ComplianceKnowledgeCenter.com

Canadian Regulatory Requirements for

Stationary Battery Systems

North American Update

What Factors Drive the Need for Compliance?

Regulatory

Complying with National

& Provincial Codes

“Going Green”

Proactively Reducing

Environmental Impact

Corporate Social

Responsibility

Responsible for

Employee & Community

End Users Responsible for “Cradle-to-Grave” Liability

Cradle-to-Grave Liability Considerations

� Transportation

� Employee Safety

� Incident Reporting

� Environmental Protection

� Hazardous Waste

Installation OperationEnd of

Usable Life

End User Responsibility

Dangers in a Battery Room

Regulated Materials• Sulfuric Acid• Lead

Hazards• Chemical (Toxic & Corrosive)• Electrical• Explosive Gas• Physical (Lifting & Slip)

3 2

0

W

Signage

Spill Containment & Neutralization

Aisle Mats

HazMat Spill Cleanup Kit

Eyewash or Shower

Hydrogen Gas Monitor

Ventilation

Personal SafetyEquipment

Areas of Battery Room Compliance

Terminal Insulation &

Barriers

Standards Organizations

� CSA (Canadian Standards Association)� Electrical Safety: Z462-08 Section 6.3 Battery and Battery Rooms (Electrical Safety, PPE)

� ICC (International Code Council)� International Fire Code 608 (Spill Containment, Signage, Thermal Runaway, Spill

Kits, Gas Monitoring)

� NFPA (National Fire Prevention Association)� NFPA 1 Article 52 (Spill Containment, Signage, Thermal Runaway, Spill Kits, Gas Monitoring)� NFPA 70E Electrical Safety in the Workplace, Article 320 (Training, Terminal Covers,

Ventilation, Spill Control, PPE)

� IEEE (Institute of Electrical and Electronic Engineers)� IEEE 1578 Recommended Practice for Stationary Battery Electrolyte Spill Containment

and Management (Spill Containment)

� IEEE 484 Recommended Practice for Installation Design and Installation of Vented Lead-Acid Batteries for Stationary Applications (PPE, Spill Containment, Ventilation)

� IEEE 1187 Recommended Practice for Installation Design and Installation of Valve-Regulated Lead-Acid Batteries for Stationary Applications (PPE, Spill Containment, Ventilation)

� IEEE 1657 Recommended Practice for Personnel Qualifications for Installation and Maintenance of Stationary Batteries (Training, PPE)

What are Standards?

� A published specification that establishes a common language, and contains a technical specification or other precise criteria and is designed to be used consistently, as a rule, a guideline, or a definition.

� CSA – Canadian Standards Association

� American National Standards Institute (ANSI)

� ASTM - American Society for Testing and Materials

� Ulc – Underwriters Laboratories of Canada

What is a Code or Regulation?

� Created by a delegate of the Parliament

� Mandatory requirement

� a form of law

� The operational and enforceable part of a law

� Complies with an applicable Act.

� Code/Regulatory source is often originates from Standards doctrine

� IEEE, CSA, NFPA

Regulations adopt Model Standards

� Developed through committee and national organizations

� Based on standards and international code associations.

� CSA – Canadian Standards Association

� ICC – International Code Council (International Fire Code)

� IFC 608 Stationary Storage Battery Systems

� NFPA – National Fire Protection Association

� NFPA 1 Chapter 52 Stationary Lead-Acid Battery Systems

Federal Regulatory Agencies in Canada

� Environment Canada (EC)

� Ministry of the Environment

� Coordinates environmental policies and programs.

� Transport Canada

� Safety standards and regulations on transportation of dangerous

goods.

� Canadian Centre for Occupational Health and Safety (CCOHS)

� Work-related illnesses and injuries.

Canadian Regulations

� Ministry of the Environment

� Clean Water Act

� Environmental Protection Act

� NFC (The National Fire Code of Canada)

� OH5 Hazardous Substances Containment

� Canadian Transportation of Dangerous Goods (TDG) Regulations

� 49 CFR Hazardous Materials Regulations (Transportation, Training, Spill Containment, Signage)

� Canada Occupational Health And Safety Regulations

� SOR/86-304 — Warning of Hazardous Substances 10.13 (Signage, Eyewash, Training)

� Occupational Health and Safety Act

� Ontario Regulation 67/93 - Health Care And Residential Facilities (Signage & PPE)

� Ontario Health and Safety Reg 851 – (Shower/Eyewash)

� R.S.O. 1990, Chapter O.1 – (MSDS - Material Safety Data Sheets)

� Fire Protection and Prevention Act, 1997

� Ontario Regulation 213/07 - Fire Code – (Spill Containment)

Regulated Materials

� Canadian Centre for Occupational Health and Safety (www.ccohs.ca)

� WHMIS (Workplace Hazardous Materials Information System)

� Class D – Div. 2 Toxic – Lead

� Class E - Corrosives – Sulfuric Acid

Quebec Hazardous Material Regulation

� Prevent damage to the environment and wildlife

� Section 8. No one may emit, deposit, discharge or release a hazardous material into the environment or into a sewage system…

� Section 9. Every person who accidentally releases a hazardous material into the environment shall immediately

� (1) stop the spill;

� (2) inform the Minister of Sustainable Development, Environment

and Parks; and

� (3) recover the hazardous material and remove all contaminated

material that is not cleaned or treated on site.

