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

1. 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.

2. The Chairman discussed the benefit of past Working Groups and reviewed the terms of reference as assigned by the UN Subcommittee. These include:

a. Comparison of UN Recommendations on the transport of Dangerous Goods (Model Regulations), UN Manual of Tests and Criteria (UN Manual), and IEC Standards

b. Presentation of test requirements in a table to clarify applicabilityc. Update the definitions to take account of cell design developmentd. Review testing of large cells in small batteriese. Develop a test report template.

3. 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.

4. Presentations for the session can be viewed at: http://www.rechargebatteries.org/1rst-informal-working-group-2015-un-manual-of-tests-and-criteria/

Definitions

5. 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

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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.

6. 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

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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).

7. 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.

[8.] 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

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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.

8.[9.] 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 batteriesWith

overcharge protection (for rechargeable

batteries)Not transported

separatelyTransported 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 Battery 38.3.2.1 NA T1-T5 T1-T5 and T7

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tests Scope (for rechargeable

batteries)Assembled battery

(with tested batteries)

38.3.2.1 NA T3-T5 T3-T5 and T7 (for

rechargeable batteries) or protection

systemLarge assembled

battery with tested batteries (more than 6200 Wh)

38.3.3(f) NA Protection System

Protection System

9.[10.] 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 XT.2 X XT.3 X XT.4 X XT.5 X XT.6 X XT.7T.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

Battery3

T.1 X XT.2 X XT.3 X XT.4 X XT.5 X XT.6 X XT.7 X XT.8 X X

1 A component cell is never transported outside of a battery

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2Single cell battery containing a cell that has passed all applicable tests as a cell

3T.7 required when battery is equipped with overcharge protection.

10.[11.] Once the tables created a visual review of the testing regime, the WG discussed whether a single cell battery must be retested in per T.1-T.6, and T.8 as well as T.7 for rechargeable cells. Arguments were made on both sides, noting examples where attachments could present additional opportunities for failure and others where attachments would not impact testing results. PRBA noted the UN Manual language in the NOTE to 38.3.2.2 requires that any changes to the design type which could change the test results must be retested. The Chairman reminded the WG the Mandate from the Subcommittee is to clarify the existing text under 38.3.2.1. Therefore, any additional testing provisions to be added must be submitted separately to the Subcommittee. ICAO supported the proposal by the UK that additional guidance would be a welcome option for clarifying the text and harmonizing opinions within the WG. DGAC supported the comments from ICAO, noting that guidance could be included on the UN Website and available. France pointed out a similar process was used in France by referring to industry guidance documents which meet CA scrutiny. The UK stated that it is not UK policy to issue “guidance” as responsibility for interpretation ultimately falls to the courts. However, there would be no difficulty in supporting the development of common understandings in conjunction with other relevant parties.The UK stated that the UK cannot issue “guidance” as that falls to the courts. However, there is no limitation for them to participate in groups which develop such guidance.

11.[12.] The WG agreed to the revised Table 1 but suggested a vertical representation as shown in Tables 2 and 3 from China may be a beneficial addition.

ACTION ITEMS

WG to request clarification from the Subcommittee as to whether individual cells (single or component) may exceed 20 Wh.

WG to request clarification from the Subcommittee as to whether the 20 Wh limit in SP 188 applies to cells contained in batteries or only to cells when transported as cells.

Review proposed language addition to 38.3.2 for batteries installed in equipment. WG to review revised table for inclusion in UN Model Regulations and UN Manual.

Hybrid Batteries

12.[13.] Tadiran explained that they have begun developing hybrid batteries which include both a primary and rechargeable components. The battery is not rechargeable (from an outside source) but contains rechargeable cells. The cells cannot be overcharged as the voltage from the primary cells is less than for the rechargeable cells. Tadiran proposed the batteries be subject to testing and transport conditions for primary batteries instead of rechargeable batteries (overcharge test is not appropriate). T.7 can be tested on the rechargeable component cells instead. Tadiran asked the WG to consider whether the battery as presented and tested, is eligible for transport as a UN3090.

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13.[14.] The WG discussed the need and design of such batteries. Germany supported the testing and identification as UN3090, but they felt that additional communication would be needed in both the UN Manual and UN Model Regulations. The Chairman summarized the discussion and stated that issue could be presented to the Subcommittee.

Action Items

WG to continue discussion on hybrid batteries and determine if separate definitions and testing conditions are needed or whether simple clarification statements could be made. Options could include:

o Precise text depending on conditions, oro Principle agreement that primary takes precedent over secondary.o Issue to be presented to the UN SC for guidance to the IWG on how to proceed.

