This [Portable] Rechargeable Battery Association (PRBA) inquiry includes a number of scenarios and questions raised by its members related to
- the article determination,
- hazard classification,
- consumer product exemptions, and
- labeling requirements
The PRBA scenarios and questions have been paraphrased, followed by our responses. In addition, Attachment 1 to this letter provides several scenarios to give a clearer understanding of the application of the HCS to Li-ion batteries. Here is the list of questions OSHA addresses: