2.3 Waste, Transport and Battery Fire Documents

2.3 Waste, Transport and Battery Fire Documents

Quick Answer: End-of-life and replacement work is still Learning Outcome 1. Waste Batteries and Accumulators Regulations 2009 cover take-back and disposal when EESS batteries are replaced. Waste Electrical and Electronic Equipment Regulations 2013 (WEEE) cover inverters, modules, and meters at end of life — the handbook extra guidance flags WEEE when you replace equipment. Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2021 (CDG) cover lithium battery transport to and from site, including damaged cells; a spare battery is not general van waste. PAS 63100 is the dwellings battery energy storage fire specification City & Guilds 2922-34 lists in the LO1 non-statutory set: know that it exists and that it deals with location, ventilation, detection, and separation from escape routes. Do not invent clause numbers you have not opened.

This independent OpenExamPrep section is a study resource for City & Guilds 2922-34. Candidates who treat the award as “only new panels on a sunny roof” miss why LO1 includes EESS documentation on a PV qualification. Hybrid inverters and batteries arrive on the same vans, fail in the same lofts, and leave the same terraces as waste. The knowledge test can still ask which document family applies. The practical assignment will not forgive a swollen lithium module bouncing in an open crate.

Think in three piles on every replacement visit: people and electrical danger (HSWA/EAWR from section 2.1), building and planning (section 2.2), and what leaves site in the van. This section is the third pile.

Waste Batteries and Accumulators Regulations 2009

These regulations exist because portable and industrial batteries are a distinct waste stream from mixed skip waste. For 2922-34, the live issue is stationary EESS batteries that you remove when they fail, when capacity has collapsed, or when a hybrid system is upgraded. Take-back and proper treatment are not optional extras you offer if the customer asks. You need a route: manufacturer or distributor take-back, an authorised treatment facility, or another lawful collection arrangement that the duty holder can actually use on a Tuesday in a residential street.

Do not put lithium EESS modules in the same mixed WEEE cage as a small inverter “to keep the van tidy” unless that facility is expressly set up for both and your procedure says so. Battery regulations exist because lithium chemistries behave differently in the waste chain — fire, residual charge, and treatment plant rules. The exam point is simpler than a waste-broker licence: when you replace an EESS battery, the 2009 battery regulations are in play, which is why LO1 mentions EESS documents on this PV award.

Lead-acid or other chemistries, where still encountered on older storage, are still batteries. Identify the chemistry before you choose the take-back route. Never drain electrolyte into a gully to “make it lighter.”

Waste Electrical and Electronic Equipment Regulations 2013

WEEE 2013 covers electrical and electronic equipment at end of life. On a solar job that includes:

• Inverters and hybrid power conversion equipment
• PV modules (they are EEE, not “just glass”)
• Meters associated with the generating or storage installation
• Related controls, optimisers, and monitoring kit that are EEE

The handbook extra guidance flags WEEE when replacing equipment. That is the candidate trap. You do not wait until the whole array is demolished in 2048. A failed string inverter swapped in year six is a WEEE event. A cracked module removed after impact is a WEEE event. A generation meter exchanged because it is not MID-suitable for a payment route is a WEEE event if the old meter is discarded.

WEEE is discharged by using an authorised collection and treatment route, keeping the equipment intact enough to be handled safely, and not fly-tipping “scrap panels” behind a customer’s garage. Producer and distributor obligations sit in the background; on site, your method statement should name where the old inverter and modules go before you unbolt them.

WEEE and the battery regulations can apply together. A hybrid inverter (WEEE) bolted to a lithium battery cabinet (waste batteries) is two waste families, not one skip label.

Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2021

CDG 2021 is how Great Britain gives effect to the dangerous-goods transport rules for road (ADR family). Lithium-ion batteries are Class 9 dangerous goods:

• UN3480 — lithium-ion batteries (the spare or replacement module in a box)
• UN3481 — lithium-ion batteries contained in equipment or packed with equipment (a battery still inside, or packed with, the hybrid unit)

That classification is why you do not treat a spare battery like a bag of cable offcuts in the footwell. Depending on quantity, packaging, state of charge, and whether cells are damaged, you may need specified packaging, marks, labels, documents, and trained people. Small-load reliefs exist in ADR for some consignments; they are not a rumour you invoke by saying “it’s only one module.” If you do not know whether a relief applies, you do not guess — you follow your company’s CDG procedure or you do not carry the battery.