End of Day 1

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Day 2 – 17 March 2015

New Battery Technologies

14.[15.] RECHARGE presented information regarding lithium metal polymer batteries. These batteries are constructed similar to lithium ion batteries, but contain lithium metal, and therefore may be better described as UN3090. Further, these batteries are designed to operate at relatively high temperatures (80 oC). The UN38.3 testing provisions do not test the batteries at their operating temperatures.

15.[16.] RECHARGE also presented information regarding lithium sulfur batteries. These batteries including lithium metal on the anode but contain a non-flammable electrolyte. Finally, hybrid ultracapacitors were discussed.

16.[17.] The WG discussed the new technologies and whether they were properly described and could be subject to testing under the existing regulatory texts. RECHARGE explained the lithium metal polymer batteries are considered rechargeable batteries and tested as such, but the overcharge test does not really test the battery. They clarified that batteries which are stored at very low temperatures would not experience damage due to over discharge. France shared experience with the batteries noting that the design of the battery has inherent safety properties. The overcharge test should be conducted at 80 oC but all other tests should be conducted at ambient temperatures. The batteries should be described as UN3090 but the UN38.3 provisions and possibly a special provision should be revised to reflect this opinion. UL question whether T.5 should be conducted at 80 oC as well. France and RECHARGE explained that the batteries have a charge at temperatures below 80 oC, and therefore T.5 would still be appropriate at 55 oC. This value represents extreme temperatures experienced in transport. Tadiran asked if the proper shipping name for UN3090 would need to be modified to include these batteries. The Chairman indicated that no change would be necessary. The US compared the battery to a reserve battery and cautioned that they may review the battery as a Div. 4.3 and may require a special permit or approval for classification and transport. RECHARGE explained that the electrolyte was not in reserve but already activated. Further, the battery is not a one-time-use whereas reserve batteries are one-time-use.

17.[18.] The Chairman suggested providing: a clarification in the UN Model Regulations in 2.9.4 that lithium metal polymer batteries should

be considered lithium metal batteries for transport; and Provide clarity that overcharge test (T.7) and forced discharge test (T.8) must be conducted at

normal working conditions for the battery.

18.[19.] RECHARGE reiterated the point made by Tadiran that UN3090 includes lithium alloy batteries, but the descriptor for UN3480 indicated lithium polymer batteries, thus that wording creates confusion for these batteries. Germany suggested providing a special provision that indicates the

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battery must be described as UN3090. The Chairman opined that it would be cleaner to simply expand the entry for UN3090 to:

LITHIUM METAL BATTERY, including lithium alloy and lithium metal polymer batteries

19.[20.] The WG discussed the same questions of lithium sulfur batteries. RECHARGE explained that lithium sulfur batteries present a reduced risk compared to other lithium metal batteries. The Chairman pointed out the UN Model Regulations 2.9.4 states that lithium batteries includes batteries which include any quantity of lithium in the anode or cathode. Therefore these batteries would meet that description and should be regulated as such. PRBA explained that lithium metal rechargeable batteries are not a new technology, but there is growth in the development of these batteries. The WG discussed the fact that historic opinion is that lithium metal batteries are more dangerous than lithium ion batteries. However, these new technologies may present lithium metal batteries which are safer than lithium ion batteries. Should exceptions be provided for these newer types of batteries? Varta stated they would prefer to keep the current system the same. For transportation, the description would be based on the use of lithium metal on the electrodes, and for testing the battery would be tested as either primary or rechargeable as appropriate. Germany agreed, noting that the transportation conditions and testing conditions are not connected. The Chairman suggested adding a note to UN Model Regulations 2.9.4 that provides examples of lithium metal polymers and lithium sulfur batteries. Germany and the UK did not support the idea noting that nowhere in the regulations are lithium metal batteries tied to primary batteries. The WG discussed whether clarity was needed in 2.9.4, T.7 and T.8. or the definitions of the manual (§ 38.3.2.3.) [2.9.4] A Lithium metal battery means a battery that is designed and manufactured with Lithium

in a metallic form. A Lithium-Ion battery is defined in § 38.3.2.3. of the Manual of Tests and Criteria. [T.7, T.8] These tests shall be conducted at normal operating conditions [temperatures] for the

battery.

