Draft SOP for Lead recycling units desirous of importing lead scrap/lead acid battery scrap


The Ministry of Environment, Forest & Climate Change (MoEF&CC) has recently issued comprehensive Draft Standard Operating Procedures (SOP) for the recycling of lead scraps, including scrap lead-acid battery waste, lead acid battery plates, and other lead-based scraps and residues. These guidelines are aimed at ensuring environmentally responsible recycling practices and maintaining the safety and health of workers in the lead recycling industry.

Requirements for Seeking Permission for Import of Lead Scrap/Used Lead Acid Batteries for Recycling:

  1. Authorization from SPCB/PCC: Entities seeking to import lead scrap or used lead acid batteries for recycling must possess valid authorization from the concerned State Pollution Control Board (SPCB) or Pollution Control Committee (PCC) under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. The guidelines for authorization, including recycling facilities and standard operating practices, are detailed in Annexure-I.
  2. CTOs and Authorization: Valid Consents to Operate (CTOs) and authorization under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, are mandatory.
  3. Registration on EPR Portal: Lead recycling units must register themselves on the Extended Producer Responsibility (EPR) portal developed under the Battery Waste Management Rules, 2022, by the Central Pollution Control Board (CPCB).
  4. Compliance with Plastic Waste Rules: Units importing lead scrap, specifically Rains/Rinks, are required to comply with the provisions of the Plastic Waste Management Rules. They must also register on the centralized Extended Producers Responsibility Portal for Plastic Packaging and fulfill their obligations as importers of plastic packaging material, as per the ‘Guidelines on Extended Producer Responsibility for Plastic Packaging’ notified in February 2022.

Minimum Required Facilities and Standards for Secondary Lead Recycling Units:

Secondary lead recycling units must have either a Rotary furnace with a suction hood connected to Air Pollution Control Systems (APCS) over the charging point or a Mandir Bhatti with a suction hood connected to APCS over the charging point and molten metal tapping point.

Emission/Discharge Standards for Lead:

SPCBs/PCCs are mandated to prescribe the following emission/discharge standards for lead:

  • Lead in work area, NIOSH 8-hour average (mg/m3): 0.05
  • Lead in emission through stack (mg/Nm3): 10.0 (already notified)
  • Lead in effluents (mg/l): 0.10 (notified general standard)
  • Lead in factory premises near the boundary wall 24-hour average (µg/m3): 1.0 (µg/m3 – normal cubic meter)
  • Workers Blood Lead Levels: Lead-related units should regularly examine their workers for lead levels in blood and urine. Workers with elevated lead levels (greater than 42 micrograms/dl) should be immediately transferred to non-lead activity areas and provided with special medical treatment until their lead levels return to an acceptable level (10 micrograms/dl).

Minimum Requirements for Transportation of Used Lead Acid Battery Scrap (Rains/Rinks Batteries):

The guidelines provide detailed instructions for the safe transportation of used lead acid battery scrap, emphasizing the need for secure packaging and handling procedures to prevent environmental contamination and ensure worker safety.

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