Navigating the Regulatory Maze for Lithium Batteries Part I Introduction

Tom OHara Business Manager, Energy Storage

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Navigating the Regulatory Maze for Lithium Batteries Part I

Governments regulate those areas in life where significant hazards are present. One example is automotive regulations, which cover issues ranging from gas tank safety to crash protection to vehicle lighting. Regulations reach beyond the manufacturing of the vehicle itself to usage of the vehicle, requiring that drivers are licensed and have auto insurance. Government regulation to protect individuals from the hazards associated with lithium batteries is no different. When a risk of significant personal hazard is exposed, a regulation will likely follow. This introductory paper discusses the regulatory maze which now exists, created by a number of separate organizations, to help protect people from the hazards associated with lithium batteries and cells. This need has been highlighted in recent years because of highly publicized incidents and recalls affecting the industry. A variety of regulations, agencies, and certification bodies now exist, coded with alphanumeric designations, sounding so similar that one needs to be trained in order to recognize the distinctions. There are U.S. entities and European counterparts. Japan has their own standards, as do other parts of the world. Equipment manufacturers often have additional internal standards and specifications which they apply in order to better protect both their brand and consumers. Some regulations are statutory requirements, others are guidelines, still others are not mandatory but are essentially required if company wants to sell their product to an original equipment manufacturer (OEM) who requires all device components to be safety listed. So, where to begin? First, a brief overview of the key regulatory agencies and the critical role Nationally Recognized Testing Laboratories (NRTLs) play. Key regulatory agencies to become familiar with are: OSHA; UN/DOT; ANSI; UL; IEEE; IEC; CTIA and SAE. Next, key industry standards will be discussed.

Regulatory Organizations:
1. OSHA In the US, workplace and product safety essentially begins with OSHA (Occupational Safety and Health Administration), an agency of the United States Department of Labor. Its mission is to prevent work-related injuries, illnesses, and occupational fatality by issuing and enforcing standards for workplace safety and health. For the purposes of this paper, OSHAs role is to approve and maintain a list of NRTLs.

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What are NRTLs? Under the narrow scope of this paper, Nationally Recognized Testing Laboratories are testing facilities recognized by OSHA as organizations that have the resources and competence to provide product safety testing and certification for lithium batteries and cells. The test standards which NRTLs follow are not developed or issued by OSHA, but are issued by U.S. standards organizations, such as ANSI (the American National Standards Institute) or UL (Underwriters Laboratories), both of which produce consensus-based product safety test standards. There are several NRTLs, including Intertek. It is important to note that any NRTL can obtain approval to certify against specific UL standards if they apply for and pass a number of OSHAdefined criteria designed to assure the test lab has the rigor, resources, and experience to conduct the tests.

2. UN/DOT The U.S. D.O.T. (United States Department of Transportation) defines shipping regulations for the US under 49 CFR, where section 173.185 specifically addresses lithium batteries. The UN (United Nations) issues recommendations for the transport of dangerous goods worldwide. Together, the UN/DOT 38.3 guidelines (also known as the T1 - T8 Tests and UN ST/SG/AC.10/27/Rev. 4) define test requirements for the safe packaging and shipment of lithium metal and lithium ion batteries, with tests T1 through T8 detailed in section 38.3 of the UNs Manual of Tests and Criteria. There are several related organizations serving the transportation industry which have a say in lithium battery regulation, listed here for reference: PHMSA (Pipeline and Hazardous Materials Safety Administration); IATA (International Air Transport Association); ICAO (International Civil Aviation Organization); IFALPA (International Federation of Air Line Pilots Associations). 3. ANSI The American National Standards Institute (ANSI) is a private non-profit organization which develops consensus-based standards. For batteries, the key standard is C18.

