Does EPA have a standard or recommended reporting approach for lead acid batteries when complying with EPCRA Section 312 Chemical Inventory Reporting (i.e., Tier II reporting)?
EPA suggests that facilities report for lead acid batteries in the same manner they used when complying with EPCRA Section 311 MSDS reporting requirements. Under Section 311, facilities have the option of submitting an MSDS for each component of a mixture or for the mixture itself. Thus, if a facility submitted an MSDS to the SERC, LEPC, and local fire department for the battery when complying with EPCRA Section 311, the facility should report on the battery, not the components, on the Tier II Chemical Inventory Form when complying Section 312 reporting. The facility would include the hazards associated with the battery. This best practice will provide consistency for local responders who receive both reporting deliverables for EPCRA Sections 311 and 312.