Two years inside for supplying non UN38.3 batteries

[trex]

Originally Posted by trex

UN38.3 does not apply if the battery weighs less than 5kgs.



I am pretty certain that ALL Lithium Ion batteries have to be UN38.3 certified, even watch batteries. The only exemption, according to Clive, BEBA's DGSA, is for prototype batteries.

Trex, where did you read that batteries under 5kg were exempt? I would like to get Clive to look into it.

Best regards

David

http://inspiredenergy.com/standard_products/Shipping%20&%20Handling%20Li%20ion%20Batteries%2013-01-01.pdf
Page 3 of the report, there is a table to recap current US regulations. Towards the bottom of the table, there is a row concerning typical e-bike shipped with battery.
I could not find much on various EU libraries - most information understandably comes from Royal Mail, UPS, TNT and various UK forwarders.
Did not find much written about the new DGSAs besides stories of disposal of dead batteries by some UK universities.

 

[shemozzle999]

The following link will take to Accutronics website where there is a very clear explanation of the rules regarding transportation of Lithium batteries Lithium Ion Battery Transportation

Interesting testing procedures, no mention of an optional fire bucket required for T5!

Test T1: Altitude Simulation. Simulates air transport under low pressure conditions. Store at 11.6kPa or less for 6 hours at +20°C.

Test T2: Thermal Test. Assesses cell and battery seal integrity and internal electrical connections using thermal cycling to simulate rapid and extreme temperature changes. Perform 10 cycles between +75°C and -40°C, 6 hours per cycle with no more than 30 minutes between cycles of the battery.

Test T3: Vibration. Simulates vibration during transport. Sinusoidal waveform with a logarithmic sweep between 7Hz and 200Hz and back to 7Hz in 15 minutes. This cycle must be repeated 12 times for a total of 3 hours for each of three mutually perpendicular mounting positions of the battery.

Test T4: Shock. Simulates possible impacts during transport. Half-sine shock of peak acceleration of 150g and pulse duration of 6 milliseconds. Each battery shall be subjected to three shocks in the positive direction and 3 shocks in the negative direction of three mutually perpendicular mounting positions for a total of 18 shocks. The test differs for large cells or batteries, refer to the Manual of Tests and Criteria.


Test T5: External Short Circuit. Simulates an external short circuit. After stabilizing at +55°C, apply an external resistance of less than 0.1 Ohm for 1 hour and then observe for 6 hours.

Test 6: Impact. Not applicable for batteries (only for cells).

Test 7: Overcharge. Evaluates the ability of a rechargeable battery to withstand overcharge, Charge at twice the manufacturer's recommended maximum continuous charge current for 25 hours, and then observe for 7 days.

Test 8: Forced Discharge. Not applicable for batteries (only for cells)

 

[Wisper Bikes]

We at BEBA have asked our DGSA to put a set of rules together that should be adhered to by any company handling lithium ion batteries and electric bicycles in particular. I think this sets out the rules and regulations succinctly and clearly. I have liaised with our DGSA to come up with the following;

We believe these regulations are a good thing for the industry, they ensure batteries are safe and reliable. We believe that such tough penalties against dealers and distributors for mishandling or selling uncertified batteries will discourage the sale and distribution of potentially dangerous products. Such certification will also give potential customers and dealers the opportunity to make certain the bike they are buying is legal. To ensure that household and business insurances are valid incase of an incident involving a battery.

Advice and notes regarding legally handling Lithium Ion battery packs in the UK and Europe

1. Lithium Ion batteries, rated 100Wh or more, are classified Class 9 Dangerous Goods for the purposes of transportation anywhere in the world.

2. All Lithium Ion Batteries, manufactured anywhere in the world, must be certified to UN Manual of Tests & Criteria Chapter III subsection UN38.3, whether sold in equipment or not.

3. The UN38.3 test is a manufacturing requirement and the manufacturer MUST evidence both this and a Quality Manufacturing Program.

4. No Lithium battery can be offered for transport, whether or not installed in a bicycle, unless the person or organisation offering that battery or bicycle has evidence that tests have been carried out, and has documentation showing evidence of a Quality Management System from the battery manufacturer.

5. It is a criminal offence to offer for transport Lithium Ion batteries that are not certified to UN38.3 standards. Severe penalties apply to any person that offers Dangerous Goods for transportation that are not in compliance, this could be up to 2 years in prison plus unlimited fines whether or not an incident arises.

6. Any company offering Lithium Ion batteries for transportation must employ staff trained and certified in receiving and sending Dangerous Goods. Certification must be renewed every 24 months.

7. Any company supplying a Lithium Ion battery, and cannot show evidence of the supporting testing to UN38.3, would almost certainly be uninsured against commercial losses in a civil recovery by the carrier or an injured third party.

8. The authorities have started to crack down in this area. This is due to the fact that, it is the failure of manufacturers to comply with the tests, and criteria, that are believed to be the reason for a number of recent fires in transport.

9. As an importer of Dangerous Goods into Europe, incorrect packing and marking would be the liability of the importer under ADR, which makes the importer the "consignor".

10. All electric bicycle suppliers should notify their insurers that they are selling lithium battery powered vehicles.

11. Companies that receive, unload, load or offer for transport, more than 333kgs of batteries* (in most cases less than 100 e-bike batteries), are required to appoint a DGSA (Dangerous Goods Safety Advisor). This applies whether the batteries are installed in bikes or not.

* The weight of the batteries only within any single consignment.

