The Environmental Issues

The human health and environmental issues associated with nickel-cadmium batteries arise mainly from the ultimate disposal of the spent batteries. In general, occupational exposures to and manufacturing wastes and emissions from nickel, cadmium, cobalt and other materials in NiCd battery production are well regulated and controlled. There is virtually no danger of nickel or cadmium exposure during normal use of NiCd batteries. Even when NiCd batteries are disposed of in landfills, there is little danger of risk or exposure, at least in the short to mid-term, to nickel or cadmium from the battery's electrodes since they are always encased in at least two layers of steel or plastic or both.

In the past twenty years, the space available for the disposal of waste in landfills has diminished rapidly, in some of the densely populated countries much more so than in others. In several countries in Europe and in Japan in particular, incineration and the human health and environmental issues arising from incineration have been instrumental in promulgating regulations affecting metal products. Since 1985 in the United States, some municipalities and local jurisdictions have made huge investments in solid waste incinerators to reduce the volume of disposal waste and because there just has not been sufficient space available for landfilling. However, these incinerators have not proved to be totally cost effective because of the additional expense of disposing of the incinerator's waste products, ash and slag. Unfortunately, these wastes and slags may contain levels of toxic materials that result in them being classified as "hazardous." The end result is an enormous increase in ash and slag management and disposal costs.

In 1989, Franklin Associates published a report under contract to the U.S. Environmental Protection Agency on the sources of lead and cadmium in municipal solid waste (MSW) that clearly identified NiCd batteries as a major source of cadmium. Based on this report, which later proved to have exaggerated the NiCd contribution to MSW, state jurisdictions, especially those with heavy commitments to new incinerators, began to propose legislation and regulation to divert NiCd batteries from the waste stream, and several even mandated NiCd battery collection programs which in turn led to voluntary action by some companies. However, shortly after issuance of the Franklin Report, EPA changed its test protocol for determining what wastes should be classified as hazardous. The new test protocol, the TCLP test, required that used NiCd batteries first be crushed or cut to a certain size much smaller than the size of the battery itself thereby exposing the internal nickel and cadmium electrodes, and then placed in an acetic acid solution for about a day to simulate the relative amount of nickel or cadmium leaching from the batteries into landfill leachate over a protracted period of time. Not suprisingly, used NiCd batteries failed the TCLP test and were classified as "hazardous waste."

As a consequence, the transportation, storage and handling of used NiCd batteries immediately came under the jurisdiction of the United States' Resource Conservation and Recovery Act (RCRA) under which waste generators are required to obtain identification numbers from federal and state regulators, transporters must meet stringent regulatory requirements, and collection and recycling facilities need comprehensive and expensive permits. Such an array of regulatory requirements immediately halted the voluntary collection and recycling programs previously started for NiCd batteries even though some states were beginning to put legislation in place requiring collection and recycling. To add further to the confusion, RCRA requirements on used batteries did not apply to those generated from household wastes, but did apply to batteries from institutional generators. If a mixture of batteries from both sources were collected, then all were regulated.

Previously, the U.S. EPA had specifically promulgated regulations that exempted used lead acid batteries from the regulatory burdens of RCRA in order to facilitate the already well-established recycling of automotive batteries. As a result, lead acid batteries enjoyed a recycling rate of better than 95%. NiCd batteries, however, were not included in this earlier scheme, and at the time the TCLP test was initiated, its potential impact on NiCd batteries was not recognized and no provisions were made to facilitate their recycling.

THE NiCd BATTERY RECYCLING PROBLEM

In April 1991, the NiCd battery manufacturers approached the U.S. Environmental Protection Agency with their problem. Even though they wanted to collect and recycle NiCd batteries to get them out of the municipal solid waste stream and needed to comply with several state recycling mandates as well, they were hindered from doing so because of the "hazardous waste" classification of used NiCd batteries. There was no technologically economical way to segregate exempted "household" used batteries from regulated "business" batteries, and too many of the mass market distributors whose cooperation was required to collect the batteries simply would have nothing to do with handling hazardous wastes. Even if collection systems could be set up, they would be economically prohibitive to manage when, for example, shipments of used NiCd batteries had to be transported by manifested hazardous waste carriers.

