UN TH EDITION TOP 10 FAQ S. Rich Byczek, Intertek
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1 UN TH EDITION TOP 10 FAQ S Rich Byczek, Intertek
2 IF WE DID ALL THE THINGS WE ARE CAPABLE OF WE WOULD LITERALLY ASTOUND OURSELEVES. Thomas Edison 2
3 MORE THAN 100 COUNTRIES, WITH 1,000 LOCATIONS & 42,000 EMPLOYEES, DELIVERING TOTAL QUALITY SOLUTIONS OUR SECTORS OUR SERVICES Products Assurance Testing Trade Resources Inspection Certification DEPTH AND BREADTH OF SERVICES GLOCALLY 3
4 A GLOBAL ENERGY STORAGE FOOTPRINT North America: Detroit, MI Grand Rapids, MI San Antonio, TX Phoenix, AZ. EMEA: Milton Keynes, UK Kaufbeuren, Germ. Kista, Sweden APAC: Shanghai, China Guangzhou, China Taipei, Taiwan 4
5 BATTERY TESTING AND CERTIFICATIONS From hearing aids to electric busses UN 38.3 CB Scheme IEC ETL Safety Mark UL 1642 (Non-rechargeable Lithium) UL 2054 (Household / Commercial) UL 1973 Electric Vehicle Battery SAE J2464 Custom Abuse Testing Performance and Life Cycle Evaluation 5
6 FAILURE ANALYSIS Review of battery and electronics design Critical examination of supporting documentation such as: FMEA Manufacturing controls Dissection and analysis of fresh and failed cells Material Analysis: CT Scan SEM-EDS X-ray GC-MS Technical Manufacturing Audits 6
7 AGENDA 01 Introduction 02 Brief UN 38.3 Status 03 Latest changes 04 Top 10 FAQ 05 Q&A 7
8 UN 38.3 REQUIREMENTS LATEST and GREATEST section 38.3 Recommendations on the Transport of Dangerous Goods. Manual of Tests and Criteria. 6 th Revised Edition Issued 2015 Date of Enforcement: January 1, 2017 Notes: 1. Corrigendum 1 released Feb Multiple corrections to section Any testing of batteries must now reference the 6 th edition.
9 HISTORY OF UN 38.3 REQUIREMENTS Separate from Electrical Safety Part of Dangerous Goods Regulations Consider all means of transport Sub-supplier to end product Mfr. MFR to distributor Battery in our outside of product In-field/In-use Product returns Non Standard packaging
10 CHANGES IN THE 6 TH EDITION 2015 Rev 6 1. Clarification of COMPONENT CELL, CELL, and BATTERY/ BATTERY ASSEMBLY/ MODULE: As described in this training. 2. Reduction in the SHOCK test peak G level for large batteries. Base shock pulse on constant energy, rather than constant acceleration. a) For Cells and Batteries under 12kg, start at 150G/6ms, and allow for reduced peak above 4 kg. b) For Cells and Batteries over 12kg, start at 50G/11ms, and allow for reduced peak out to 120kg 3. Clarification of Overcharge test applicability. 4. Clarify Overcharge test reasoning.
11 CHANGES IN THE 6 TH EDITION 2015 Rev 6, continued 5. Clarification of Short Circuit test temperature conditions. 6. Short circuit test conditions clarified to allow for testing inside or outside of a temperature chamber or oven (i.e. precondition, then test at ambient temperatures. 7. Added a separate paragraph to the Battery Assembly exemption: was previously f, now includes g as a separate paragraph. 8. For >6200 Watt-hour battery assemblies, add requirement to demonstrate that Overcharge, Short Circuit and Over-discharge between batteries within the assembly are addressed. This may be done via testing or other engineering demonstration
12 TESTS T1 T8 T1-T5 (Same Samples, Tested in Order, All Types) T1: Altitude Simulation T2: Thermal Test T3: Vibration T4: Shock: major change for large cells and batteries T5: External Short Circuit: small changes T6: Impact/Crush (Primary and Secondary Cells Only) T7: Overcharge (Secondary Batteries Only) T8: Forced Discharge (Primary and Secondary Cells Only)
13 T4: SHOCK (CELLS) May/may not be representative of actual events Tests mechanical integrity. Major change for batteries larger than 4.48kG TEST: Small cells :150g/6ms Large cells :150g/6ms OR 50G/11ms Consider the type of battery these will go into and select accordingly. Recommend to test both levels if uncertain.
