UN Lithium Battery Tests 1985 - 2013

1. UN Lithium Battery Tests1985 - 2013 George A. Kerchner PRBA – The Rechargeable Battery Association 1776 K Street, NW Washington, DC 20006 202.719.4109 gkerchner@wileyrein.com

2. 1985 ICAO Packing Instructions* * Similar entries in IMDG Code

3. 1985 ICAO Packing Instructions* * IMDG Code had similar requirements but limits batteries to 500 g Li metal

4. 1985 ICAO Packing Instructions* • Tests in Packing Instruction 406 included following tests: - Thermal - Short circuit - Altitude - Vibration - Shock * Same requirements in IMDG Code

5. 1989 – 1990 • December 1990, UN Sub-Committee Meeting • Canada proposes series of tests for lithium batteries • No reference to origin of tests • Passing tests authorizes classification of batteries as Class 9 dangerous goods

6. 1991 – 1992 • July 1992 proposal from U.S. and Canada • Special Provision 188 • Exception for “small” batteries, no UN testing required • Exception for “medium” batteries, provided UN tests conducted • Special Provision 230 • Applies to larger batteries; UN testing required • Battery may not contain more than 500 g Li metal • Meeting report notes UN tests generally consistent with new IEC standard; new ISO standard also being developed

7. 1991 – 1992 • December 1992, UN Committee adopts new UN tests and Special Provisions • New definitions but no distinction made between small and large lithium batteries • Shock test references IEC standard 68-2-27 • “… applicable to components, equipments and other electrotechnical products.” • New tests and definitions effective January 1995 • Section 38.3, Second Revised Edition of UN Manual

8. 1997 – 1998 • Significant activity and participation by Sub-Committee members and industry • Germany, Canada, U.S. , France, IEC, PRBA, NEMA, EPBA and BAJ • Emphasis on Lithium ion battery technology and need to distinguish between large and small lithium batteries • Germany proposes change to shock test • Notes shock tests simulating auto accidents typically range up to 40 g peak

9. 1997 – 1998 • Agree to modify UN tests to account for lithium ion technology • Equivalent lithium content introduced in Model Regulations • New definitions for Large and Small Cells and Batteries • Large battery: aggregate lithium content > 500 g • No exception for battery assemblies over 500 g lithium content • Shock test • Small cells and batteries, test unchanged (75 g and 125 g to 175 g) • New test criteria for Large cells and batteries - subject to 50 g • Test still references IEC 68-2-27 • New tests and definition effective January 2001 • Section 38.3, Third Revised Edition of UN Manual

10. 1999 – 2000 • Canada and Germany again raise question about testing large EV batteries • “Modules” as batteries first mentioned • March 1999 lithium metal battery incident at LAX airport • March 2000, Intercessional WG meeting held in Ottawa • December 2000, UN agrees to substantial changes to lithium battery tests • Require testing of all cells and batteries (i.e., “small” cells and batteries no longer exempt from testing)

11. 1999 – 2000 • Shock test changed to require 150 g for Small cells and batteries and 50 g for Large cells and batteries • Exemption from testing adopted for battery assemblies containing over 500 g lithium content based on U.S. and Japan proposal • New tests and definitions effective January 2003 • Section 38.3, Amendment 1, Third Revised Edition of UN Manual

12. 2005 – 2006 • PRBA proposals adopted • New entries in Model Regulations for Lithium ion batteries to distinguish from Lithium metal batteries • Regulate Lithium ion batteries based on Watt-hours instead of equivalent lithium content (ELC) • 20 Wh replaces 1.5 g ELC for cells • 100 Wh replaces 8 g ELC for batteries • 6200 Wh replaces 500 g ELC for battery assemblies • Applicable changes made to UN Manual • New tests and definitions effective January 2009 • Section 38.3, Amendment 2, Fourth Revised Edition of UN Manual

13. 2007 – 2008 • July 2008, PRBA proposal adopted eliminating testing of discharged lithium ion cells/batteries • November 2008, PRBA hosts working group meeting on UN lithium battery tests • December 2008, PRBA proposals adopted • Testing one battery assembly < 6200 Wh • Exemption from the overcharge test for batteries not equipped with overcharge protection designed for use only in battery assembly (with overcharge protection) • “Large battery” definition changed from > 500 g Li content / 6200 Wh to gross mass > 12 kg • New tests and definitions effective January 2011 - Section 38.3, Fifth Revised Edition of UN Manual

14. 2009 – 2010 • Working group meetings held in Paris, Kyoto and Washington, DC • December 2010, UN adopts changes to UN tests and definitions focused primarily on small cells and batteries • Vibration test for large batteries changed • Peak acceleration reduced from 8 g to 2 g • New tests and definitions effective January 2013 • Section 38.3, Amendment 1, Fifth Revised Edition of UN Manual

15. Section 1.1.2 of UN Manual of Tests and Criteria • The competent authority has discretion to dispense with certain tests, to vary the details of tests, and to require additional tests when this is justified to obtain a reliable and realistic assessment of the hazard of a product. • How is this used by competent authorities? • Does it authorize modifications to UN tests? • Are such approvals recognized internationally?