20.[21.] UL pointed out that T.5 may also need to be conducted at normal operating conditions/temperatures noting that the comparable IEC standard is designed to push the battery to its limits. T.5 would not stress a lithium metal polymer battery. The WG agreed to review the applicability of normal operating conditions for the battery to T.5.

21.[22.] The WG discussed whether the testing and transport conditions should consider safer battery designs which could be provided greater exceptions. The US stated that even though a lithium sulfur battery contains a non-flammable electrolyte, they were not sure the battery would be considered safer. Further evidence would need to be shown that as the electrolyte was heated, decomposition of the electrolyte would not result in a flammable or toxic product. However, that fact did not prevent them from identifying the battery as UN3090 and testing as a rechargeable battery.

22.[23.] The Chairman noted determining the State of Charge (SOC) is a way to ensure batteries are safe. Procedures to ensure SOC may be possible at the manufacturing level but it may be more difficult to

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determine SOC at the individual shipper level or after the battery has been used. At some point in the future, the WG could consider simplified packing provisions for batteries shipped at a reduced state of charge but for now, the SOC should not be considered.

Action Items

WG to draft language to add to 2.9.4 or § 38.3.2.3 of the Manual of T&C to clarify that lithium metal polymer should be classified as a lithium metal battery

WG to draft language to T.7 and T.8 to clarify that these tests should be conducted at normal operating conditions [temperatures] for the battery.

WG to research whether T.5 should be conducted at normal operating conditions [temperatures] for the battery.

Testing Requirements for Small Batteries with Large Cells

23.[24.] RECHARGE discussed the testing conditions for small batteries constructed with large cells. When large cells are tested, they are subject to a 50g acceleration, whereas when the cells are installed in a small battery, the battery would be subjected to an acceleration as high as 150g acceleration. RECHARGE proposed to add the following sentence to UN Manual 38.3.2:

[add to definition of large battery] Any battery assembled with large cells shall be considered as a large battery for testing purposes.

24.[25.] The US indicated that if the cells were not intended as component cells, they felt the cells and batteries should be subjected to the conditions as presented. The UK questioned whether the anomaly created a real problem. Are such testing conditions leading to failures? The US and the Chairman pointed out that if the cells were component cells, then T.4 would not apply and the anomaly is eliminated. RECHARGE indicated the costs associated with creating a cell that will withstand a 150g acceleration are greater than cells which must only withstand a 50g acceleration. The UK suggested that T.4 could be changed to align the scaled approach for batteries with cells as well. The WG discussed the benefits and impacts of changing the acceleration for cells to a sliding scale. The US reminded the WG the basis for the sliding scale was a constant energy. The FAA suggested that lithium content and nominal energy should also be considered. The WG decided they could continue to review the issue at future sessions.

Action Items WG to consider sliding scale for T.4 acceleration for cells (align with sliding scale for batteries) WG to consider redefining the definition of a large cell battery (currently at 12 kg) Participants were invited to provide additional technical data (testing data) to support the

discussion

Standard format for Declarations of Conformity

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25.[26.] PRBA explained that they are developing a website depository for Declarations of Conformity (DOC) to make available documentation that cells/batteries have passed relevant UN38.3 tests. PRBA noted they would not be certifying the documentation, nor would the website be used to maintain testing data. It would only be used to include documents which would confirm cells or batteries were successfully tested.

26.[27.] Examples of Declarations of Conformity were shared. Important items which were included: Type of battery Wh for lithium ion, lithium content in grams for lithium metal Tests which have been conducted/passed Date of tests Certification of cell/battery testing Company information including address, contact information

27.[28.] The WG discussed the benefits of such a depository and DOCs. DGAC pointed out the UN Model Regulations do not make it clear what exactly is required. The WG should consider defining exactly what information needs to be provided by manufactures and shippers. The UK also supported the concept but stated that key elements should include: An unambiguous description of what was tested Who conducted the testing How do you get in touch with the manufacturer How responsiveness is the manufacturer