608.5 Spill control and neutralization

An approved method and materials for the control and neutralization of a

spill of electrolyte shall be provided in areas containing lead-acid, nickel-

cadmium or other types of batteries with free-flowing liquid electrolyte.

Exception: VRLA …shall not require spill control. (Check with AHJ on local

applicability).

608.5.1 Nonrecombinant battery neutralization (Flooded)

… capable of neutralizing a spill from the largest lead-acid battery to a pH

between 7.0 and 9.0.

608.5.2 Recombinant battery neutralization (VRLA)… capable of neutralizing a spill of 3 percent of the capacity of the largest VRLA cell or

block…

Per IFC 608: All VRLA systems REQUIRE neutralization.

International Fire Code (IFC) Section 608

Copyright © 2011 EnviroGuard.

All Rights Reserved.

� Ministry of the Environment

� Fire Department code

enforcement

� CanOHS Inspector

� HazMat Inspector

� Insurance Carrier inspectors

� Loss Prevention

� Facility Owners and Managers

� Real Estate Professionals

� Environmental Compliance Manager

� Corporate Health and Safety

� Site Security and Human Resources

� Environmental Health and Safety

� Outside Environmental or Safety

Auditor

� Water Quality Inspectors

� Fish and Game

� Site Safety Manager

Any AHJ can require Spill Containment.

Authorities Having Jurisdiction (AHJ)?

Who Enforces the Need for Compliance?

Green Policy

Corporate Standards

Hazardous Materials

Management

Safety RegulationsFire Inspectors

CanOHS. Inspectors

EH&S Directors, LEED Certification

Facility Owners & Insurers

Local Authorities Having Jurisdiction

Regulatory

Going Green

CorporateResponsibility

What is Considered a Battery Spill?

� “Unintentional release of hazardous material.”

� Common causes:

� Installation and Removal� Handling (drops or punctures)

� Improper installation or support

� Operational� Over-charging / charger failure

� Thermal runaway

� Battery Explosion (hydrogen)

� Jar crack due to plate growth

� Seismic events

� Maintenance

� Water additions (electrolyte overflow)

� Jar Crack (punctures or unapproved cleaning fluids)Source: IEEE

“Most spills occur during installation & maintenance.” - IEEE

The Problem? - Damage to Rack

The Problem? Damage to Floor Substrate

The Problem? – Damage to Environment

Purpose & Terminology for Spill Containment

Neutralization

Method and materials for the neutralization of a release of electrolyte.

Spill Control

Method and materials for the control of a spill of electrolyte.

Barriers

Full spill control will typically require 4” high barriers.

Liner

Acid resistant liner to contain and control electrolyte spills.

Pillows

Pillows filled with chemicals to neutralize and absorb spilled electrolyte.

� Tested by globally recognized lab

� “a tested & proven means of containment”

� Reduces Risk / Liability

� Streamlines Fire Permit

Sign-off and Future Inspection

Importance of ULc for Spill Containment

Room or Rack Spill Containment?

Room Containment Rack Containment

Type of Neutralization Systems

Passive Neutralization

ALWAYS Ready

(Neutralizes upon Contact)

Reactive Neutralization

Manually Applied

(MUST be Trained to Use)

Due Diligence Checklist – Site AssessmentYes No Questions

Do you know and understand your safety and health responsibilities?

Do you have definite procedures in place to identify and control hazards?

Have you integrated safety into all aspects of your work?

Do you set objectives for safety and health just as you do for quality, production, and sales?

Have you committed appropriate resources to safety and health?

Have you explained safety and health responsibilities to all employees and made sure that they understand it?

Have employees been trained to work safely and use proper protective equipment?

Is there a hazard reporting procedure in place that encourages employees to report all unsafe conditions and unsafe practices to their supervisors?

Are managers, supervisors, and workers held accountable for safety and health just as they are held accountable for quality?

Is safety a factor when acquiring new equipment or changing a process?

Do you keep records of your program activities and improvements?

Do you keep records of the training each employee has received?

Do your records show that you take disciplinary action when an employee violates safety procedures?