Even though the U.S. EPA staff was sympathetic, no direct action was initially taken, and NiCd battery manufacturers proceeded to file a formal petition for rulemaking to reduce the regulatory burdens associated with the collection and recycling of NiCd batteries. Their proposal suggested that EPA either suspend or defer the application of the TCLP test to used NiCd batteries intended for recycling or that the exemptions granted for the recycling of lead acid batteries be extended to NiCd batteries as well. However, rather than adopt either of these suggestions, the U.S. EPA indicated that it would treat NiCd batteries within the framework of its ongoing effort to adopt rules to facilitate recycling of a number of other products including pesticide containers, mercury switches and fluorescent light bulbs. There were, however, potential problems and questions about recycling some of these products, which proved difficult and controversial. In spite of a groundswell of national support from NiCd battery manufacturers and users, little progress was made until political support was obtained from Capitol Hill. Even with bipartisan political support and fundamental agreement with the principles of the program, it was not until April 1995 that a final EPA regulation was issued and not until May 1996 that national legislation was signed into law, which facilitated a uniform, national NiCd battery recycling program in the United States. Thus, five years of intense effort and expense by the industry were necessary to implement what everybody agreed was a fundamentally sound idea in the first place.

THE INDUSTRY NiCd BATTERY RECYCLING PROGRAM

The plan proposed by the NiCd battery industry as early as 1993 and which today is being implemented by the Rechargeable Battery Recycling Corporation (RBRC) is known as the Charge Up to Recycle! program. RBRC is a not-for-profit corporation founded in 1994 and funded by rechargeable battery and product manufacturers to implement and maintain NiCd battery collection and recycling programs in the United States and, through a subsidiary, in Canada. The RBRC program has created various recycling plans for communities, retailers, businesses, and public agencies. For each group, RBRC pays or shares the cost of consolidating the batteries, shipping them to the processing facility, and recycling them.

All NiCd batteries collected by these plans are sent to the sole North American facility capable of processing and recycling them, the International Metals Reclamation Co., Inc. (INMETCO). At their Ellwood City, Pennsylvania facility near Pittsburgh, nickel and iron are separated from cadmium in NiCd batteries and shipped to specialty steel producers to produce stainless steel. The recovered cadmium, at a 99.95 percent purity level, is sold for production of new NiCd rechargeable batteries and in other cadmium-containing products. INMETCO's recycling process is recognized by the U.S. EPA as being the "best demonstrated available technology" to recycle NiCd batteries.

The Charge Up to Recycle! program contains several key elements which are specified both in the U.S. EPA regulation (40CFR, Part 273), various United States' state laws governing NiCd battery recycling, and in the "Mercury-Containing and Rechargeable Battery Management Act" of 1996. These include the following provisions:

• Uniform Battery Labeling Requirements

• Removeability of Batteries from Appliances

• National Network of Collection Systems

• Regulatory Relief to Facilitate NiCd Battery Collection

• Widespread Publicity to Encourage Public Participation

• Development of a Funding Mechanism for the Program

The uniform battery labeling requirements, as, for example, specified in the "Mercury-Containing and Rechargeable Battery Management Act", mandate that each regulated battery or rechargeable consumer product without an easily removable battery contain the three chasing arrows recycling symbol or a comparable recycling symbol, the designation "nickel-cadmium" or "Ni-Cd" and the phrase "Battery must be recycled or disposed of properly." On each rechargeable consumer product containing a regulated battery, which is not easily removable, the required labeling is "Contains nickel-cadmium battery. Battery must be recycled or disposed of properly."

The easy removeability provision is also specified in the 1996 legislation and was an early requirement in several of the state NiCd battery recycling laws. These provisions were developed at the time when many NiCd battery power tools and appliances did not provide for easy removeability, mainly as a consumer safety measure. Since the early 1990s, however, battery operated tools, appliances and other devices have been designed so that in most cases the batteries are easily removable while still ensuring consumer safety. In fact, many manufacturers of battery powered tools today market replacement battery packs, which are interchangeable in a number of different tools. Only in certain systems such as computer memory backup and medical devices are the batteries permanently installed to avoid system failure.