28.[29.] GM explained that multiple battery designs may be included under single DOC. Further, model numbers may not be appropriate as there may be too many to list. BMW reiterated the need to keep the form simple. The Netherlands asked who could conduct the testing. The WG responded that anyone could conduct the testing as self-certification is allowed. The tests are part of classification. Germany cautioned the WG that currently no such document is required and therefore the discussion should be recommended only. Further, the Subcommittee discussed the need to provide recommendations on what should be provided on a test report, not necessarily what is being described as a DOC. The Chairman drew attention to similar language in Chapter 6.1.5.7.1 in the UN Model Regulations for packaging testing reports, and agreed with Germany that the WG should not create an obligation to complete when such an obligation is not required by the Model Regulations today. China pointed out the transport conditions may change for the number and type of batteries being offered. PRBA responded that the DOC would be on the tested cell or battery, and would not be a full declaration of how it is packed or offered for transportation. The Chairman and Germany again cautioned that it is important to understand the difference between a test report and a DOC. Germany indicated the Subcommittee should be conferred before work was completed on a DOC. COSTHA supported the effort noting that regulatory text might not be needed and a document required, but providing guidance of what could be used to communicate classification testing to shippers would be beneficial. The US shared their experience with requiring manufacturers to maintain and provide a test report noting that industry has already developed

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ways of addressing the issue. Germany commented that the discussion suggests it is not clear who is responsible for classification. The Chairman suggested the test report could be used to communicate all relevant requirements of the example DOC without “certifying” conformance.

29.[30.] The WG concluded the discussion by requesting participants to review the text in 6.1.5.7.1 and determine what information could be used, identify what elements would be necessary, and indicate how the information can be provided (electronic or manual). Many participants felt that it would be useful to discuss the responsibility to assess conformity: who is responsible for testing and who is responsible for providing additional information?

Action Items

WG to review 6.1.5.7.1 and determine if text is usable as a basis for test report language. Report to Subcommittee that additional elements of conformity could be discussed within the

WG at future sessions.

China’s Lithium ion Battery Standard GB 31241 - 2014

30.[31.] Shanghai Research Institute of Chemical Industry presented information on a new national standard (GB 31241-2014) in China applicable to lithium ion cells and batteries designed for use in “portable electronic equipment.” The standard defines “portable electronic equipment” as weighing a maximum of 18 kg. Portable banks or power packs are not covered under the standard . Tests conducted include all UN38.3 tests along with additional tests (e.g., washing test, enclosure fireproof requirement) to ensure safety. The tests include testing of the protection circuit module (PCM). Test conditions will be implemented 1 August 2015. The WG asked whether testing can be conducted by laboratories outside China. China responded that the tests are voluntary until 1 August 2015, but it is unclear after 1 August 2015 whether tests will be required to be conducted by approved laboratories in China. Tests are separate and in addition to UN transport tests.

Internal Short Circuit Testing Methods

31.[32.] The US presented research on an internal short circuit test. They described reasons for cell failure, current test methodologies, and examples of test methods that could be implemented. The US emphasized the improved test could be used to determine if thermal runaway will occur due to failure of separator membranes within the cell. RECHARGE stated that industry has improved cell resistance to short circuit through improvements to separators. Further, dendritic grown does not always result in thermal runaway, but would result in a short circuit in any case. RECHARGE again emphasized that the industry has improved cell design to reduce the risk of internal short circuit and questioned the need for a more severe short circuit that circumvents the improved cell technology. The US commented battery incidents have occurred possibly due to short circuit, and therefore the test should be improved. PRBA noted there has been no direct connection made between incidents in transportation and internal short circuits and cautioned the US against making such a connection. BAJ questioned the need for the test and its applicability to transport, and noted UL previously submitted and withdrew a similar proposal noting the test method was not fully appropriate. The

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US responded that the test method is designed to test the stiffness of the separator and its ability to withstand dendrite growth. DGAC supported the discussion and commented the need to improve understanding of the test methods. UL indicated they have reviewed the test but have some reservations about the repeatability of the proposed test. The Chairman explained T.6 was not designed as an internal short circuit test but instead is a crush or impact test that is designed to create an abuse condition which could result in a short circuit. However, if dendrite growth is a significant problem, perhaps the test proposed could be used to ensure such dendrite growth will not lead to an internal short circuit. RECHARGE stated that dendrite growth is not an immediate condition but instead occurs over time. Therefore the current test methods already take into account this condition. The WG discussed the value of having a test which includes greater cycling which could result in dendrite growth. The FAA explained that the incidents involving the Boeing 787 main battery involved internal short circuit, and they are reviewing for adoption their own internal short circuit for batteries to be installed on aircraft. The US emphasized their proposed test checks the quality of the separator membranes. Deutsche ACCUmotive commented they have been unsuccessful in developing a reproducible short circuit test method using cell penetration.

32.[33.] The WG could not come to a consensus as to whether a revised test method was necessary. However, the WG decided the Subcommittee should be notified that the issue of internal short circuit has been raised, and asked whether the WG should include developing a standard methodology for such a test in the terms of reference for the WG.

