Lithium Battery Working Group Meeting – 2015-2016
Version 2 of Minutes Including Comments from Germany and UK
1St Session, 16-17 March 2015 – Brussels, Belgium
Day 1 – 16 March 2015
Introduction
- Jean-Pol Wiaux (RECHARGE) welcomed the participants to the Session and introduced the logistics for the meeting. Claude Pfauvadel (Chairman) noted the WG is working in the context of the UN Subcommittee of Experts on the Transport of Dangerous Goods and more specifically the testing criteria for Lithium Batteries as described in the UN Manual of Tests and Criteria, Section 38.3. The participants introduced themselves, noting participation from several competent authorities as well as numerous battery manufacturing companies and trade associations.
- The Chairman discussed the benefit of past Working Groups and reviewed the terms of reference as assigned by the UN Subcommittee. These include:
- Comparison of UN Recommendations on the transport of Dangerous Goods (Model Regulations), UN Manual of Tests and Criteria (UN Manual), and IEC Standards
- Presentation of test requirements in a table to clarify applicability
- Update the definitions to take account of cell design development
- Review testing of large cells in small batteries
- Develop a test report template.
- The Chairman indicated the expectation that proposals would not likely result from this session, but instead the WG would provide the Subcommittee with progress report, and proposals could be developed for a 2nd Session.
- Presentations for the session can be viewed at: http://www.rechargebatteries.org/1rst-informal-working-group-2015-un-manual-of-tests-and-criteria/
Definitions
- IEC presented a comparison of definitions in IEC Standards versus those contained within the UN Model Regulations and UN Manual. IEC presented new definitions for CELL and BATTERY and then reviewed locations in Model Regulations where these changes could impact the existing text. Special Provision 188 would require a number of modifications, as would P909. Several questions were raised about recent changes to the UN Model Regulations and UN Manual. However, the Chairman reminded the WG the presentation was limited to definitions and the discussion should be limited to that topic. The Chairman pointed out currently the definitions are found in the UN Manual, and the WG should consider whether definitions should be included in the UN Model Regulations. Further, new cell and battery technology may necessitate the need for new or revised definitions. The WG discussed the benefits of keeping the existing definitions given shipper understanding and a possible need to retrain employees, versus the need to update the definitions to better describe the technology. DGAC supported putting definitions in the Model Regulations but indicated that they were not opposed to considering aligning the UN and IEC definitions if appropriate text could be developed to minimize and detrimental implications to shippers. Germany opposed changing the definition as well as voicing concern for the proposed changes in SP188, the use of the term “multi-cell”, and the proposed changes to P909. PRBA supported the changes to SP188 (new paragraph (c) indicating it would provide guidance for battery manufacturers. The Chairman noted both Germany and PRBA have identified a point of confusion on whether there is a limit on the size of a cell in a battery. For example, SP 188 would allow up to 4 cells up to 100 Wh, but no more than 2 batteries with up to 100 Wh. The UK indicated there are different interpretations on the existing text but supported the interpretation of PRBA that cells cannot exceed 20 Wh and thus component cells cannot exceed 20 Wh either. Germany suggested that the Subcommittee could provide a uniform interpretation in the issue. IEC noted that a shipper may not be able to determine whether he/she is offering a cell or a battery and the proposed definition would be a more universal and practical definition. The WG continued discussion of whether a Wh cell limit is present already and how that limit is communicated through Special Provision 188. Germany questioned whether a 100 Wh cell would be more dangerous than a 100 Wh battery. The Chairman noted that at one time, small cells and batteries were completely exempted from the regulation including testing. But the confusion we face now is due to the limits placed on smaller cells and batteries. The US agreed with the UK and PRBA that a battery containing cells that exceed 20 Wh would not be covered under SP188, paragraph (b), Germany opposed this interpretation and the proposed amendment to SP 188.
- RECHARGE presented on behalf of Envites new technologies that are difficult to consider under the current cell and battery definitions. IEC standards (IEC 61960 ed 2, IEC 62260, IEC 60086/IEC 62281) include definitions which are different than the UN Manual. Envites pointed out there are cells with more than one positive or negative electrode. Under the current provisions, these cells would be considered batteries. The presentation also discussed the need to define tabs or terminals which may often be confused in transport. Envites questioned whether cells which have a zero voltage when in transport (not activated) should be regulated. Finally, the presentation questioned whether a singled cell battery is subject to T.1-T.8 or just a subset applicable to a battery. PRBA and Tadiran voiced concern on the definition change noting possible significant implications to industry. Tadiran stated they believed a cell that is not activated is still regulated as a cell. The Chairman voiced confusion over the proposal questioning whether this would replace the concept of single cell battery. Germany agreed with previous speakers, stating that for a single cell battery, T.1-T.8 would be required. UL indicated it is much clearer to have a the definition of a single cell battery which allows for T.7 to be done on a cell that was tested under T.1-T.6 and T.8, instead of having to retest all over again. The UK suggested the WG could consider changing the testing conditions so that the differentiation would not be necessary. The WG discussed cells and batteries which have no voltage at their terminals, and concluded they were to be handled as cells and batteries. The Chairman voiced confusion as to the need for a new definition of battery cell stating the condition is better addressed under the current language. The WG discussed thermal batteries, concluding that thermal batteries are not covered under the entries for lithium batteries, and thus must be considered under a separate entry in the UN Model Regulations (to be developed by the UN Subcommittee during the current biennium).