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4. UL Underwriters Laboratories (UL) is an independent product safety certification organization which, in conjunction with other organizations and industry experts, publishes consensus-based safety standards. For lithium batteries, key standards are UL 1642, and UL 2054 (with automotive battery standard UL 2580 under development). Any NRTL can test to UL standards (for which they are accredited) and issue their own mark (for Intertek, it is the ETL Mark), indicating the certified product complies with specific safety requirements of the standard. In contrast, the European CE Mark is a manufacturers self declaration that their product meets requirements for EU product safety. 5. IEEE The Institute of Electrical and Electronics Engineers (IEEE) is an international non-profit organization covering technologies related to electricity, and develops safety standards for industry, including batteries. For lithium batteries, key standards are IEEE 1625 and IEEE 1725. 6. IEC The International Electrotechnical Commission (IEC) is a non-profit standards organization that writes International Standards for all electrical, electronic and related technologies. This includes batteries. For lithium batteries, key standards are IEC 62133 (emerging as a unified worldwide standard, replacing UL 1642), IEC 60086, IEC 61960, and IEC 62281 (the IEC version of UN/DOT 38.3). CTIA The Cellular Telephone Industries Association (CTIA) is an international trade group, also known as The Wireless Association. CTIA certifies compliance to the IEEE 1725 standard. CTIA is currently working on plans to cover IEEC 1625 as well. SAE SAE International (Society of Automotive & Aerospace Engineers), is a professional organization for the aerospace, automotive, and commercial vehicle industries. SAE develops standards for engineering professionals. With hybrid and full electric vehicles now entering the marketplace in large numbers, the need for battery standards is getting greater attention. UL 2580 (currently under development) will likely overlap existing SAE J 2464. Upcoming J 2929 is planned as a Pass/Fail version of J 2464.
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Key Industry Standards

Several key industry standards for lithium batteries were mentioned in the previous section: UN/DOT 38.3; ANSI C 18; UL1642; UL2054; IEEC 1625; IEEC1725; IEC 62133; IEC 60086; IEC 61960; IEC 62281; SAE J 2464; UL2580. When are these standards applicable? UN/DOT 38.3 -- if you are shipping lithium batteries, either alone or as part of a device. ANSI C18.3 (Portable Lithium Primary Cells and Batteries) -- general guidelines. UL1642 (Standard for Lithium Batteries) -- general guidelines covering technician-replaceable or user-replaceable lithium batteries. UL2054 (Household and Commercial Batteries) -- general guidelines. Individual lithium batteries (cells) covered by UL2054 must also meet UL1625. There is much overlap between UL1642 and UL2054. IEEE 1625 (Batteries for Portable Computers) -- guidelines to a comprehensive system approach to lithium battery safety. IEEE 1725 (Rechargeable Batteries for Cellular Telephones) -- guidelines to a comprehensive system approach to lithium battery safety. IEC 62133 (Secondary Cells and Batteries Containing Alkaline or other NonAcid Electrolytes) -- general guidelines, expected to replace UL 1642 by 2012. IEC 60086-4 -- for general safety standards for primary lithium batteries. IEC 61960 -- for general safety standards for secondary lithium cells and batteries. IEC 62281 (Safety of primary and secondary lithium cells and batteries during transport) -- general guidelines. SAE J 2464 (Electric and Hybrid Electric Vehicle Rechargeable Energy Storage System Safety and Abuse Testing) -- general guidelines. UL 2580 (Batteries for Use in Electric Vehicles), currently under development.

In the coming months, Intertek will provide a series of white papers on lithium battery safety standards, the first of which will discuss UN/DOT 38.3 transportation testing.
Interteks expertise in battery testing & energy storage services ensures products meet performance, reliability and safety criteria. Intertek has expanded global energy storage testing facilities and advisory services. Throughout design, manufacturing & system deployment cycles, Intertek provides evaluations for performance, electrical safety, interoperability, fit for use, component selection and more. Please visit our website at www.intertek.com/energystorage, contact icenter@intertek.com or call your regional lab:

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