Property Types

Recycler - Battery

Battery recyclers are critical in the sustainable management of battery waste. They specialize in the collection, disassembly, and processing of various types of batteries, ranging from household alkaline batteries to industrial-scale lithium-ion batteries used in electric vehicles and portable electronics. In performing these services, recyclers face significant environmental exposures throughout their operations, including air pollution from emissions generated during recycling processes, water and soil contamination from leaching heavy metals, and challenges associated with managing hazardous waste streams. As demand for battery recycling continues to rise, it will be critical to address these environmental exposures to protect environmental and human health.

Download PDF

Environmental Exposures May Include

Air Emissions
Heavy Metal Leaching & Ground Contamination
Hazardous Waste Management
Storage Tanks
Stormwater Run-off
Equipment Leak & Spills

Air Emissions

Battery recycling operations can emit various pollutants into the air, including particulate matter, sulfur dioxide (SO2), nitrogen oxides (NOx), and volatile organic compounds (VOCs). Third-party bodily injury claims can result.

Heavy Metal Leaching & Ground Contamination

Improper handling or disposal of battery recycling byproducts can lead to soil and groundwater contamination. Inadequate containment of battery recycling material or spills can result in a release. Heavy metals leaching from batteries can accumulate in the soil, impairing soil quality and posing risks to plants, animals, and humans through the food chain. Leaching of heavy metals such as lead, cadmium, mercury, and nickel from batteries can contaminate groundwater and surface water bodies, posing risks to aquatic ecosystems and human health. Third-party bodily injury and property damage claims can result.

Hazardous Waste Management

Battery recycling generates hazardous waste streams containing toxic chemicals and heavy metals. Inadequate characterization and management of these wastes can lead to improper disposal in landfills or illegal dumping, increasing the risk of environmental contamination and endangering wildlife and ecosystems, resulting in environmental cleanup and tort liability.

Storage Tanks

Aboveground or underground storage tanks may store wastewater, products, gasoline, diesel fuel, lubricants, motor oils, coolants, hydraulic fluids, heating oils, or other chemicals at battery recycling facilities. Spills or leaks of chemicals may occur during storage, during loading/unloading, during use, or from equipment. These releases can impact soil or groundwater, migrate to surface water bodies or drinking water sources, or impact indoor air through vapor intrusion.

Stormwater Run-off

Stormwater that comes in contact with stored stockpiles of batteries to be recycled can collect heavy metals, including lead, cadmium, mercury, and nickel and become contaminated. If the stormwater run-off is not properly controlled, contained, and pre-treated before discharge into sanitary or storm drainage systems, it could impact groundwater, surface water quality, and aquatic systems.

Equipment Leak & Spills

Collection vehicles, conveyor belts, sorting machines, and other production equipment may leak lubricants, oil, grease, or fuel. Spills or leaks can occur from stock supplies or during maintenance and fueling. Releases can contaminate soil, may be collected in stormwater run-off, or contribute to fire hazards.

Environmental Pollution Liability Can Provide Coverage For

Integrated GL/Site Pollution, options to include Excess, Auto and WC may be available

Monoline Site Pollution Liability

Third-party claims for bodily injury, property damage

First-party and third-party cleanup

Defense of third-party claims

Emergency response costs

Natural resource damage

First and third-party transportation pollution liability

Loading and unloading

Products pollution liability

Crisis/reputation management

Civil fines and penalties

Off-site services pollution liability

Business interruption expenses

Non-owned disposal sites

Claims Scenarios & Examples

A recycling facility was found to be mismanaging scrap batteries. As a result, lead and other hazardous substances were leaking onto the ground. The Department of Environmental Conservation (DEC) investigated the facility and found batteries were being stored on-site with a lack of secondary containment. The recycling company was fined and ordered to clean up the site and the contaminated soil.
State regulators found two battery recycling companies were mishandling co-contaminated dust, which contained various metals, and that the dust should have been classified as hazardous. The recyclers were found selling the dust for smelting and refining as they thought it was a recyclable material. The state environmental regulatory department issued violation notices for improper storage, treatment, transportation, and disposal of hazardous waste and hazardous dust found on the facilities’ floor. As part of the settlements, the recyclers agreed to pay $400,000 and $390,000, respectively and began incorporating better management practices.
A car battery recycling plant in South Carolina was forced to shut down after only ten years of operation due to repeated violations of environmental laws and fines totaling over $375,000. The plant is believed to have polluted the soil near the plant, which has tested positive for elevated levels of lead. Ongoing lead sampling is being conducted and any cleanup will be the responsibility of the battery recycler.
A former battery recycling plant is believed to have caused high levels of arsenic and lead contamination in a nearby community, exposing more than 100,000 people. Lead concentrations on resident properties as far as 4.5 miles from the former plant tested for levels above state standards. The Environmental Protection Agency is currently evaluating adding the plant to the Superfund list. Cleanup efforts from the state have failed and residents have become sick from the contamination. The former operator of the plant was fined and then became insolvent.

Final Consideration

Your business can be faced with the cost to defend itself against allegations or legal action from pollution related events, regardless if you are at fault or not. Having the proper insurance coverage in place will help fund the expenses incurred to investigate or defend against a claim or suit and provide you with environmental claims handling expertise.

Disclaimer

This environmental risk overview offers a general understanding of potential risks and may not reflect all risks associated with your business. Environmental Risk Professionals has compiled this overview for informational purposes only. This overview does not constitute legal opinion or advice, nor does it establish a consultant-client relationship. This overview is not intended to guide project parties in interpreting specific contracts or resolving disputes; such decisions may require consultation with counsel and depend on various factors. © 2025 Environmental Risk Professionals, LLC

Download PDF