1. UN Lithium Battery Tests 1985 - 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?