Damaged or defective lithium batteries are a higher-risk category. Swollen pouches, impact damage, water ingress, or a module that has been in thermal trouble are not “the same UN3480 in a nicer box.” Air transport of damaged lithium batteries is generally forbidden; even by road, special provisions and competent-authority conditions can apply. The 2922-34 teaching point is behavioural: isolate electrically first (EAWR), contain the module, keep it from shorting and from crushing, and use the damaged-battery procedure — do not throw it in the van as general waste.

CDG is a transport statute. It does not replace WEEE or battery take-back at the destination, and it does not replace PAS 63100 at the dwelling. It answers “may this battery legally and safely travel on the public road in this condition?”

PAS 63100: dwellings BESS fire performance

PAS 63100:2024, published by BSI and sponsored by the Department for Energy Security and Net Zero, specifies protection against fire of battery energy storage systems for use in dwellings. It is a Publicly Available Specification, not a British Standard. MCS has described it as specifying fire-safety requirements for small-scale EESS in domestic dwellings using stationary secondary batteries, including issues such as location (industry discussion of loft spaces is part of why the PAS exists). City & Guilds 2922-34 includes this document in the LO1 non-statutory list. Teach it as the dwellings BESS fire code of practice / specification that candidates must know exists.

Do not invent clause numbers, kilowatt-hour caps, or “minimum millimetre separations” unless you have the current PAS open. Unofficial installer blogs quote figures that this study resource will not launder into exam facts. What you can teach, because it is the published intent and the handbook topic list, is the theme set:

• Location — where in the dwelling or its curtilage the battery sits; outdoor or detached-garage preferences appear throughout industry briefing on the PAS; loft and habitable-room siting is a live fire-performance issue.
• Ventilation — batteries and conversion equipment reject heat and, in fault, can emit gases; stuffing a cabinet into an unventilated cupboard fights the fire-performance intent.
• Detection — fire or fault detection so a dwelling occupant is not relying on smelling plastic at 02:00.
• Separation from escape routes — stairs, hallways, and the way out of a terrace house are not storage rooms for a lithium cabinet.

The PAS also addresses battery and fault management, power conversion equipment, and fail-to-safe behaviour at specification level. For 2922-34, remember the document name, the dwellings scope, and those fire-performance themes. Manufacturer instructions still apply; the PAS does not give you a licence to ignore the battery maker’s location limits.

Scenario: failed hybrid inverter and battery module on a terrace house

You are called to a mid-terrace house. The hybrid inverter is dead. One battery module has failed. The existing equipment is in a cupboard under the stairs — the only inner escape route to the front door. Neighbours share party walls. Parking is on-street.

Electrical first. Dual-source isolation: grid AC, PV DC, and battery DC as the manufacturer and EAWR require. Do not unmate connectors under load. Prove dead where the procedure allows. Residual PV voltage remains in daylight.

What leaves in the van. The failed inverter is WEEE. The failed battery module is a waste battery under the 2009 regulations and a CDG consignment if you carry it on the road. Package it as a lithium-ion battery (UN3480 if shipped as a battery; UN3481 if still contained in or packed with equipment), not as mixed metal. If the module is swollen or heat-damaged, use the damaged/defective procedure — not the “spare on the passenger seat” method.

What is installed. The replacement battery’s location is a PAS 63100 fire-performance question as well as a manufacturer-instruction question. Reinstalling under the stairs because “that is where the old one was” may fail the dwellings BESS fire intent (escape-route separation) even if the electrics are neat. Ventilation and detection need a look before you drill. The replacement inverter is new EEE that will itself become WEEE one day; for now, Part P / national building-control notification still applies to the electrical work, and ESQCR/G98/G99 still apply if ratings change.

What you tell the customer. Waste routes, why the under-stairs cupboard is a fire-performance problem, and who notifies Building Regulations. LO1 is 7 percent of the knowledge test, but this terrace visit is how that 7 percent looks in a real hallway.

Official sources

• Waste Batteries and Accumulators Regulations 2009 — take-back and treatment of waste batteries, including replacement EESS modules.
• Waste Electrical and Electronic Equipment Regulations 2013 — inverters, PV modules, meters, and other EEE at end of life.
• Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2021 — lithium batteries as dangerous goods on the road.
• BSI: PAS 63100 protection against fire of battery energy storage systems — dwellings BESS fire specification.
• MCS update on PAS 63100 — installer-scheme context; 2922-34 remains a separate qualification.

Read the current PAS and your employer’s CDG procedure before you move a damaged battery. This study resource names the document families for 2922-34; it does not replace dangerous-goods training or the PAS text.