The Charge Up to Recycle! program features three different avenues of collecting used NiCd batteries for recycling:

• Retail Recycling Plan (over 30,000 locations)

• Community Recycling Plan (300 enlisted)

• Business & Public Agency Recycling Plan (1,800 enrolled)

By offering a different type of collection method to each target audience, this program is designed to obtain the maximum return of the small sealed NiCd batteries from each sector. These batteries could only have been collected by these mechanisms provided that the regulatory relief which is embodied in the exemptions granted under 40CFR, Part 273 for the storage, handling and shipment of used NiCd batteries intended for recycling was developed. Essentially, this regulation exempts the diffuse sources such as the retail outlets, county and municipality collection points, commercial/institutional generators, and individual consumers from any regulatory burdens associated with collecting and shipping their used NiCd batteries back to centralized collection or "consolidation" points or directly to the NiCd battery recycling facility itself. In the Charge Up to Recycle! program in the United States today, Kinsbursky Brothers of Anaheim, California and INMETCO in Ellwood City, Pennsylvania are the two RBRC consolidation points for collected NiCd batteries, while INMETCO is also the NiCd battery recycler.

Publicity and public awareness of the program has been generated through a number of means, and is increasing. To make the program work and develop the levels of NiCd battery recycling desired, widespread public education and outreach is required. This has been provided by a number of approaches including:

• Prime Time Television Celebrity as Program Spokesperson

• Nationwide Toll-Free Voice Automated Response System

• Information and Collection Kits for Retail Outlets

• Collection/Shipping Arrangements with Municipalities

• Collection/Shipping Arrangements with Institutions/Corporations

Finally, a funding scheme was implemented to pay for the recycling program, and it is paid for entirely by the rechargeable power industry. In order to assure equitable funding, entities at various levels of the manufacture and distribution chain (cell manufacturers, battery pack assemblers, battery marketers, and product manufacturers and marketers) may license the right to display the trademarked and EPA-certified

Figure 1. Trademarked RBRC Seal for Licensees

RBRC seal, shown in Figure 1, on their products. The licensing fee is proportional to the size of the cells incorporated in the product.

The program also provides incentives for licensees to utilize their own distribution infrastructure to collect batteries and recycle them in a manner similar to that of the commercial/institutional generators. Licensees can receive a rebate of up to 75% of their original licensing fee based on the weight of batteries collected for recycling through their own infrastructure. To date, there are approximately 325 licensees signed up for the Charge Up to Recycle! Program, including virtually all of the major producers and users of NiCd batteries in Canada and the United States.

The RBRC program has the support of over 30,000 collection sites in the United States and Canada where consumers can drop off their used NiCd batteries for recycling. Participating retailers in the United States include ACE Hardware, Ameritech, BellSouth Cellular, Black & Decker, Car Phone Store, Cellular One, Circuit City, Radio Shack, Sear, Target and Wal-Mart. Consumers can locate the collection locations nearest them by calling 1-800-8-BATTERY (1-800-822-8837) or by visiting RBRC's website at www.rbrc.org.

The RBRC Charge Up to Recycle! Program was launched in Canada in 1997, and has now received the endorsement of Environment Canada and Natural Resources Canada. An EcoAction Network was established by Environment Canada to create public awareness for positive environmental actions taken by Canadians. The Network's objective is to demonstrate how entities such as RBRC are contributing to a healthier environment - and thereby encourage others to take similar actions across the country. This recognition acknowledges the proactive and voluntary action of the RBRC in developing and successfully implementing the program.

The only battery management program of its kind in Canada, the RBRC program is available to all Canadians. Consumers can take their used NiCd battery to any of the more than 4,500 retail outlets that serve as collection sites. Participating Canadian retailers include Astral Photo Images, Authorized Motorola Dealers, Battery Plus, Black's Photography, Canadian Tire, Radio Shack Canada, Zellers, Personal Edge, and Centre du Rasoir.

The effectiveness of the RBRC program is demonstrated most clearly in the amounts of NiCd batteries collected for recycling in the program over the six years. These data are summarized in Figure 2.

These data show an almost 52% increase in the collection of NiCd batteries in Canada and the United States from 1995 through 2001, an average of 8.6% per year improvement, and clearly demonstrate the effectiveness of the RBRC Charge Up to Recycle! Program.

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