Investment recovery in the telecommunication industry (‘telcos’ for short) is filled with many challenges, made more challenging with an increase in a wide range of surplus equipment due to technological advancements in fiber optics. However, one core investment recovery opportunity that remains constant is reclaiming the nonferrous metal lead from end-of-life batteries, and their recycling at lead smelters. Other industries also maintain a supply of backup batteries, but not to the extent of most telcos.

When managing these batteries for recycling, IR professionals must maintain a cradle-to-grave policy and conduct due diligence to address the liabilities on their proper disposal method. You must adhere to all environmental guidelines concerning the batteries’ recycling and final disposal methods. You must always keep in mind that your department is managing “dangerous goods” and ensure that all government regulations are adhered to as the surplus scrap batteries are warehoused, crated and transported to their final destination.

Key components and their advantages

Managing an effective scrap battery program consists of several key components to maximize your investment recovery value, while also addressing the legal and environmental liabilities.

Obtain a view into your company’s battery removal program.

As much as possible, try to obtain information about the styles and volumes of batteries being extracted, total gross weights of removals, locations and removal timelines. Battery types include large wet cells, steel-cased cells, Absolyte gel cells and various styles of dry cells. As with any other recurring surplus item, the more information you can provide to a potential buyer about the type and volume of the surplus, the better pricing you’ll be able to secure. This data places the IR department into a power negotiation situation when securing pricing per pound with the lead recycler, because you can provide a detailed long-range view on gross weights and timelines.

Importantly, you need to conduct due diligence when securing the battery data because there are scrap batteries heading to recycling that contain the heavy metal cadmium, and you must inform the lead recycler of their existence and related information

Form a relationship with a reputable licensed lead recycler.

This is a vital component, so be sure to build in time to pre-qualify the lead recycler your company is entering into an agreement with. As part of the pre-qualification process, you should request and keep on file a copy of the lead recycler’s license, with identifying site property ID number, license approval number and expiration date.

Once a relationship is established with a licensed lead recycler, negotiations can begin to have the lead recycler act as the consignor on the scrap battery shipments. This includes supplying vitals such as freight logistics, supplying and completing the move-ment document/manifests, supplying four-trailer #8 (“dangerous goods”) placards and securing the POs from the lead smelter on shipments of scrap batteries heading into the smelter for recycling.

Engage a licensed freight company to transport the “dangerous goods” to the lead smelter. IR professionals must adhere to all government regulations and laws when transporting scrap batteries because they are deemed as “dangerous goods,” which requires complete and accurate documentation on the movement document/manifests, including a brief description on the style of scrap battery, battery class, UN number, style of packaging, total gross weights in kilograms and the number of pallets on the shipment.

You should pre-qualify the freight company and ensure it has an equivalency certificate to transport dangerous goods by road, railway vehicle and marine (domestic voyage). Keep on file a copy of this certificate, which will provide data such as certificate number, name of certificate holder, mode of transportation, issue date and expiration date.

Batteries are extremely heavy, so one key component when negotiating with a licensed freight company on the transportation is to ensure the company has an inventory of tri-axle trailers, which will maximize the load weights over a full load of 26 4×4 pallets single stacked on a 53-foot trailer. By using tri-axle trailers, you can maximize load capacity weights while controlling freight expenses.

Complete and record all movement documents/manifests when transporting the scrap batteries. Accuracy and due diligence must be maintained when completing the movement document/manifests to make sure the manifest conforms to all federal and state or provincial transport and environmental legislation. This manifest will provide critical data to several departments, including emergency crews if an accident should occur while the scrap batteries are in transit from the holding warehouse to the lead smelter. Some key components on the movement document/manifest are:

  1. Generator/consignor’s name, address and telephone number.
  1. Intended receiver/consignee’s name and address.
  1. Name of licensed freight company and its address, trailer number, driver’s name and signature, and date of pick-up.
  1. Description of scrap batteries assets, classification of the battery type, UN number (the four digit number used around the world to identify the specific type of dangerous goods being transported), class of packaging, gross weight (kilograms in Canada or pounds in the U.S.) and number of pallets per classification of scrap batteries on the shipment.
  1. Dates of pick-up and projected date of shipment arrival at the lead smelter.

All movement document/manifests must be recorded and kept on file to maintain the cradle-to-grave documentation for every shipment of scrap batteries designated for recycling. This documentation will prove invaluable to the IR department if your company’s safety division conducts an audit on its battery recycling program or if the U.S. Department of Labor conducts 7 an audit resulting from an incident.

 

Secure a “Certificate of Waste Material Recycling-Spent Lead-Acid Batteries” from the lead smelter. This is the final segment of the cradle-to-grave policy when managing a scrap battery program. This certificate is documentation that the scrap batteries have been recycled in a manner consistent with acceptable engineering standards and in compliance with applicable rules and regulations set forth by the various governing authorities.

Documentation and due diligence are the key factors in managing a successful battery recycling program. They will prove beneficial for the IR professional in addressing the attached legal and environmental liabilities when recycling scrap batteries, while also capturing the investment recovery residual value of the nonferrous metal lead.

—Gordon Chennell, CMIR,

Chennell Investment Recovery Services, Inc. Chennellinvestmentrecovery@bellaliant.net 902.396.3609