Transportation – R&D Batteries NiCd Batteries User Manual
Page 2
Notice: The information and recommendations set forth are made in good faith and are believed to be accurate at the date of preparation.
Panasonic Industrial Company makes no warranty expressed or implied.
Panasonic_NiCd_D_Info.doc
Page 2 of 2
Product Information
Panasonic strongly recommends that all of its customers join the RBRC Nickel Cadmium Recycling Program thus,
allowing you to use the following License Seal, which meets all the labeling requirements of the 1996 Federal
Battery Law.
Nickel Cadmium batteries destined for recycling can be managed under the federal Universal Waste Rule codified at 40
CFR Part 273.
In the event of disposal, dispose only in accordance with federal, state and local regulation. Batteries generated as a
waste are subject to the Resource Conservation and Recovery Act (RCRA) as a D006 (cadmium) hazardous waste.
Transportation
Panasonic sealed Nickel Cadmium batteries are considered to be “dry cell” batteries and are unregulated for purposes
of transportation by the U.S. Department of Transportation (DOT), International Civil Aviation Administration (ICAO),
International Air Transport Association (IATA) and the International Maritime Organization (IMO). The only
requirements for shipping these batteries by DOT is Special Provision 130 which states: "Batteries, dry are not subject
to the requirements of this subchapter only when they are offered for transportation in a manner that prevents the
dangerous evolution of heat (for example, by the effective insulation of exposed terminals). The only requirements for
shipping these batteries by ICAO and IATA is Special Provision A123 which states: “An electrical battery or battery
powered device having the potential of dangerous evolutions of heat that is not prepared so as to prevent a short-circuit
(e.g. in the case of batteries, by the effective insulation of exposed terminals; or in the case of equipment, by
disconnection of the battery and protection of exposed terminals) is forbidden from transportation.”
All Nickel Cadmium batteries are classified as a D006 hazardous waste because of the presence of cadmium. This
waste code is assigned because of toxicity, not corrosiveness. These batteries do not meet the definition of a
corrosive waste.