Lithium Battery Compliance Management

Day 1 - Battery Introduction

1. Speaker Credentials / Student Self-Introductions
2. System view of batteries   “Cradle to Grave”
   1. Engineering - Optimize cell/battery design to match tool
   2. Manufacturing – Production of batteries
   3. Operations - Support tool-battery interface issues
   4. Sustaining - Support field disposition of batteries
   5. Regulatory – Assure compliance with shipping/storage/disposal laws
3. Battery Information
   1. What is a battery?
      1. What makes them dangerous?
         1. Gas evolution
         2. Heat evolution
         3. Combustion
         4. Toxic & corrosive ingredients
   2. Differences between Primary & Rechargeable
   3. Specific examples of battery chemistries
      1. Consumer applications
      2. Oil service applications
4. Why do we need batteries
   1. Can’t use power cord
   2. Want device portability
      1. Examples (IPhone, Smart Watch, Toys, EV, etc.)
      2. Want small & light & long lasting power source
         1. Small ---> high volumetric energy density
         2. Light ---> high gravimetric energy density
         3. Long life ---> efficient tool electronics & high energy content battery
5. Consequences of efficient, long lasting, high energy batteries
   1. Severe failure modes
   2. Toxic ingredients
   3. Restrictive shipping
   4. Regulatory compliance issues
      1. Packaging requirements
      2. Special Labeling
      3. Limited carriers (Certified cargo shippers)
      4. Special Storage requirements
      5. Training certification for handlers
6. Why Do We Need Regulations?    
7. Examples of US and International Organizations and Standards
8. Publicized Examples of Battery Failures

Day 2 Battery Regulations & Compliance with HSE

1. Review of First Day
   1. Types & Groupings of Batteries
      1. Individual Cells vs Battery Packs
      2. Primary vs Rechargeable
      3. Stand Alone, Packed with Equipment, Packed in Equipment
   2. Regulation Realms
      1. Manufacture
      2. Transportation (air, ground and sea)
      3. Usage
      4. Disposal
   3. Justification for Battery Regulations
   4. Must be global & harmonized
   5. Must include all modes of shipment
   6. Must be dynamic & relevant
   7. Not to be confused with current negative reg mantra
2. Battery Regulations Designations
   1. Shipped as individual batteries only
   2. Shipped ‘with equipment’
   3. Shipped ‘in equipment’
   4. Rechargeable batteries (Lithium ion)
   5. Primary batteries (Lithium metal, non-rechargeable.)
3. Examples of proper shipping names
   1. UN 3090 – Lithium metal batteries only
   2. UN3480 – Lithium ion batteries only
   3. UN3091 – Lithium metal batteries packed with equipment
   4. UN3091 – Lithium metal batteries contained in equipment
   5. UN3481- Lithium ion batteries packed with equipment
   6. UN3481 – Lithium ion batteries contained in equipment
4. Modes of Transportation Regulations
   1. Ship via ground in USA uses DOT (Dept. of Transportation)
   2. Ship via air in USA or outside uses DOT & IATA (Int’l Aviation Transport Association
   3. Ship via ocean going vessel in USA or outside uses DOT & IMDG (Int’l Maritime Organization’s Dangerous Goods)
5. Examples of IATA Packing Instructions (PI)
   1. Standalone Lithium ion Battery is PI 965 UN3480
   2. Lithium ion Battery packed with Equipment is PI 966 UN3481
   3. Lithium ion Battery contained in Equipment is PI 967 UN3481
   4. Standalone Lithium metal battery is PI968 UN3090
   5. Lithium metal Battery packed with Equipment is PI 969 UN3091
   6. Lithium metal Battery contained in Equipment is PI 970 UN3091
6. DOT/UN Battery Safety Tests (as of 2001)
   1. T1 – Altitude simulation test (50,000 feet)
   2. T2 – Thermal test (75 C à -40 C in < 10 minutes)
   3. T3 – Vibration (7 Hz à 200 Hz à 7 Hz in 15 minutes)
   4. T4 - Shock (150 G @ 6 mSec)
   5. T5 - External Short Circuit (0.1 ohm @ 55 C)
   6. T6 – Impact (20 lbs. dropped 2 feet on 5/8” rod)
   7. T7 – Overcharge (rechargeable cells only)
   8. T8 – Forced Discharge (Max. current @ 12 V for capacity duration)
7. Details of relevant Regulations. (partial list)
   1. UN/DOT 38.3
   2. 49 CFR sections 173.185 and 172.101
   3. UL 1642 and UL2054
8. Training Requirements

