In support of Doug's comments, check this out............
I wonder what kind of disposal statements are with these batteries?
I bet you they are revising this now................ :)

http:www.support.dell.com/battery/

Regards,

Regan Arndt
Sr. Engineer
TUV Rheinland of North America, Inc.
Product Safety West Division
Calgary, AB  Canada




"Massey, Doug C." <[email protected]>@ieee.org on 11/16/2000 10:40:39 AM

Please respond to "Massey, Doug C." <[email protected]>

Sent by:  [email protected]


To:   [email protected]
cc:

Subject:  FW: EPA Hazardous Materials & Lithium Batteries disposal



Hi Jeffrey:

As far as the EPA is concerned, Li-ion batteries are not considered as
hazardous material. Remember, the EPA is NOT concerned with the safety of
your customer, only the effects on the environment. The Battery Management
Act is Public Law 104-142, 104th Congress, and there is an EPA publication
available, EPA530-K-97-009. The act is concerned with keeping with mercury,
lead, and cadmium out of landfills - ie, Ni-Cd and SSLA's (Small Sealed
Lead
Acid) batteries. For Lithium batteries, the only disposal criteria is DO
NOT
INCINERATE - the contents are not considered harmful to the environment,
but
it may explode if heated beyond certain temps. Although it is still a
mystery to me why a coin cell exploding in a trash incinerator at 2500 C
can
cause anyone concern.....

As to the UL concerns, the text of the safety warning is given in UL1950
3rd
Ed., clause 1.7.17. Note that if the battery is in a service area and not
operator accessible, this text need only be in service instructions. So if
we're talking about a coin cell Lithium battery, most likely UL will want
this text in the reference guide only. This text includes the statement
"Dispose of used batteries according to the manufacturers instructions."
Now, you can take the low road and say that you aren't the battery
manufacturer, but in my opinion you aren't making things easier for your
customer - so you should take the initiative to either publish disposal
instructions in your operators guide, or make those instructions available
to your tech support folks so that if a customer calls in asking they will
know what the answer is.

If your battery is a custom Li-ion battery pack, then you become the
manufacturer, even though you probably did not manufacture the cells
themselves. I have recently addressed this issue with one of our products,
and it caused me a bit of consternation. As a quick sanity check, I looked
on a variety of battery packs used in various laptop and notebook computers
to see what text was there - to my surprise, they all differed slightly
(all
were UL listed products). What I have learned is that the conditions of
acceptability in the UL reports for the cells may dictate what the text
says. The only thing you can do in this case is to let UL dictate the text
to you, as you most likely don't have access to those reports. The main
difference will be warning text restricting the upper operating temp, which
in most cases will be much higher than anyone is likely to operate your
device under.

Here is the text on our battery pack: CAUTION: Risk of fire, explosion, or
burns. Do not short circuit, crush, heat above 100 C, incinerate, or
disassemble the battery.

I have seen that temp range go as high as 200 C, all on UL listed products.
I can't find a specific temp in the standard or in the practical
applications guides, so all I can say in this case is let UL tell you. I do
believe it depends on the conditions of acceptability of the particular
cell
used.

You can get a lot of info from the cell manufacturers - Sanyo, Sony,
NEC/Moli Energy. Also the RBRC and PRBA might help - independent battery
recycling organizations.

The upshot is to put the warning text required by UL in the appropriate
location, and let your customers know that the batteries are not to be
recycled or incinerated - just dispose of normally. I could never figure
out
how one disposing of a Lithium battery knows whether the trash can you just
tossed it in is bound for an incinerator or not.

I'm interested in hearing from anyone with more knowledge of proper
disposal. The best I could find out from EPA, vendors,RBRC and PRBA is
chuck
'em.

Hope this helped.

Doug Massey
LXE, Inc.


-----Original Message-----
From: Collins, Jeffrey [mailto:[email protected]]
Sent: Wednesday, November 15, 2000 4:04 PM
To: IEEE EMC-PSTC Forum
Subject: EPA Hazardous Materials & Lithium Batteries disposal



Group,

I've got two general questions regarding hazardous material:

1). Any experience with identifying materials defined as hazardous by the
EPA? (Is there a list somewhere??)  My customer is interested in steps that
should be taken to:

 * Avoid exposure
 * Avoid injury
 * Proper disposal of the material

I took a look at the EPA website but it appears not to be straight forward
in identifying what is and is not hazardous.
We are the Mfg of Telecom equipment so there are no chemicals or fumes
associated with our products.
I've also looked at the WEEE Directive but this is a US based customer and
they are specifically referencing the EPA.

2). Do you provide any instructions / processes regarding the disposal of
Lithium batteries for your customers?
     If so what documents/standards are you referencing???


All replies are appreciated..............


Jeffrey Collins
MTS, Principal Compliance Engineer
Ciena Core Switching Division
[email protected]
www.ciena.com


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