14 T4: SHOCK (SMALL BATTERIES) TEST: Small Batteries: 6ms duration with a peak acceleration the LESSER of 150g or Result of the equation: Accelerati on( g n ) mass* ** NOTE: acceptable to use a higher peak acceleration (ie: 150G in all cases)
15 SHOCK PULSE 6MS, BELOW 12 KG
16 T4: SHOCK (LARGE BATTERIES) TEST: Large Batteries: 11ms duration with a peak acceleration the LESSER of 50g or Result of the equation: Accelerati on( g n ) mass* ** NOTE: acceptable to use a higher peak acceleration (ie: 50G in all cases)
17 SHOCK PULSE 11MS, ABOVE 12 KG
18 T5: EXTERNAL SHORT CIRCUIT Simulates an external short to the terminals of the cell or battery. TEST: Sample case monitored for temperature. Stabilize sample at temperature of +57C +/-4C Stabilization time of 6 hours (small cell/batteries) or 12 hours (large cells/batteries) OR document reasoning for shorter or longer durations to achieve homogeneous stabilized temperature Apply short circuit (<0.1ohm) across terminals. Maintain at least hour after sample temperature returns to For cells and small batteries: +57 +/-4C For large batteries: has decreased by half of the maximum temperature increase observed during the test and remains below that value NOTE: Short circuit may be applied under ambient conditions or within test chamber conditioned to achieve the +57 +/-4C, but the sample must be at > +53C at the beginning of the short circuit.
19 COMMON QUESTIONS 1. I tested to the old version UN 38.3, do I need to retest?
20 COMMON QUESTIONS ANS: No, you do not need to retest batteries that have already been shown to pass a previous version of the UN 38.3 tests. When a new battery is assembled with old (tested under a previous UN 38.3 version) cells, the battery is tested to the current requirements, and the cells DO NOT require retesting. TEASER: China is an exception, see question 6 For models already tested in the past: Reference United States 49 CFR (harmonized to section of the UN model regulations) Cells and batteries manufactured according to a type meeting the requirements of sub-section 38.3 of the UN Manual of Tests and Criteria, Revision 3, Amendment 1 or any subsequent revision and amendment applicable at the date of the type testing may continue to be transported, unless otherwise provided in this subchapter.
21 COMMON QUESTIONS 2. I have a Lithium Polymer (or Lithium Iron Phosphate), not a Lithium-Ion, so I am exempt from testing, right?
22 COMMON QUESTIONS ANS: No, Lithium Polymer and Lithium Iron Phosphate are just different versions of rechargeable Lithium When a new battery is assembled with old (tested under a previous UN 38.3 version), the battery is tested to the current requirements, and the cells DO NOT require retesting. Per definitions in clause Lithium ion cell or battery: A lithium polymer cell or battery that uses lithium ion chemistries, as described herein, is regulated as a lithium ion cell or battery. 22
23 COMMON QUESTIONS 3. Do I need to perform UN 38.3 on my UL 2054 listed battery? or My battery meets UN 38.3, so I don t need to certify my battery to UL 2054, IEC 62133, etc.
24 COMMON QUESTIONS ANS: UN 38.3 is part of the dangerous goods transportation regulations, and does not address the battery as part of an electrical device or system. Conversely, UL 2054 has similar, but not fully harmonized tests to UN 38.3, and therefore is not considered equivalent. In the case of IEC 62133, there is a clause assuming that UN 38.3 requirements are already met (to avoid performing redundant tests), but there are still additional requirements within IEC NOTE check with the test lab/certification body as to what evidence they require to prove that the UN 38.3 requirements are properly met (i.e. Test report, calibration data, evidence of lab s accreditation, etc.) 24
25 COMMON QUESTIONS 4. Do I need to enable my BMS, or close contactors, etc. for the short circuit or overcharge tests?
26 COMMON QUESTIONS ANS: NO for Short Circuit, YES for Overcharge. The Short Circuit test is evaluating an external short circuit to the terminals of the battery DURING TRANSPORT (i.e. not during use). Note: terminal covers (which are manually attached to the battery) must be removed. It is not assumed that they will be in place during any future transport of the battery. The Overcharge test, on the other hand, is evaluating a battery that has been exposed to a improper charging event, then subjected to transport (hence the 7 day observation period.) 26
27 COMMON QUESTIONS 5. Can you certify my battery(or cell) to UN 38.3?
28 COMMON QUESTIONS ANS: UN 38.3 is part of the dangerous goods transportation regulations, and is a self-declaration test. The manufacturer or shipper of the cells/batteries must affirm that the shipment complies with the appropriate shipping regulations (including compliance to UN 38.3). TEASER: The exception is for exports from China.
