222 South Hamilton, Suite 11
Madison, WI 53703
Phone: 608-256-0565
Fax: 608-256-4562
email: john.muir.chapter@sierraclub.org
www.sierraclub.org
January 2014
Mr. Dave Lumley
CEO, Spectrum Brands
601 Rayovac Drive
Madison, WI 53711
Sent via fax: 608-288-4485 and US Mail
Dear Mr. Lumley:
Sierra Club, the nation’s largest, oldest and most influential grassroots environmental
organization in the United States, adds its name to those requesting Rayovac take
responsibility for the end-of-life with the batteries it produces.
The Sierra Club's Toxics Program and our Zero Waste Programs are devoted to
protecting public health and the environment by reducing exposure to hazardous
substances through advocacy, education, regulation and legal efforts. While we
approve of the work Spectrum Brands and Rayovac have done to eliminate mercury
and cadmium in single-use batteries, the establishment of Call2Recycle for
rechargeable batteries and promoting legislation regulating button cells, this is
simply not enough.
Sustainability requires a larger commitment than a written policy, and as long as
Rayovac’s products continue to end up in landfills, work remains. This is particularly
true in the context of the leadership provided by Rayovac’s competitors with the
Corporation for Battery Recycling. While their effort represents a step forward,
Rayovac has not taken that step. This disappoints those of us who seek Rayovac’s
stewardship of its products as a good corporate citizen. Therefore, Sierra Club joins
Texas Campaign for the Environment and other environmental and public
organizations throughout the country in demanding Rayovac step up efforts on
developing a sustainable battery take-back and recycling program for your products.
Sierra Club strongly objects to the suggestion that consumers dispose of any of their
batteries with their ordinary household trash. Frankly, we find your statement
indicating this practice as proper behavior extremely disappointing. We object to the
notion that anything ought to be thrown into the trash, and would identify any
product designed for disposal as one that is inherently unsustainable. This is
particularly true when recycling options exist for many products, and you must be
aware that there are a variety of recycling options available for alkaline batteries. We
ask you to cease telling people to throw their batteries in the trash, and to direct
them to recycling opportunities.
Sierra Club disputes your claim that alkaline batteries are not harmful to the
environment. As Rayovac knows, the state of California considers alkaline batteries
hazardous waste, and they are banned from solid waste landfill disposal there.
California relies on bioassay characterization criteria. By these standards, alkaline
batteries exceed toxicity for zinc and corrosivity for the electrolyte used. That is to
say, when single-use batteries leach into water, they can be lethal to animals and
microorganisms central to waterway health.
In addition, the extractive mining and refining processes for the components used in
your batteries—in particular zinc—are environmentally destructive. More recycling
equals less need for mining, meaning when you discourage recycling you encourage
toxic releases from other industry. While alkaline batteries are certainly not the most
dangerous product on the market, with 2 billion of them disposed of annually in the
United States, to simply disregard the cumulative effect of their pollutants is
irresponsible.
Additionally, while alkaline batteries may not be categorized as hazardous by the US
federal government, they are classified by the EPA as “universal waste,” which is a
special category of waste known to be hazardous and widely generated by the public
at-large. The EPA regulates battery disposal as universal waste in order to “encourage
the development of municipal and commercial programs to reduce the quantity of
these wastes going to municipal solid waste landfills or combustors.” The EPA’s
position may be that it is allowable to throw them in household trash—a position we
dispute—but it is clearly also their position that this is not preferable. As for other
national governments, the European Union prohibits disposal of alkaline batteries and
has strong expectations for collection activity. We expect the same consideration for
US consumers that Rayovac offers your European customers.
It is for all of these reasons that Sierra Club agrees that Rayovac should:
 take back all of your batteries—both single-use and rechargeable—for all of
your consumers,
 set meaningful and ambitious collection goals, and
 support legislation requiring proper take back of all batteries for recycling.
Furthermore, we need you to stop telling consumers they should dispose of alkaline
batteries by stating “Alkaline batteries can be disposed in your household waste.”
Your sustainability policy puts it well when it states that “Waste, whether produced in
the manufacturing plant, office, or home, represents environmental and economic
inefficiency.”
Please consider your role as a good steward for all your products. If you lead and take
back and recycle what you produce, Rayovac can move beyond the competition. We
encourage you to engage in a constructive dialog with Sierra Club, Texas Campaign
for the Environment and their allies in order to work towards a responsible resolution
to this problem.
Sincerely,
Spencer Black
Vice President for Conservation
Sierra Club National Board
David Blouin
Group Chair
Sierra Club Four Lakes Group
Eric Uram
National Toxics Committee
CC: Robin Schneider (Texas Campaign for the Environment), Andrew Dobbs (Texas
Campaign for the Environment), Debbie Sease (Sierra Club National Legislative
Director), Doris Cellarius (Sierra Club National Toxics Committee), George Dreckmann
(Madison Recycling Coordinator)