Posted by Kara Humes on Monday, December 8, 2025
As industrial facilities increasingly shift from lead-acid to lithium-ion batteries, understanding the implications for Tier II reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) becomes critical. These regulations require facilities to report hazardous chemical inventories to local emergency planners, ensuring safety and regulatory compliance.
Understanding the Shift from Lead-Acid to Lithium-Ion Batteries
The industrial sector favors lithium-ion batteries for their longer life, higher efficiency, faster charging, and lighter weight compared to traditional lead-acid batteries. However, this advancement introduces new regulatory considerations.
Regulatory Reporting and Compliance Implications
Tier II Reporting: Battery Type Comparison | ACID | - Acid Content
- EHS (Sulfuric Acid) >500lbs
- Lead >10,000lbs
| | LITHIUM-ION | - Total Weight >10,000lbs
- Chemical Composition
- Fire Hazards
| |
Transitioning away from lead-acid may give people a false impression that they no longer have to report, but lithium-ion batteries still contain hazardous chemicals that are known to be flammable, which can pose potential safety issues. Lead-acid battery reports usually focus on acid content, whereas lithium-ion reporting is driven by total weight, chemical composition, and associated fire hazards. An upside is that, unlike lead-acid batteries, lithium-ion batteries do not contain any Extremely Hazardous Substances (EHS). Facilities must carefully update Safety Data Sheets (SDS), chemical inventories, and Tier II filings to reflect the new battery chemistry.
Reporting Options: Lithium-Ion Batteries
Tier II reporting allows batteries to be quantified as a mixture or as individual components. If batteries are reported as a mixture, the total quantity of batteries located in the facility goes towards the reporting threshold. Whereas if they are reported by component, the SDS must be used to calculate the total quantity of each battery component (e.g., lithium cathode, copper, lead, etc.). When reporting by component, it’s important to remember that not only the chemical (e.g., Copper) located in the batteries contributes to the reporting limit, but that any other stored chemical (e.g., Copper) within the facility must also be accounted for. It is also important to reference the lithium-ion battery SDS from the appropriate manufacturer, which helps in getting accurate chemical components as well as providing the most accurate information to local emergency services.
Lithium-Ion Reporting Options: | INDIVIDUAL COMPONENTS | - Use battery SDS
- Calculate total chemical weight of all stored chemicals (within li-ion batteries as well as otherwise stored at the facility)
| |
Action Steps for Facilities
- Inventory all batteries by chemistry and weight in the facility.
- Review updated SDSs to calculate applicable reporting thresholds.
- Update Tier II reports and emergency response plans ahead of the annual March 1 submission deadline.
- Train personnel on new lithium-ion battery hazards and compliance expectations.
- Collaborate with local emergency responders to ensure clear hazard understanding.
Conclusion
The transition from lead-acid to lithium-ion batteries offers operational benefits but demands vigilant attention to regulatory compliance under EPCRA Tier II reporting. Facilities must reassess reporting thresholds, update documentation, and maintain proactive communication with regulatory and emergency response stakeholders to avoid costly noncompliance fines during audits or regulatory inspections.
If you have questions about your EPCRA Tier II compliance reporting, reach out! I love to help!
Categories: Industrial & Manufacturing
Tagged: Environmental | Regulations