Lithium-Ion Battery Disposal: What You Need to Know

Energy Hazards | By CHRIS PFAFF and CHRIS G. GREENE 

We’ve been hearing quite a bit about the hazards of lithium-ion batteries over the past few years. Well-established groups such as the Seattle (WA) Fire Department, the Fire Safety Research Institute (FSRI), the Fire Department of New York, and others have worked hard to provide many lessons on how to extinguish fires caused by lithium-ion batteries. What to do with them remains a challenge for many agencies across the nation and the world. In this article, we will discuss some options currently available to agencies as well as possible options for the future.

• The Lithium-Ion Revolution
• Lithium-Ion Batteries: The 18650

The debate over whether lithium-ion battery fires should be dropped into the hazmat response bucket, the fire response bucket, or the emerging energy response bucket continues. This conversation is happening on both the national and international fronts. Lithium-ion battery fires qualify as all three, if not more, depending on the threat at hand. A simple example is an auto accident with a battery electric vehicle with injuries, entrapment, and eventual fire. This scenario obviously has the major focus of auto extrication and possibly technical rescue, if the vehicle is large enough.

EMS plays a major part as well, due to the injuries involved. As the event progresses, the fire rescue bucket becomes an important component of the response. Evaluating water or air contamination and support for disposal would easily fall into the hazmat response bucket. Throughout the entire event, the emerging concept of energy response, heralded by the Seattle Fire Department and its energy response team, plays a major role. We can even involve our second responders, the tow-truck operators, to see how quickly an incident like this becomes a highly technical event that’s intensive for staffing, training, and risk (photo 1).

1. Photo by Eric Hurst.

Compare the previous event with a garage fire with five to 10 lithium-ion batteries for power tools, a micromobility device, and a few lithium-ion-powered yard maintenance tools items, such as lawnmowers or snowblowers. In this scenario, many of the same technical disciplines remain. And an important question comes up during this event: What do we do with the damaged batteries?

Available Options

In our first scenario, at the international level, SAE J2990 currently guides the discussion on what second responders will do with fire-damaged EVs, where to store them, how to store them, and how to ensure safety throughout the entire process.¹ However, during the event in the second scenario, we don’t have the support of any standard on how to dispose of these batteries. In addition, we now also face considerations concerning personal property, fire investigation, and responder safety. So what do we do? Here’s a look at our options.

Option 1

We could leave the batteries in the garage, as we want to keep the scene as pristine as possible for the fire investigator to conduct a proper and thorough investigation for fire cause and origin.

Is this a good idea? Absolutely not. You can find ample studies proving that lithium-ion batteries that become fire-damaged can ignite for many days after the initial fire. The most painful sound for any firefighter is additional tones, just hours after a response, for a rekindle at the same address.

During a structure fire, a message I Greene) delivered comes to mind: “no cell left behind.” We must ensure that a proper and thorough overhaul of the space is performed, to include the removal of all cells. This will ensure we aren’t coming back in a few hours, days, or beyond. An agency in King County, WA, experienced such an event in March 2023. Firefighters secured the power and scene and left it intact for the fire investigator, as is common with most events. Two days later, responders had to return to the house to extinguish a secondary fire that was started by fire-damaged lithium-ion cells that were not involved in the original fire.

Option 2

Once the fire is out and overhaul is conducted, we should relocate all batteries out to the front yard to ensure area separation.

Is this a good idea? This option is much better than Option 1, but it still has flaws. This approach correctly assumes that the investigator would want to perform a thorough investigation to identify the origin and cause of the fire. We must work hard in suppression to ensure the scene is left as intact as possible. This will allow for a valid investigation. When it’s possible for things to be left in place, it’s best not to disturb them. This guideline, however, does not apply to lithium-ion batteries, as they still pose a hazard to the structure and any occupants within it.

What is an ideal course of action? The best option is to keep a crew on scene and a hoseline deployed until the public fire investigator arrives to perform an initial investigation. If this option is not possible due to staffing or possible delays with investigators, it’s time for the lead officer to provide double duty.

A rudimentary photo documentation by any firefighter can work (photo 2). Although this is not the optimal situation for the fire investigation, it may be your only option. The lead officer should use a department-issued camera or cell phone to ensure good lighting and keep responders out of the camera shots. Once a photo documentation of the area exists, removal of the cells can begin.

2. Photos courtesy of Chris Pfaff unless otherwise noted.

Option 3

Once the fire is extinguished and an investigation is performed, request hazmat technicians to come out to dispose of the cells (photo 3).

3.

Is this a good idea? Option 3 really serves as a second step to Option 2. At the least, departments should consider it for the current status of laws across the fire service. If we look back at Option 2, what will happen with the cells after the fire department, investigators, and other parties release the scene back to the responsible party? We hope the homeowner will contract out a proper cleaning agency to safely dispose of the batteries.