12. A battery can be offered for transportation, without restriction, by road, if the battery is installed and securely fastened in the battery holder of an e-bike. In such a manner to prevent damage, short circuit or accidental activation. It is not permitted to include spare batteries in the same carton. This does not apply if sending more than 333kg of batteries in the same consignment (see 10).

IMPORTANT NOTE

All of the above is intended as a generalisation of requirements and is not intended as a definitive instruction. It is for general guidance only.

BEBA and it’s officers can not be held responsible for any losses, costs or damages due to any reliance on the information contained in this post.

I do hope this helps everyone involved, if you have any questions you would like to put to me please feel free to email me at dmiall@me.com

All the best

David

 

[Scimitar]

Yet another little piece of legislative nonsense, and the ratchet gets screwed down a little tighter.
What's all this crap about renewing certs every 2 years? Jobs for somebody, that's for sure.
This has the smell of some agency about it - some agency that's set up to get government work or lucrative fees from the private sector (who have no choice but to comply).

 

[Wisper Bikes]

The problem is Dave, that there have been a lot of instances of cheap, uncertified batteries causing fires in Germany and now one fatality in China. This kind of publicity does absolutely nothing for the electric bicycle industry. I cant think of an electric bicycle producer or distributor who would mind conforming to these regulations if conformance meant that such bad publicity and unnecessary suffering was put to an end.

As long as the batteries have been tested (costs about £15,000), have passed the tests, and staff have been trained in DG handling (£500) there is very little to worry about. Batteries need to be retested every year to make certain nothing has changed, (£500). Staff need to be re-certified avery 24 months (£150.00).

For the sake of confidence in the industry and customer safety, not too big a price to pay IMHO.

All the best

David

 

[trex]

I agree that all e-bike batteries should have UN38.3 attached to it and people should use UN38.3 certified packaging for sending bike batteries by post but i think Dave's interpretation is a bit alarmist.
A DGSA is required by substantial consignors, usually the courier company.
Dave's interpretation makes any vendor a 'consignor' where in reality, the courier company picks up the bike - presumably with their DGSA's accord.
If there is a problem, the courier who handles the battery is the one who messes up (eg dropping it).
As far as I am aware, you can go on the internet and ask for a quote to take your e-bike to any EU country without needing a DGSA.

 

[Wisper Bikes]

Hi Trex,

Yes we can send the bikes, or batteries now, anywhere in the world without needing a DGSA. I would however need a trained and certified member of staff to sign off such deliveries, in our out and use the correctly certified packaging.

If however I was accepting a delivery of over 333kg of batteries or despatching the same, I would need a DGSA on board as a consultant.

I am sorry if I sound alarmist, that is not my intention. I am simply sharing what I have discovered over the last few weeks with everyone in the industry, so they do not fall foul of the law or end up with an uninsured claim against them. I would hate for one of us to get into serious trouble at a time I had the information, but had not shared. Although a lot of us here are in competition with one another, we all need to band together to make this work. BEBA or not!!

All the best

David

 

[Scimitar]

And the cheapskate knobs who caused the problems will continue to ship dodgy goods and just lie about what's in the package.

 

[Wisper Bikes]

'fraid so Dave!

I believe we all have a duty to warn potential e-bike customers that there are dangerous batteries on the market. That they should demand to see UN38.3 certification before, or at the time of purchase. The customer can then make the decision whether to take the risk or not. "Caveat emptor"

All the best

David

 

[trex]

The current legislation is here for anyone interested in a little light reading:
Carriage of Dangerous Goods - ADR and the carriage regulations 2004

It applies to carriers, packers, fillers, loaders and unloaders, subject to some exemptions discussed below. The exemptions arise from ADR 1.8.3.2 and have been implemented by CDG Regulation 3 (j). The GB exemptions do not apply to international carriage. The two exemptions are alternatives.
12 Packer and unloader are defined in ADR at 1.2.1. DfT guidance is that “final unloaders” (consignees) will not need to appoint a DGSA. Intermediate unloaders (such as freight forwarders and consolidators and operators of “in-transit” storage facilities) will need to have a DGSA.

 

[Wisper Bikes]

Thanks Trex, I will look into that immediately.

I think however the "final unloaders" or "consignees" refers to the end user. So "Mr Smith" who has just bought his shiny new electric bike of course take delivery. I am not certain it applies to an electric bike dealer though. I will get clarification.

All the best and thanks for your valuable assistance.

David

PS, I have now written to Clive for clarification as promised. I think that a bike distributor would be considered "operators of “in-transit” storage facilities". Dont forget this only applies to distributors taking more than 333kg of batteries in one delivery. So in our case about 80 bikes.

 

[trex]

Just to clarify with regard to sending e-bikes by courier, e-bike Lithium batteries are specially excluded from ADR as per http://www.unece.org/fileadmin/DAM/trans/danger/publi/adr/adr2011/English/VolumeI.pdf

1.1.3.7
Exemptions related to the carriage of lithium batteries
The provisions laid down in ADR do not apply to:
(a) Lithium batteries installed in a vehicle,
performing a transport operation and destined
for its propulsion or for the operation of any of its equipment;
(b) Lithium batteries contained in equipment fo
r the operation of this equipment used or
intended for use during carriage (e.g. a laptop).

Presumably the batteries on e-vehicules are subject to more rigorous tests than RC toys.
The 333kgs specification only applies to transport of batteries, not consignment of e-vehicules.