Is there a special permit that allows for mixed batteries (Alkaline, Nickel Cadmium, Lead Acid, Lithium, etc.) to ship in the same container for Disposal / Recycle?
USDOT’s Pipeline and Hazardous Materials Safety administration (PHSMA) grants relief from regulation based on documented cases where it is proven that transportation safety is not compromised. This relief is offered through the issuance of Special Permits. Special Permits can be issued to anyone involved in the transportation network regulated under PHSMA. For mixed battery shipments the Special Permit may be issued to a battery recycler or a package manufacturer for example. Special permits that allow the mixture of batteries types in a single container can be utilized. In most cases, limitations on the gross weight of batteries, the types of batteries that may be shipped and the packaging are all specified in the Special Permit. The majority of the Special Permits are similar in nature, however the shipper should always research to make sure the Special Permit has not expired and it is relevant to what is being offered to ship and is applicable to the transportation mode being utilized – i.e. -highway, rail, vessel, aircraft. All parties utilizing the Special Permit must ensure that they have a valid copy of the permit in their possession. Typically, the Permits have an expiration date associated with them and it is incumbent on the original submitter/grantee to apply for extensions on the expiration date.
Areas covered by the Special Permits include:
- Operational Control
- Packaging Requirements – Inner and Outer
- Gross Weights of Packages
- Marking / Labeling / Placarding / Emergency Response Information
- Shipping Paper Requirements
Detailed closure, packing and shipping instructions are provided to and must be followed by individuals preparing shipments under terms of the Special Permit. Individuals must also be trained and have proof of training.