29 COMMON QUESTIONS 6. So, what about China, then?
30 COMMON QUESTIONS ANS: Chinese ports (air/sea) require that all batteries be certified for safe transport; there are separate Airworthiness and Seaworthiness certificates. In the case of Lithium/Lithium-ion, the batteries must be tested to the UN 38.3 requirements as well as meet a 1.2 meter drop test (within its intended packaging). This must be performed in-country at an approved/recognized lab. Each Chinese port will determine which labs test reports/certificates are acceptable, so it is best to verify with the port authorities. Chinese Certificates are valid for one-year. They must be renewed annually for a fee (without retest) Retesting is required when the UN 38.3 requirements change (i.e. Must retest batteries now to the 6 th edition).
31 COMMON QUESTIONS 7. Do I need to apply the UN mark?
32 COMMON QUESTIONS ANS: Although there are some discussions on applying a UN mark or similar to batteries, there is no such requirement, regulation or official recommendation to do so. The UN mark here is limited to certain types of packaging only, which is certified by a UN-approved packaging lab.
33 COMMON QUESTIONS 8. Is my power bank/booster a battery or a charger?
34 COMMON QUESTIONS ANS: While these devices may have additional features, they are primarily used to provide power to another device, and therefore considered as batteries by transportation regulators (UN 3480 or UN 3090). They are subject to the same tests and packaging requirements as cells (for single-cell power banks) or batteries (for multi-cell power banks). A single cell Power bank, assuming the component cell has already met T1-T5,T6, and T8, must be tested to T7 as a single cell battery. A multi-cell power bank, must be tested to T1-T5 and T7(for rechargeable types) as a battery. Shipping/packaging quantities are based on UN 3480/3090 (cells or batteries)
35 COMMON QUESTIONS 9. I ve heard about 30% SOC requirements, what does this mean?
36 COMMON QUESTIONS ANS: While not directly part of the UN 38.3 requirements, there are currently requirements in place that batteries shipped alone (UN 3480) must be set at or below 30% state of charge (SOC) for air shipment. This does not apply to batteries shipped in/with equipment (UN 3481).
37 COMMON QUESTIONS 10. Back to 30% SOC requirements, how can I meet this requirement and how can it be enforced?
38 COMMON QUESTIONS ANS: Enforcement is unclear, as there is no consistent method for a regulator to determine a battery SOC. Recommendation for shippers: Document your own method for ensuring <30% Charge indicator (how many bars?) Specific charge/discharge duration OCV (below xx Volts = 30%SOC) Document the method used, and how the shipment was verified.
39 MORE ON ENFORCEMENT Competent Authorities have the final say. You may request an official finding. These may be made public information. If you believe you have a Unique battery type that warrants different test conditions, not defined in the test standard. If you are unsure how to configure the test sample for test conditions (such as Short circuit) Does a certain test result constitute a failure? Consider the competent authority in the country of origination of the shipment (not only the country of manufacture), and any lay-over country. Airlines and carriers will have their own rules about what is/ is not acceptable.
40 EVEN MORE ON ENFORCEMENT Recommendations: 1. Consult with your shipper or forwarder on their requirements, including training. 2. Get copies and review test reports from 3 rd party mfrs and cell suppliers. The manufacturer is officially responsible, but technically/ realistically: whoever offers for transport is taking legal liability for the shipment, and should be able to provide evidence of compliance to regulators. 3. Utilize a Test Declaration of Conformity (i.e.: one pager ) for your shipping documents, and maintain a copy of relevant test reports.
41 COMMON QUESTIONS BONUS QUESTION: What s next?
42 COMMON QUESTIONS ANS: Many of the recent changes (5 th and 6 th editions) have addressed the complexities of larger and larger battery systems, such as Stationary Energy Storage and Electric Vehicles. Much effort in place currently to develop a repeatable PROPAGATION TEST to evaluate a battery or packaging ability to contain or self-limit any fires or explosions. Statistically, we cannot prevent a single-cell thermal runaway event from occurring, but we can limit (through design) the effects of a single-cell failure during transport.
43 SUMMARY UN th edition in effect, mostly minor changes. Always consider what level of cell/ battery/ assembly/module/pack is to be shipped, how and to/from where There are still misconceptions, always document your rationale, but know that the dangerous goods/transport authorities have final say. 43
44 Rich Byczek, Global Technical Director intertek.com/transportation
45
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