Action Item

WG to ask Subcommittee if development of an internal short circuit test should be included in the mandate for the Lithium Battery Working Group.

Damaged and Defective Batteries

33.[34.] DGAC pointed out the introductory language in UN Model Regulations Special Provision 376 starts by explaining the conditions for damaged and defective batteries apply when a cell or battery has been identified as being damaged or defective such that they do not conform to the type tested according to UN38.3. However, they questioned what criteria would a shipper use to determine of a battery was damaged or defective. DGAC proposed modifying the text in SP 376 to provide additional clarification when a battery may be damaged or defective. Since the topic is not currently in the mandate for the WG, the Subcommittee would have to direct the WG to do so.

34.[35.] The Netherlands stated that the revised text appeared to assign responsibility and believed that was beyond the expertise of the WG. France indicated they would prefer to avoid reference to who is performing the determination (e.g., shipper, consigner, manufacturer). Otherwise, they supported the approach with minor modifications. The US shared experience with implementing the damaged/defective battery provisions. They stated many shippers are using this provision as a default method for shipping cells and batteries that are simply being returned without expertise for whether the battery is actually damaged. Ford pointed out that in the EU, battery manufacturers

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MUST accept batteries for collection and recycling/disposal due to environmental protection laws. Therefore the damaged/defective provisions provide a very safe approach. VDA has produced a paper which describes their processes. Germany stated the language was left open by design to provide flexibility to the shipper to make the determination of whether the provisions applied or not. Ford explained the costs associated with preparing shipments according to the damaged/defective batteries under these provisions are very significant.

35.[36.] DGAC explained they will not ask the WG to consider the language in SP376. However, they requested the WG consider providing additional clarification and examples of when cells and batteries can be considered damaged/defective. RECHARGE requested the WG provide examples of currently used methods to package damaged and defective batteries. The Chairman suggested that DGAC present their proposal to the Subcommittee and that the issue may be referred back to the WG in due course.

Action Item

VDA to share damaged/defective transportation methodology with WG. WG participants to provide example guidance of how to handle such batteries to next WG

meeting. WG to ask Subcommittee whether the WG can issue guidance or technical criteria for when

lithium batteries are to be considered damaged for defective.

Test Failure Criteria

PRBA noted that many batteries equipped with resettable circuit interrupt devices. However the test provisions do not currently permit for the resetting of such devices during the test sequence, and therefore these batteries would fail. PRBA requested the Subcommittee add the issue of fail/safe devices to the mandate of the WG and discuss the issue at the next session.

Action Item

WG to ask Subcommittee to add the issue of failsafe devices to the fail criteria of the UN38.3 tests.

Schedule of Next Session

1. The WG discussed the possible dates and location of the next WG Session. Dates and locations were discussed: 26-28 August 2015

Locations proposed:

Bordeaux, France (Saft) Germany Washington, DC, USA

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Dearborn, Michigan, USA

End of Day 2

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Annex

Draft Proposed Changes to UN Model Regulations

[IEC proposal - Definitions] 3.3.1, SP 188

New (c) Each component cell shall not exceed the cell limit for a cell given in (a).

(f)(ii) Packages containing no more than f0our cells or four single cell batteries or two multi-cell batteries installed in equipment...

(i) – delete new paragraph

P909 (2) However, [delete existing text] [add] cells and batteries meeting requirement (a) or (b) of special provision 188.

[Envites proposal - Definitions] - Battery cell means a (single) encased electrochemical unit (at least one positive and on negative electrode) which exhibits a voltage differential across its (two) terminals, and may contain its protection devices or other features.

[PRBA Proposal - Definitions] 38.3.2 Scope

[add at the end of the paragraph] A cell or battery that is an integral part of the equipment it is intended to power, is installed in the equipment during the manufacturing process and that is transported only when installed in the equipment may be tested in accordance with the applicable tests for a battery when installed in the equipment.

[PRBA Proposal - Definitions] 38.3.4.5.2 Test Procedure

[add at the end of the paragraph] When testing an integral battery that is installed in the equipment it is intended to power, the short circuit shall be conducted by contacting exterior points of the battery (e..g., connectors, sockets).

[RECHARGE Proposal – New Battery Technologies] UN Model Regulations 3.3 Dangerous Goods List

[Modify UN3090 Entry] LITHIUM METAL BATTERY, including lithium alloy and lithium metal polymer batteries

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