UNITED NATIONS - DOC 8 by US8mod

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									UNITED
NATIONS                                                                                            ST
                                                                        Distr.
                                                                        GENERAL

                                                                        18-20 May 2010
                                                                        Original: ENGLISH


Lithium Battery Informal Working Group
Washington, DC
18-20 May 2010


                                      Definition of Component Cell

                      Transmitted by PRBA – The Rechargeable Battery Association


1. At the last working group meeting in Kyoto, there were discussions regarding the definition of
“Component cell” in the UN Manual of Tests and Criteria, the reason for including the definition in the
UN Manual, and Component cell testing requirements.

2. Based on recent discussions with industry representatives and testing labs, Component cells are
generally recognized as cells that are placed directly into battery packs after coming off the production
line. That is, the cells are never shipped as individual cells but rather only as “components” of a battery
pack.

3. Under the scenario described in paragraph 2, the Component cells are not subject to the full set of UN
tests. Instead, the UN Manual requires that Component cells be subject only to the T.6 Impact test. The
battery pack containing the Component cells is subject to the full set of UN testing requirements.

4. PRBA does not believe it was ever the intention of the UN Manual to require test labs to remove UN
tested cells from battery packs and subject them to the T.6 UN test as Component cells. However, we
understand how this interpretation could be made based on the existing definition of Component cell.

5. In order to clarify the issue, PRBA is proposing a minor amendment to the definition of Component
cell.

PROPOSAL

Component cell means a cell contained in a battery that has not been subjected to the test requirements.




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