Do you review your OSH program at least once a year and make improvements as needed?

Requirement Regulatory

Spill Control IFC, Ontario Reg 213/07

Neutralization IFC, Ontario Reg 213/07

Spill Clean-up Kit IFC, Ontario Reg 213/07

Eyewash Station Ontario Reg 851

Battery Room Signs IFC, SOR/86-304, 67/93

Hydrogen Gas Monitoring IFC

Thermal Runaway Protection IFC

Battery Terminal Covers NFPA 70E,

Acid-resistant Aisle Mats TBD

Smoke Detectors IFC, NFC

Fire Extinguishers NFC

Personal Protection Equipment (PPE) NFPA 70E, Ontario Reg 67/93

Required Battery Room Safety Equipment

Copyright © 2011 EnviroGuard.

All Rights Reserved.

Battery Room Signage

� Signs shall be posted at each door.

� Room Contains Lead Acid Battery System

� Energized electrical circuits

� Battery electrolyte solutions are corrosive liquids

� Clearly mark location of:� Eye Wash Station

� Fire Extinguisher

� First Aid Kit

� Exits

� Spill Cleanup Kit

Canada OHSR - SOR/86-304

Ontario Regulation 67/93

IFC Section 608.6

Canada OHSR - SOR/86-304

Ontario Regulation 67/93

IFC Section 608.6

Spill Clean-up Kits

Typical Personal Protection and Spill Response!� D.O.T. container� Neutralizing Pillows or SOCS� Acid Absorbent & Neutralizer� Full body coveralls� Headgear and face shield� Rubber boots� Goggles� Rubber gloves� Shovel and brush� Duct tape� pH test kit

� ONLY trained personnel are authorized to perform spill clean-up.

Ontario Regulation 67/93

National Fire Code – OH5

CSA Electrical Safety: Z462-08

Ontario Regulation 67/93

National Fire Code – OH5

CSA Electrical Safety: Z462-08

Eyewash Stations

OSHA requires ANSI Z358.1 Standard

Within 25 feet of battery work.

Plumbed shower stations:

� 30 gpm

Wall-mount stations:

� 0.4 gpm for 15 min.

Eyewash bottles (1 qt.)

� Ideal for personal protection

� Should not be stand-alone

Canada OHSR - SOR/86-304

Ontario Reg 851

Canada OHSR - SOR/86-304

Ontario Reg 851

Battery Terminal Covers

Features:

� Clear PVC

� Low Flame Spread LOI >32

� UL 94V-0

� Five Different Sizes

Provide:

� Insulate terminals and intercell connectors

� Meet NFPA 70E and OSHA Regulations

Include with ALL Battery Systems!

CSA Z462-08 Section 6.3

NFPA 70E

CSA Z462-08 Section 6.3

NFPA 70E

Prevent H2 Gas Buildup

Hydrogen Detection Units

Hydrogen Gas Monitor Applications

� Ensure code compliance

� Continuous monitoring of Hydrogen Gas

� Early warning of hydrogen gas presence

� Turn off chargers

� Turn on secondary ventilation

Ventilate Room per Code� < 1.0% of H2 of total volume

� Same for Cabinets

Personnel Safety

Aisle Mats

- 36” or 48” wide

- Acid Resistant

Battery Lifts

Electrical Safety

� Insulated Tools

� Battery Blankets

� HV Mats

30.0kVA Floor Mat

Battery Blanket

Insulated Tools

Required Training

� Hazard Communication

� Battery and Battery Room Safety

� Transportation of Hazardous Material

� Battery Spill Response Awareness

� Packaging and Handling

� NFPA 70E Electrical Safety

� Electrical PPE

� Arc Flash Hazards

� Lock-out/Tag-out

� And more…

References

� BCI (Battery Council International)http://www.batterycouncil.org

� Environment Canadahttp://www.ec.gc.ca

� Transport Canadahttp://www.tc.gc.ca

� Province of British Columbia

� Environment Management Act, Reg 449/2004, Recycling Regulationhttp://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/449_2004

� Product Stewardship for Lead-Acid Batteries:http://www.env.gov.bc.ca/epd/recycling/batt/index.htm

� Ontario Ministry of the Environmenthttp://www.ene.gov.on.ca/environment

� Canadian Battery Associationhttp://canadianbatteryassociation.ca/

Acknowledgements

� Battery Council International

� Veolia Environmental Services

� References:

� “An Update on the Codes, Standards and Guides Applicable to

Stationary Lead-Acid Batteries” by J. Allen Byrne

ComplianceKnowledgeCenter.com

Thank You

Bill Ryan

Email: BRyan@EnviroGuard.com

Call: 800-206-9884

R1

Slide 38

R1 Richard, 2011-05-27