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checkImplement a facility-wide battery recycling program.

All PIM content was independently developed and reviewed to be vendor-, product-, and service provider-neutral.


Establishing or improving upon a facility-wide battery recycle program will reduce the negative human and environmental impacts associated with improper battery disposal, achieve regulatory compliance and enhance staff engagement within your sustainability efforts.

  • Project Talking Points

    • Batteries contain heavy metals such as mercury, lead, cadmium, and nickel.
    • Improper disposal of batteries poses a significant threat to public health and the environment. When batteries are incinerated or landfilled, they can release heavy metals and other hazardous substances that contaminate groundwater and pollute the air.
    • Numerous resources exist for the recycling of batteries. Make sure your battery recycler properly manages these products to end-life. Check with your hazardous waste vendor, local battery store, etc.
  • Triple Bottom Line Benefits

    • Cost benefits–– Battery recycle programs are often cost-neutral or add expense to your waste management budget.
    • Environmental benefits - Proper disposal of batteries reduces/eliminate heavy metals from entering and negatively impacting the natural environment.
    • Social benefits – Improved public health through the reduction of heavy metals entering the environment and polluting air and water systems.
  • Purchasing Considerations

    If you have suggestions for purchasing considerations, or suggested sample contract language for any product or contracted service, please participate in the discussion below.

  • How-To

    1. Identify a battery recycling vendor.
      • Numerous resources exist for the recycling of batteries. Make sure your battery recycler properly manages these products to end-life. Check with your hazardous waste vendor, local battery store, etc.
    2. Conduct a facility walkthrough to determine battery container placement.
      • Battery collection containers (typically gallon utility pails) are placed throughout the facility in areas such as soiled utility rooms, nurse stations, break rooms, copy rooms, etc.
      • Hospitals use batteries in equipment such as pacemakers, defibrillators, fetal monitors, heart monitors, pagers, telemetry devices, temperature alarms and blood analyzers, pumps, diagnostic equipment, otoscopes, opthalmoscopes, dictation machines, pen lights, glucometers, flashlights and telemetry devices. Batteries are used in portable generators, wheelchairs, lighting and a myriad of electronic devices. Ensure battery collection containers are placed in areas where this type of equipment is utilized.
    3. Work with Environmental Services to define a collection process.
      • Consider integrating the battery collection process into an existing waste management route, i.e. recycling or RMW collection.   
    4. Determine battery storage location.
    5. Label and package batteries according to regulation and best practice.
      • All handlers of universal waste need to mark or label the universal waste or a container of the universal waste for the purposes of identifying the type of universal waste and to let inspectors know that you have chosen to handle these hazardous wastes as universal wastes. An inspector will assume these wastes are hazardous wastes unless you clearly designate otherwise.
      • Batteries are to be labeled as follows: Universal Waste Battery(ies); or Waste Battery(ies); or Used Battery(ies). Refer to the EPA’s Battery website for more information.
      • Packaging requirements for battery disposal is regulated by the Department of Transportation (DOT) and has become quite rigorous over the past few years. Veolia Environmental Services has developed a guidance document on battery packaging guidelines (Veolia-Battery-Packaging-Guidelines-rev-9-01-09.pdf) that will help ensure compliance.
    6. Develop a battery tracking and reporting program.
      • Work with your battery recycling vendor to provide monthly volume and cost reports.
      • As for recordkeeping that is required by law, only large quantity handlers of universal waste (LQHUW) are required to keep records of where they are sending their universal waste and if applicable, any universal wastes they are receiving from others. There is no specified form for these records. The only requirement is that when a LQHUW is shipping universal waste off site, the records must show the name and address of the facility to whom the wastes are being sent; the quantities and types of waste they are sending that facility; and the date of shipment. These records must be kept for three years. For more information refer to the Health Care Environmental Resource Center.
    7. Ensure staff handling, transporting, labeling and packaging batteries are trained properly. Partner with your battery recycling vendor as they typically offer professional staff training programs/certification courses. Require as part of the training that staff are able to respond and manage emergency response situations.
    8. Conduct a site visit of your battery recycling vendor to understand their collection, treatment and reporting process. Ensure they comply with all state and federal regulations. See Health Care Environmental Resource Center and the EPA’s Battery website for more information.
    9. Launch battery recycling program.
      • Ensure all staff receive appropriate education on battery recycling, including where to find the nearest container, what to recycle and how the collection process works.
      • Develop a reporting feedback process that communicates battery recycling progress, particularly the volume of batteries recycled.
  • Tools

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  • Regulations, Codes and Standards, Policies

  • PIM Synergies

  • Education Resources

    If you have any information or resources to contribute, please contact us or participate in the discussion below.

  • More Resources

    • EPA Battery Disposal Resource
    • Healthcare Environmental Resource Center
    • Earth 911
    • Wisconsin Department of Natural Resources Battery Recycle Guide (Sample Battery Recycle Guideline.pdf)
    • Health Care Without Harm – This site contains a valuable fact sheet for hospitals called Battery Roundups: Get Charged! This fact sheet provides an overview of the different types of batteries used in hospitals and discusses how, through a battery roundup, hospitals can safely and properly collect, manage, and properly dispose of or recycle batteries.
    • Call2Recycle is a non-profit public service organization dedicated to recycling used rechargeable batteries and old cell phones. Call2Recycle collects the Nickel Cadmium (Ni-Cd), Nickel Metal Hydride (Ni-MH), Lithium Ion (Li-ion), and Small Sealed Lead *(Pb) rechargeable batteries that power a variety of portable electronic products such as cellular and cordless phones, power tools, laptop computers, camcorders, two-way radios, and digital cameras. Through its national program and with the help of retail and community partners, these items can be recycled through a convenient and environmental-friendly way.
  • PIM Descriptors


    Level: Beginner

    Category List:

    • Hazardous Waste
    • Recycling
    • Universal Waste

    PIM Attributes:

    • Environmental Health and Safety
    • Measurement and Reporting
    • Optimize Operations
    • Waste Reduction

    Improvement Type:

    • Recycling


    • Environmental Services
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