREM cards.
• Equipped with mechanical handling tools, spill kits, first aid, and fire extinguishers.
• Drivers must be at least 10th pass, trained, licensed for heavy vehicles, with minimum 5 years’ experience.
• Batteries to be transported in sealed, acid-resistant upright containers/pallets (no manual loading/unloading).
• Containers must not be repurposed for other uses and must prevent leakage/spillage.

Environmental Standards

SPCBs/PCCs may prescribe the following standards for Emission /Discharge for Lead

• Lead in workplace air: 0.05 mg/m³ (8-hr avg)
• Lead in stack emissions: 10.0 mg/Nm³
• Lead in effluent: 0.10 mg/l
• Lead at factory boundary: 1.0 µg/m³ (24-hr avg)
• Workers Blood lead levels: As a practice, all lead related units should periodically examine their workers at least once in year for lead level in blood as well as urine. Persons with higher lead levels (greater than 42 micrograms /dl) should be shifted immediately to non-lead activity areas and given special medical treatment till the lead levels come back to acceptable level (10- micrograms /dl).

Steps to minimize fugitive emissions of Lead

• The design of hood /fume collection system from the smelting/ refining operations (from metal tapping point, charging doors, furnace joints etc.) should be capable of collecting lead emissions and transfer to the air pollution control system.
• The storage and handling of all the raw materials, intermediates and products should be in covered area/ shed having concrete floors and mechanized equipment should be used to handle these materials as far as possible.
• The floors in the loading area should be kept wet through sprinklers to reduce the chances of lead particles/ dust getting airborne.
• Any water used for washing, rain water etc, should be collected through separate pits (to delink this from the regular drain) for removing metallic lead etc and the pit should have fine screens for passage of clear water.
• The movement of vehicles to the administrative /working /production areas should ensure that only the trucks /vehicles involved in the material handling/ transportation reach the work areas, and their tyres are washed before they leave these areas
• The unit has to have facilities for washing tyres of vehicle entering and going out of the recycling facility.