Waste batteries (usually scrap lead acid batteries from vehicles - UN 2794) may be carried in bulk subject to the conditions set out in ADR 7.3.3 V V 14. There is no minimum load for bulk carriage so ADR/CDG apply in full. This is fully understood by the relevant trade association and its members have undertaken to train drivers to ADR standards as soon as practicable. If drivers carrying waste batteries in bulk do not have a valid ADR certificate a deferred PN is appropriate and the carrier should be asked to confirm arrangements for training.
Conventional skips can be used as long as they are corrosion resistant lined or thick enough to retain their integrity. They must be covered. The pictures below show a typical skip and how corrosion that could allow leakage may develop.