Lithium Battery Regulatory Overview

EPA OSHA FIRE CODE CPSC

LOTS OF LINKS TO RESOURCES! QR codes replaced! ☺

Fire safety

Jennifer Volkman

Jennifer.Volkman@state.mn.us

Who Regulates Lithium Batteries?

DOT/PHMSA: requires taping and special packaging

Check out the first webinar posted online at NAHMMA.org! (Chris Blan)

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Final (5-22) Safety Advisory Notice for the Transportation of Lithium Batteries for Disposal or Recycling

Webinar: Safe Transportation of Lithium Batteries: What You Need to Know

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9/21 Lithium-Battery-Guide.pdf ---posted under webinar 3

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Common Carriers have additional requirements and guidance

Follow your Contractor’s guidelines for packaging, labeling, and shipping for recycling or disposal.

Lithium Battery management: staff and consumer safety

Consumer Product Safety Commission: recall management, safety information, research.

Consider adding yourself to their mailing list for recalls.

CPSC needs our guidance to help them better manage battery recalls.

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OSHA: exposure to gasses

Alkaline, NiCd, NiMH: Hydrogen gas

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Lithium: CO, CO2; large amounts of hydrogen fluoride and phosphoryl fluoride (POF3) (Check your NIOSH guide for exposure limits—they are low)

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“…the emission of toxic gases can be a larger threat than the heat…”

Link to OSHA Resources: https://www.osha.gov/sites/default/files/publications/shib011819.pdf

Who Regulates Lithium Batteries?

EPA: Infrastructure Grant work efforts and regulations EPA Slides 1-6: courtesy of Chris Newman, USEPA Region V

Fire Code: International fire code updates are being adopted around the US Slides courtesy of George Kerchner from The Battery Recycling Association

International Air Transport Association: LIBs are “dangerous goods”2022 Lithium Battery Guidance Document, covers: Intro to LIBs, packaging, training, air transport prohibitions and restrictions

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What Is The Infrastructure Law’s Battery Collection Best Practices Initiative?

1 C.N. EPA

How Will EPA Develop Best Practices?

• Synthesize input from governments, NGOs, and the private sector through feedback sessions and the Request for Information (RFI). (Complete)

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2 C.N. EPA

• Develop a draft report and provide opportunity for public comment.

• Submit the report to Congress by November 15, 2023.

What Is the Battery Labeling Guidelines Initiative?

• Labeling guidelines for end-of-life batteries – Voluntary

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• Communication materials for battery producers, consumers, and others on reuse and recycling of critical materials from batteries.

3 C.N. EPA

Resources

• Used Household Batteries | US EPA

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• Used Lithium-Ion Batteries | US EPA

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• Battery Collection Best Practices and Battery Labeling Guidelines | US EPA 🡨placeholder

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• Questions? Email
• Batteries@epa.gov (Batteries)

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4 C.N. EPA

More Resources

• An Analysis of Lithium-ion Battery Fires in Waste Management and Recycling

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• Workshop on Lithium-Ion Batteries in the Waste Stream | US EPA

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• Experimental study on thermal runaway and vented gases of lithium-ion cells:

https://www.sciencedirect.com/science/article/pii/S0957582020316360

5 C.N. EPA

EPA/RCRA Regulation of Used Batteries

Depending on their specific chemistry, used batteries can exhibit one or more of the characteristics of hazardous waste per 40 CFR part 261 Subpart C.

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Hazardous waste batteries may be regulated as “universal waste” per 40 CFR part 273.

Household and VSQG batteries are exempt from RCRA HW regulation.

States decide how batteries collected from HH and VSQG’s are regulated.

6 C.N. EPA

The NFPA has excellent resources on battery safety for consumers:

PDF on E-bike and E-scooter Safety; EV safety video

https://www.nfpa.org/standard_items/search_results?searchStr=e-bike%20safety

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International Association of Fire Chiefs (IAFC) https://www.iafc.org/home

Developing a Lith-ion Toolkit for responders; fire marshals; webinars/videos on fire fighting challenges related to LIBs

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Fire Prevention Resources

Fire Code

International Fire Code updated every 3 years:

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International adoption🡪 Countries 🡪 State adoption (can take 2 years)

PRBA: Rechargeable Battery Association and members: focus on regulatory, legislative and policy issues at the state, national and international level

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The International Code Council approved new lithium battery storage requirements to be incorporated into the 2024 IFC and IBC at its September 2021 Annual Conference.

Excellent Resources and links!

Battery Regulations & Safety | Rechargeable Battery Association (prba.org)

International Fire Code 2024

• 2021 IFC didn’t have many LIB storage related requirements.
• 2024 IFC has extensive storage requirements.