Day 3   Management Systems for Lithium Batteries: “How to Safely and Efficiently Handle Batteries throughout their Life Cycles”

1. Definition of Battery Life Cycle
   1. Engineering/Manufacturing Phase
   2. Storage – Pre, Trans and Post Manufacture
   3. Operational Issues
   4. Shipping Concerns
   5. Disposal Issues
2. Engineering/Manufacturing Phase Details
   1. Define electrical, mechanical and usage requirements of intended tool
   2. Determine best battery match from existing batteries
   3. Engineering & manufacturing staff determine optimal design and assembly process
   4. Build & test prototype battery per custom requirements (2a)
   5. Document Qualification test results for regulatory and operational needs
3. Storage Issues (Legally compliant)
   1. Assure safety relevant issues (fire extinguisher, alarm, distance, etc.)
   2. Locate and build storage area for hazardous and non-hazardous battery parts
   3. Locate and build storage area for completed lithium packs
   4. Assure that battery assembly area and storage areas are contiguous.
   5. Determine & obtain packaging materials with proper up to date labels.
   6. Assure segregation and unique identity of new, used and depleted batteries.
4. Operational Issues
   1. Assure proper training of manufacturing assemblers, field users and engineering staff.
   2. Determine battery performance in tool versus temperature, tool load, multi-use, etc.
   3. Confirm battery-tool performance on shock machine at temperature.
   4. Provide field guidelines when battery is to be replaced or when to be re-used (CRITICAL)
      1. If possible, allow electronic determination of consumed capacity of battery
      2. Organize database of battery field results per region, per tool.
   5. Assure that all required Regulatory documentation is available to users.
5. Shipping Concerns
   1. Assure that Regulatory documents are current, relevant and available
      1. Documents are sender and receiver location sensitive.
      2. Batteries by themselves have separate unique documents
      3. Batteries in tools have separate unique documents
      4. Batteries with tools have separate unique documents
      5. Depleted batteries have different regulatory documents
      6. Rechargeable batteries must be shipped with less than 30% charge.
      7. Damaged batteries have separate unique documents.
   2. Each different battery type has different regulatory documents.
   3. Air, ground, maritime mode of transportation have different regulatory documents
6. Disposal Issues
   1. Assure that disposer is licensed to handle relevant battery chemistry
   2. Assure that disposer has sufficient expertise and takes on liability.
   3. Assure that all batteries sent for disposal are identified, tracked and neutralized.
   4. Assure that all depleted batteries are packaged per current regulations
   5. Assure proper record keeping and maintain world wide database (new, used, disposed)
7. Corporate Wide Battery Continuity
   1. A team of BSO (Battery Safety Officers) are required to maintain knowledge base
   2. Evolving matters with technology, regulations and operational aspects require this
   3. BSOs should circulate and not be stationed in one geographic area.
   4. BSOs need to interact with field and product centers.
   5. BSOs need to audit battery disposer, field sites and product centers routinely.
   6. BSOs need to report to HSE headquarters not Operations.
   7. Minimum requirements is BS or (preferred) advanced degree MS/MA or PhD
   8. BSOs are more critical if battery manufacturing is performed outside the company
8. Final Course Q&A

Appendices

1. List of Handouts for the Class
2. Links discussed in the Class and offered for additional references
3. Recommended books or publications for purchase