But what if they don’t? If the damaged batteries end up in the traditional waste stream, they may pose yet another threat to the community through secondary fires in garbage trucks, at waste transfer stations, and farther down the waste stream. We are currently seeing a major spike in waste facility fires (Figure 1).

Figure 1. Recycling Plant Fires in the United States and Canada, 2016 to 2023

Figure 1 demonstrates the increase in recycling plant fires in recent years.

(Source: Ryan Fogelman, rfogelman@firerover.com.)

The Difficulty of Proper Disposal

To fully understand the difficulty we are facing as we explore the proper disposal of these batteries, we must first look at the history of this task and how the past may help us guide the future.

The History of Hazmat

In the late 1970s, large cities began forming hazmat response teams to respond to the more severe events happening in their response areas. As time passed and more significant events made the evening news on a national scale, the federal government acted to provide a few detailed guidelines on the responsibility of who owns hazmat.

In 1976, the Resource Conservation and Recovery Act (RCRA) was passed. This was a major step in creating ground rules for hazmat storage, use, emergency response, and disposal. While many of these national regulations seem disconnected from responders, the simple way to explain this law for our use is the term “from the cradle to the grave.”

What Does It Mean?

The moment a hazardous material is created, pulled from the ground, or extracted from the air, it has a designated owner. The path of ownership continues from the creation, initial storage, transportation, long-term storage, use, all the way to disposal, if the hazardous material is still considered hazardous after use. For example, if someone knocks on the door of the fire station to give you a can of brown goo they found down the road and you kindly accept the hazmat just to be a good steward of the community, you have taken ownership of this hazmat. Your agency is now 100% responsible for the safe storage and eventual disposal of it.

The Environmental Protection Agency (EPA) and state-funded environmental agencies now hold much of the responsibility for hazardous materials that are found to have no current owner. In these cases, we must dig slightly deeper. Think about gasoline, the most common hazardous material in the modern consumer world. From the moment gasoline is pulled out of the ground as crude oil, to the transport, storage, processing, continued storage, additional transport, final storage, and ultimate consumer use, a verified owner exists.

The moment the gasoline is pumped into the cylinder of an engine, mixed with air, and ignited by a spark plug to provide that smooth idle of your gas-guzzling ultra-mega truck, the products from the gasoline are no longer considered a hazardous material.

The release of water vapor, carbon monoxide, carbon dioxide, oxides of nitrogen, and any other gaseous emissions are no longer hazmats. Now we have other regulations regarding air quality, but those fall under different categories. The Department of Energy’s definition of a hazardous material is “any solid, liquid, or gaseous material that is radioactive, toxic, explosive, flammable, corrosive, or otherwise physically or biologically threatening to health.”²

So, lithium-ion batteries fall into this group, right? Not quite. The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1986, otherwise known as Superfund, was a law that, according to the EPA, “created a tax on the chemical and petroleum industries and provided broad Federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment.”³

To define hazardous waste, the EPA created an original list of hazardous waste. When you look at the list, you will be able to identify all the chemicals that are currently regulated federally by the EPA for storage, cleanup, public, and responder information. Among these thousands of chemicals, there is currently no mention of lithium-ion batteries.⁴

How Do We Solve This?

We currently do not have the assistance at the federal level to seek reimbursement for any removal or cleanup we conduct. Until that is figured out, we have the responsibility to keep our communities safe from these hazards (photo 4).

4.

We have the responsibility to remove these cells safely from the building, but we do not want to disturb the scene. If the fire investigator has not arrived by this time, it is time for the officer to take charge and provide an initial photo documentation that was taken prior to anything being removed. Ensure that no responders are shown in the pictures and ensure that the photos have proper lighting.

A search for any remaining cells that have not gone into thermal runaway needs to be conducted visually and with a thermal imaging camera (TIC). Understand that a TIC may not see all cells. Thermal runaway may be a fast process when it begins, but it may take a significant amount of time for this to begin.

Once the batteries are outside, they must be far enough away from the house or contained well enough that a rekindle is not a risk. Steel overpack drums and a granular fire suppressant are a good option for this. The downsides to this method include cost and storage. A full battery pack shouldn’t be placed in these drums; however, we should not be dismantling these batteries either. This is the mission creep of our field, and it is expanding beyond our training.

Understanding our operational guardrails is of paramount importance. We are a fire and life safety resource, not a cleanup team. This includes lithium-ion batteries. We must honor these operational guardrails and recognize when we are operating beyond them. Removing batteries for overhaul purposes will help to ensure that we do not have a rekindle that involves said structure. However, fire crews tearing apart battery packs should not be a practice we engage in. There are private companies that do this 24/7, and they are licensed, bonded, and insured just for this purpose.

