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Lithium-ion batteries are everywhere — in cell phones, tablet/laptop computers, scanners, power tools, flashlights, and other devices. OSHA recently posted a Dec. 1, 2022, letter of interpretation (LOI) in answer to questions from the Rechargeable Battery Association that relate to:

  • Who’s responsible for determining if a battery-powered product poses chemical hazards;
  • Whether the batteries fall under the article exemption at 1910.1200(b)(6)(v);
  • Whether battery-powered products fall under the consumer-product exemption at 1910.1200(b)(6)(ix);
  • Whether very small batteries require a HazCom label, and if so, what labeling method must be used; and
  • Whether a shipped pallet of batteries would be considered a container subject to HazCom labeling.

OSHA says it generally agrees that most workers are not exposed to the hazards of a user- (or non-user-) accessible lithium-ion battery as part of the normal condition of use in many end-use products or devices, such as laptops and power tools. However, exposure to potential hazards remains to workers with exposure to batteries during storage, handling, maintenance, failure/exposure detection, and during emergencies.