The issue of factors that must be considered in the formulation of regulations
related to lead acid battery management is a matter of life cycle management of
a product and its components from production to disposal. At each stage, safety
must be the prime consideration. For lead acid batteries, this requires risk
assessment of everything from the extraction of lead to the disposal of those
components of the batteries, which cannot be recycled. Each stage involves
potential harmful exposures to components of the batteries or their derivatives
and these exposures are dependent upon circumstances and what is possible to
minimize them. It is relatively easy to monitor and regulate effectively a few
large-scale centralized facilities but almost impossible to monitor and regulate
individual usage and small family businesses. Ultimately, good public education
on the safe usage and disposal of potentially harmful materials is the only
basis for effective regulation to protect our health and our environment.

The recycling of used lead acid batteries (ULABs) is an important source of
environmental contamination with lead, leading to human exposures and lead
poisoning. This is particularly the case with informal ULAB recycling, and mass
lead poisonings have resulted. The technical guidelines on ULAB recycling
jointly produced by the Basel Convention and UNEP
(http://www.basel.int/TheConvention/Publications/TechnicalGuidelines/tabid/2362/Default.aspx)
provide plenty of guidance that can be translated into regulations. These
should include measures to control informal recycling, the establishment of
emissions limits from recycling sites and mechanisms to monitor compliance. They
should also include the need for worker training and exposure monitoring.

Two key generic considerations in the formulation of regulations are efficient
recycling and disposal of batteries and their components. The regulations should
take into account the options readily available and practically feasible under
the given setting where the regulated community could effectively implement the
regulations that ensure proper recycling and disposal.

A system to recover the batteries at the end of its active life as well as the
assurance of proper procedures undertaken during maintenance/repair in the field
is important aspects to consider too.