After the batteries are removed, support from your local hazmat team or local environmental cleanup agency is necessary. It is better to know their process prior to the fire ever occurring, so begin those discussions and have those partnerships in place before the tones ever drop. Many new laws to support this process are in the works, so check your local and state regulations and agencies for possible support.

Post-Removal Steps

Once your department has safely removed the batteries from the structure, responders have multiple options to consider. The decision will most likely depend on the logistical support that an agency can provide. The largest agencies already have plans in place. Following these systems is a good practice in theory, but sometimes doing so is not the most practical approach.

The largest agencies typically request out their hazmat team or energy response team to disassemble battery packs and overpack individual cells into containment drums for disposal with contracted or governmental agencies for later disposal. This tactic is an effective method, but it requires significant training. For many, this method may progress beyond responders’ abilities, mission, or scope. It is important to remember our mission, which is threefold:

1. Life safety.
2. Incident stabilization.
3. Property conservation.

If we look further into the hazmat world, we can see an additional level of protection: the environment. Most agencies should refrain from disassembling battery packs, as this can cause evidence spoliation and injury to responders. It is also beyond our scope.

Disposal

Even with these limitations, disposal is still an option. Most hazmat teams can assist with disposal without disassembling the entire battery unit. Although this is not as effective as the previous method, it will allow insurance investigators to properly examine evidence as needed. This will also prevent potential injury to responders from stranded energy held within the batteries.

More importantly, the decision about when the fire department should assist in disposal is a heavy one for responders to consider. Once again, we must recall our scope and be sure that mission creep does not occur in this new field. If we look back at our first example of the EV incident, our second responders are vested with the responsibility of transport, disposal, and storage of the damaged vehicles.

At the national level, teams are hard at work identifying solutions for EVs, and some already have a good system in place. Energy storage systems (ESS) absolutely should not be disassembled by responders, and the disposal and cleanup responsibility should be passed on to the energy company and associated contractors. Also, loose batteries in households need to be removed, but disposal should not be the responsibility of the fire service.

Exceptions to Disposal Guidelines

It’s rare, but responders occasionally feel the owner of the battery will not handle disposal appropriately. This may occur when there are small amounts of batteries or when the owner of a micro-mobility device has left the scene.

Until we have full systems in place for this disposal, it is our responsibility to ensure that secondary fires do not occur. It is only in these rare cases that we should step in with trained responders.

A plan must be in place before these possible circumstances occur. Containment drums with granular fire suppressant capable of absorbing toxic gases and heat must be procured. Another option is to use a calculated brine solution to discharge the stranded energy in the batteries, although the EPA is still conducting research on the total efficacy of this method.

The transportation plan must allow for the potential of energetic events occurring during transport. Most importantly, a storage location and shipping plan must be planned as well. There are companies that offer shipping services and supplies for this process.

Billing

A final consideration is billing. The fire service typically isn’t in the business of billing for anything other than EMS transports, so this may be the most daunting process. Depending on the possible volume of events in your jurisdiction, this may not be enacted.

Remember the Scope

The most important item to remember when preparing for any of these events is to not get beyond the scope of your mission. If you have alternatives to the disposal of batteries that do not require overpacking, transporting, storing, and shipping batteries, consider them. At this time, however, that may not be possible.

Be sure to check your local agencies, tow operators, waste management agencies, and cleaning contractors to identify their capacity, response time, and knowledge of this new hazard. Once you have identified this information, you can make an educated decision regarding whether your agency should implement a disposal plan.

ENDNOTES

1. “Hybrid and EV First and Second Responder Recommended Practice,” SAE International, July 29, 2019. bit.ly/4bklm3n.

2. “Hazardous Material(s),” U.S. Department of Energy, August 11, 2016. bit.ly/3JLictn.

3. “Superfund: CERCLA Overview,” United States Environmental Protection Agency, updated October 30, 2023. bit.ly/4bhiKmM.

4. “Defining Hazardous Waste: Listed, Characteristic and Mixed Radiological Wastes,” updated February 7, 2024. bit.ly/4b0sJgr.

Authors’ note: Special thanks for technical specifics to Steven Rinaldi, Durango (CO) Fire Protection District, and Fire Law Blog’s Curtis Varone.

---

CHRIS PFAFF is a prevention captain and fire investigator with West Pierce Fire & Rescue in Lakewood, Washington. He is also a hazmat technician and hazmat manager/driver for FEMA’s Washington Task Force 1.

CHRIS G. GREENE is a captain (ret.) with the Seattle (WA) Fire Department and creator of the Seattle Fire Department’s Energy Response Program.