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New Section 321 in Chapter 3 of IFC dedicated to lithium batteries:

321.1 General (and list of exceptions)🡨 mainly related to new batteries/cells in original packaging or embedded in products.

321.2 Permits

321.3 Fire Safety Plan

321.4 Storage Requirements

321.4.1 Limited Indoor Storage in Containers

321.4.2 Indoor Storage Areas

321.4.3 Outdoor Storage

"Limited” Indoor Storage in Containers�(Retail/business accumulation)

Quantities may not exceed 15 cubic feet (~two 55-gallon drums)

• No permit required
• Requires fire safety plan

Containers

• Must be open-top and noncombustible (metal not plastic) or approved for battery collection (C2R collection boxes)
• Each container and groups of containers may not exceed 7.5 cubic feet
• Second container or group of containers must be separated by not less than 3 feet of open space, or 10 feet of space that contains combustible materials
• Must be located not less than 5 feet from exits or exit access doors

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Slides are from a PRBA presentation posted online; notes in blue added by JVolkman

Indoor Storage Areas Not Meeting “Limited” Storage Requirements

Applies to indoor storage with more than 15 cubic feet of lithium batteries:

1. Must secure permit and have fire safety plan

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• Technical opinion and report must be prepared to evaluate level of hazard and protection measures

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Question: are battery embedded devices included?

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Applies to any collector who routinely has more than 2 drums of lithium batteries on site: HHW, Recycle centers

Indoor Storage Areas Not Meeting “Limited” Storage Requirements

3. Construction requirements. Battery storage areas must be separated by 2-hour rated fire barriers or horizontal assemblies
• Exceptions:
• Prefabricated portable structure building with 2-hour rated fire-resistance rated enclosure
• If battery storage is limited to new batteries in packaging that has been demonstrated to and approved by fire code official as sufficient to isolate a fire in packaging

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Indoor Storage Areas Not Meeting “Limited” Storage Requirements

4. Fire Protection System. Must be protected with automatic sprinkler system or approved alternative suppression system

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• Fire Alarm System. Must be protected with fire detection system fire using air aspirating smoke detection, radiant energy-sensing fire detection, or both

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• Explosion Control. If applicable, and in accordance with technical report

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Indoor Storage Areas Not Meeting “Limited” Storage Requirements�

7. Section 321.4.2.6 provides “reduced requirements” if batteries are stored at no more than 30% state of charge
1. Technical report NOT required
2. 2-hour rated fire barriers NOT required
3. Must have procedure to verify SOC
4. Fire sprinkler system IS required
5. Fire detection system IS required

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OUTDOOR STORAGE AREAS: Fire Code

Establishes set back distances for outdoor storage cabinets and areas:

• >20 feet to buildings, property lines and streets
• 3 feet to buildings, property lines and streets if stored in either a free-standing assembly or a portable pre-fab building with a 2-hour fire resistant rating.
• Fire detection system is required.

Storage Area and Size Limits:

• >10 feet in height
• >900 sq. ft. in size
• Multiple storage areas must be separated by 10 feet

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Department of Energy: non-regulatory

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DOE: providing grants to increase the US’s capacity to recycle and reuse batteries in the US to bring us closer to energy and material independence. Check their website for information.

Albert L. Lipson is a materials research scientist at the Materials Engineering Research Facility at Argonne National Laboratory, working on the coprecipitation synthesis of high energy density Li-ion battery cathode materials. He is now part of the ReCell center focused on Li-ion battery recycling working on electrolyte extraction and recovery, thermal binder removal and making graphene from spent anode.

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Noah B. Schorr is a Senior Member of the Technical Staff at Sandia National Laboratories in the Power Sources R&D organization. His work focuses on the characterization and development of new battery materials for grid storage and national security. Since 2016 Noah has served as an author on over 20 peer reviewed journal articles covering topics including Li-ion, Li primary, redox flow, and Zn alkaline batteries. 

General safety and battery health

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• Monitor battery charge status while charging
• Use the charger designed for the device
• Avoid exposing Li-Ion batteries to excessive vibration
• Do not keep batteries in high or low temperatures -4° to +113°F 
• Keep them dry
• Ventilate storage
• Do not use damaged batteries
• In case of contact with fluid do not rub eyes. Immediately flush eyes at an eyewash station
• Wash hands after handling batteries

Lithium battery fire suppression

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Example products are visual aids, not endorsements

Heat resistant gloves and tongs

Smothering pads and blankets—quicker/better than a Class D

Fire suppressant packing materials like CellBlockEX

Class D Fire extinguishers—will not put out a high energy battery fire, but may give additional “escape” time

Store batteries away from flammables

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Have a plan and equipment

$5,000-$12,000

$600-1,500

$650-$800

If a LIB fire is larger than your hand, get staff out and call 911