- RECHARGE gave a presentation explaining that the UN definitions were developed for the purpose of testing, and that the WG should consider further refining the definitions to ensure they cover all categories of cells/batteries and have limited boundaries (do not overlap). Categories can be separated by Wh and size, or battery complexity and protection. The UN definition for cells provides a cell design definition but the component cell and single cell battery definitions overlap with regards to risk. The definition of button cells does not include any reference to size, and the concept of small cell versus large cell is measured by Wh, not by weight. Finally, the UN definitions do not provide clear definitions of different battery chemistries, whereas the IEC standards provide definitions for lithium ion and lithium metal cells/batteries. RECHARGE created two tables based on battery category and complexity which described which definition was applicable for each category. A consequential table was presented which breaks down applicable testing requirements for cells and batteries depending on their size, their use, and whether they are transported separately or only within a battery. RECHARGE proposed creating a simplified table for testing purposes that defines testing for component cells, single cell batteries, multi-cell batteries, assembled batteries, and assembled batteries >6200 Wh or 500 g Li, and whether each has overcharge protection or not. PRBA pointed out the UN Manual refers to primary or rechargeable cells/batteries. Industry is developing rechargeable cells/batteries containing lithium metal. These cells/batteries would be tested as rechargeable cells/batteries. The Chairman requested the WG focus on whether a table for the current testing scheme would be beneficial, and then test the table for use in addressing new technologies.
- PRBA discussed the concept of power packs or power banks. These are devices which are designed to recharge other batteries or devices and also include other functions such as short videos and lanterns (flashlights). Some units have the battery permanently installed but others have a removable battery (often a single cell battery). Cells are tested, but once cells are connected into the system, they may not be tested as a battery as required by the UN Manual. PRBA noted the confusion over whether these units are batteries or equipment. They also presented an example of a 2-cell battery that is permanently installed in equipment (such as a rechargeable drill). In this case, the drill is tested against the relevant testing conditions for batteries. This concept could be applied back to power packs. Germany indicated they believed the drill (and power pack) would need to be tested against the UN Manual 38.3 conditions. Therefore the Wh rating would also need to be marked on the casing of the drill. PRBA pointed out the UN Manual is not clear on this issue, and if testing of the equipment would be required, the text in the UN Manual needs to be revised. The US voiced concern over conducting the T.4 test on one of these devices using the weight of the device instead of the weight of the contained batteries. The Chairman pointed out the direction of impact could influence the test. PRBA shared that some testing laboratories often remove most of the “equipment” portion of the device, and test only the casing of the device with the batteries. The Netherlands stated based on the discussion, they felt testing would be required for the units as batteries. PRBA indicated they will present language to change several of the tests in UN38.3 to address this issue. Saft questioned whether the situation would be different if the cells were removable. The UK shared a recent incident in which several power banks caught fire in transport due to fracture of their plastic casings, shards from which penetrated the two pouch-style cells contained within. The naked pouch cells had been tested as a battery without the case and when installed into the case, were classified by the manufacturer as batteries in equipment. UK disagreed with this classification. The UK shared an example of two pouch-style cells which had passed T.6 as a battery, but did not have a case. Therefore, the battery was retested installed in equipment. The resulting test was a failure due to parts of the device penetrating the pouches. DGAC voiced concern that the text should not require batteries which are successfully tested as batteries to be retested as equipment. The WG discussed the applicability of the UN38.3 to batteries installed in equipment which will never be transported outside of the equipment. The UK suggested that detailed regulatory text may not be necessary if a guidance document were developed that added specificity and examples. The WG agreed to review possible changes to the text proposed in the PRBA document to address the issue.
- The WG reviewed the table presented in the RECHARGE presentation for cell and battery testing. The Chairman recommended two separate tables be developed, one for primary and one for rechargeable cells/batteries. The testing conditions for component cells were discussed. The WG agreed that component cells transported alone would be subject to testing as a cell, as they are no longer component cells. Several delegations questioned the need to have component cell in UN38.3. The UK proposed combining the cell and component cell test conditions in the RECHARGE Table. The WG discussed changes to the RECHARGE table.
Table 1
Reference / ConditionsWithout overcharge protection (for rechargeable batteries / With overcharge protection (for rechargeable batteries)
Not transported separately / Transported separately
Cell tests / Cell / 38.3.2.1 scope / T6 and T8 / T1-T6 and T8
Single cell battery with non-tested cell / 38.3.2.1 scope / T1-T6 and T8 / T1-T8
Single cell battery with tested cell / 38.3.2.3 definition / T7
Battery tests / Battery / 38.3.2.1 Scope / NA / T1-T5 / T1-T5 and T7 (for rechargeable batteries)
Assembled battery (with tested batteries) / 38.3.2.1 / NA / T3-T5 / T3-T5 and T7 (for rechargeable batteries) or protection system
Large assembled battery with tested batteries (more than 6200 Wh) / 38.3.3(f) / NA / Protection System / Protection System
- Shanghai Research Institute of Chemical Industry presented a simplified table for testing clarification.
Table 2
Primary / Cell / Component Cell1 / Single Cell Battery2 / BatteryT.1 / X / X
T.2 / X / X
T.3 / X / X
T.4 / X / X
T.5 / X / X
T.6 / X / X
T.7
T.8 / X / X
1 A component cell is never transported outside of a battery
2Single cell battery containing a cell that has passed all applicable tests as a cell
Table 3
Rechargeable / Cell / Component Cell1 / Single Cell Battery2,3 / Battery3T.1 / X / X
T.2 / X / X
T.3 / X / X
T.4 / X / X
T.5 / X / X
T.6 / X / X
T.7 / X / X
T.8 / X / X
1 A component cell is never transported outside of a battery
2Single cell battery containing a cell that has passed all applicable tests as a cell