Control

Prevention through Design: Whether manufacturing or using lithium-ion batteries, anticipating and designing out workplace hazards early in a process adoption or a process change is one of the best ways to prevent injuries and illnesses. It is critical for hazard controls to be addressed in the initial design and construction phases, as well as implemented through changes to management and manufacturing processes as production methods and energy storage technologies evolve. Safety by design includes the proactive substitution and adoption of less hazardous technologies.

Recommended Practices for Safety and Health Programs: Establishing a safety and health management system (SHMS) (i.e., safety program) is an effective way of protecting workers from potential hazards associated with lithium-ion batteries. An effective SHMS can prevent workplace injuries and illnesses by using proactive approaches to find and fix workplace hazards before they cause injury and illness to workers. To be effective, the SHMS must have meaningful worker engagement and participation. In many workplaces, worker participation may include a safety committee that can be used to bring workers and management together to identify and find solutions, and to promote safety and health.

Hierarchy of Controls. The most effective method to eliminate or reduce hazards is to control the hazards at the source.

Transitioning to Safer Chemicals Toolkit is a step-by-step resource with information, methods, tools, and guidance for employers and workers to proactively reduce or eliminate chemical hazards at the source through informed substitution.

Additionally, hazard controls that can be implemented in workplaces that manufacture or use lithium-ion batteries include:

• Ventilation, including local exhaust ventilation (LEV) and enclosures
• Process automation and isolation of hazardous materials
• Storage of lithium-ion batteries and devices in dry, cool locations
• Following National Fire Protection Association (NFPA) guidance for the installation of Energy Storage Systems
• Following manufacturer's instructions for storage, use, charging, and maintenance of lithium-ion batteries
• Limiting the quantity of stored lithium-ion batteries per NFPA 800, Battery Safety Cose, and NFPA 855, Standard for the Installation of Stationary Energy Storage Systems
• Following the manufacturer's guidance on how to extinguish small battery fires
• Continuous monitoring of flammable and toxic gases in large storage locations
• Using shipping guidance provided by the US Department of Transportation and International Air Transport Association (IATA) and following proper shipping and packaging requirements provided in 49 CFR 172 and 49 CFR 173.185
• Disposing of lithium-ion batteries and devices containing these batteries, at designated recycling facilities and not placing them in municipal trash or recycling bins
• Not mixing battery types (e.g. lithium-ion, alkaline, lead acid) in recycling facilities
• Providing safety showers and eyewash stations in locations where exposure to electrolytes may occur
• Developing and implementing an emergency response plan, including emergency procedures, and creating training for response personnel that addresses possible physical and chemical hazards, including hazardous decomposition products (e.g., hydrogen fluoride)
• Conducting a hazard assessment and using proper personal protective equipment (PPE), when appropriate
• Training workers how to identify defective, damaged, or failing lithium-powered devices and batteries

Training

Education and training are important tools for informing workers and managers about workplace hazards and controls. Workers must be trained in a language and literacy level they understand. Appropriate training may include, but is not limited to:

• Hazard Communication (29 CFR 1910.1200) training
• Hazardous Waste Operations and Emergency Response (HAZWOPER) (29 CFR 1910.120)
• Process Safety Management (29 CFR 1910.119)

OSHA's publication, Training Requirements in OSHA Standards, provides a general overview of the training requirements in specific OSHA standards.

In workplaces with lithium-ion batteries, it is important that employers ensure that an emergency action plan (EAP) includes lithium-related incident response procedures based on the manufacturer's instructions and NFPA guidance for responding to battery failures, including fires and/or explosions caused by thermal runaway, and that workers are trained on these procedures.

For workplaces involved in the manufacturing, repair, use, and recycling of lithium-ion batteries, it is important for employers to ensure that appropriate information about the hazards associated with lithium-ion batteries is communicated to exposed workers and that workers receive training on the physical and health hazards associated with these batteries.