OSHA HazCom 2012
OSHA Stance on Wearable Lithium Batteries

Here’s the thing. I am a TV junkie. A huge amount of my time has been dedicated to researching new shows, setting them up on my DVR, and watching said shows. One that has my attention right now is “The Rookie” starring Nathan Fillion. In the show, he is a 40-year old rookie cop in Los Angeles. It has my attention for multiple reasons aside from the obvious. The main REGULATORY one is the fact that every officer on the show wears a body camera. It got me to thinking … surely those body cameras come with rechargeable batteries. If so, what happens when in the course of the show, one of those cameras is damaged? My brain then jumped to what about workers who wear battery powered devices.

Believe it or not, OSHA recently published in their newsletter an article called, “Preventing Fire and/or Explosion Injury from Small and Wearable Lithium Battery Powered Devices”. You can find the article at https://www.osha.gov/dts/shib/shib011819.html.

In this article, they do a good job describing batteries and cells as well as how they work. There is also a lengthy section on lithium battery hazards including what can cause enough damage to create fire and explosion risks. These include such things as physical impacts, usage/storing at temperatures too high or too low and failure to follow the manufacturer’s instructions.

As to ways to prevent injuries from these devices, there is a good list of things any worker should follow to prevent possible injuries. These are things everyday users of devices with lithium batteries should also follow.

Preventing Workplace Injuries from Lithium Batteries

  • Be sure the batteries are appropriate, tested, and rated for their use.
  • Follow proper instructions and directions for how to charge, store, and maintain batteries.
  • If replacing a battery, check that the new battery is designed for the device and from a reputable dealer/seller.
  • Once fully charged, remove the device from the charger or charging station.
  • Keep lithium batteries and equipment that uses them in cool and dry locations. OSHA even suggests using “fire-resistant” containers.
  • Inspect batteries for damage – bulges, cracks, leaks, smoke, and high temperatures during usage and remove the device or battery immediately should any of these occur.
  • Damaged/defective batteries should be placed away from flammable materials and disposed of in accordance with all regulations and per a battery recycling center’s disposal instruction.
  • Know how to put out battery fires. Water is not an option here given the reaction of lithium metal with water.
  • Have proper training on the products, devices, hazards, and emergency plans for these battery-powered devices.

On a side note, which many may not know, OSHA has stated in a 2015 letter of interpretation to 2 companies that lithium batteries do not meet the definition of “article” under the HazCom2012 standard. While not yet released to the public, this has huge implications. In the letter, if lithium batteries are not used for “commercial applications” then it must follow all of the OSHA HazCom2012 standards including the need for a safety data sheet and shipped container labels.

The bottom line from all of this, lithium batteries and the devices they are in must be handled in the same way other hazardous chemicals are in regards to worker knowledge, safety, and training.

Give ICC a call today for any battery questions you may have. Stay safe out there.For more information, visit ICC Compliance Center’s website or call one of our Regulatory Specialists today! USA: 888-442-9628 | Canada: 888-977-4834

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