Finding an Independent Third Party Battery Test Lab Battery Power 2013 Denver, CO (06 June, 2013) Tom O Hara, Global Business Manager / Advisory Services 1
Global Presence Energy Storage v USA Detroit, MI Grand Rapids, MI v v v v v v San Antonio, TX EMEA Kaufbeuren, Germany Leatherhead, UK Kista, Sweden APAC Shanghai Taipei Global Centers of Excellence 2
Introduction So, you need an Independent, third party Battery Test Lab 3
Introduction WHY? 4
Reasons for Third Party Testing Safety Performance Developing Specification Limits Litigation Opportunity Evaluations (the O in SWOT) Simple need for additional test resources 5
Reasons for Third Party Testing - Safety Transportation Requirements for Lithium Batteries (UN/DOT 38.3; IEC 62281) Sales/Marketing, Customer Driven (UL / IEC / SAE / JIS, etc.) Brand Protection, Improve Product Robustness (MEOST / HALT / HASS to understand failure modes) 6
Reasons for Third Party Testing - Performance Substantiation of Market Claims (New Product Launch) Validation of In-House Test Capabilities Generation of Investor Interest 7
Reasons for Third Party Testing Spec Limits Development of Cell/Battery Specification Application Specifications (user based) 8
Reasons for Third Party Testing Litigation Litigation of Performance / Market Claims Litigation of Accident / Failure 9
Reasons for Third Party Testing Opportunity The O in SWOT Start-up Enterprise looking for New Funding Evaluating and Quantifying Opportunities Validating Claims made to Investment Community 10
Reasons for Third Party Testing Simple Need Simple need for additional test resources Avoidance of Capital Investment Time / Resource Limitations (test in parallel versus sequential) Supplementing Internal Expertise 11
Selecting a Third Party Test Lab When selecting an Independent, third party Battery Test Lab 12
Selecting a Third Party Test Lab When selecting an Independent, third party Battery Test Lab What should you look for? 13
Selecting a Third Party Test Lab Depends On Your Need! 14
Selecting a Third Party Test Lab Will any third party lab suffice? 15
Selecting a Third Party Test Lab Will any third party lab suffice? Do you need ISO/IEC 17025 accreditation? 16
Selecting a Third Party Test Lab ISO/IEC 17025 Accreditation ISO/IEC 17025 is the internationally-recognized quality management system standard for laboratory accreditation ISO/IEC 17025 includes both Management Requirements, and Technical Requirements. ISO/IEC 17025 accreditation is often a customer or client requirement. Note: A2LA is an organization which provides ISO/IEC 17025 accreditation, it is not in itself an accreditation. 17
Selecting a Third Party Test Lab Do you require more? 18
Selecting a Third Party Test Lab Do you require more? An NRTL? (Nationally Recognized Test Lab) 19
The Role of a Nationally Recognized Testing Laboratory (NRTL) 20
NRTL Primer Independent bodies recognized for their competency in electrical testing and certification are generally known in the US as Nationally Recognized Testing Laboratories (NRTL) Lab, Listed, Mark, Label Approved by who??? OSHA (U.S. Department of Labor: Occupational Safety & Health Administration) oversees safety regulations, which are US law and contain requirements for "approval" (i.e., testing and certification) of certain products by a NRTL Requirements are found in Title 29 of the Code of Federal Regulations (29 CFR), and the provisions for NRTL certification are generally in Part 1910 (29 CFR Part 1910) 21
NRTL Primer An NRTL is an organization that OSHA has "recognized" A NRTL is authorized to provide an independent evaluation, testing and certification of electrically operated or gas- and oil-fired products based on standards developed by U.S.-consensus standards organizations such as the American National Standards Institute (ANSI) and Underwriters Laboratories (UL) Recognition includes demonstrating to OSHA the capability, control programs, independence, reporting and complaint handling procedures to test and certify specific types of products for workplace safety 22
NRTL Primer What process does OSHA follow in recognizing an NRTL? Appendix A to 29 CFR 1910.7 OSHA performs an in-depth on-site review of the organization and facilities OSHA publishes a notice of finding in the Federal Register for 30 day public comment period OSHA publishes a second notice of its final decision The recognition remains in effect for a five-year period For foreign-based organizations, the Department of Commerce must consider "reciprocity" of the foreign government 23
NRTL Primer How does OSHA enforce the requirements for NRTL approval? Typically audit each NRTL annually to verify that it sustains the quality of its operation and continues to meet program requirements OSHA compliance officers could review specific products during workplace inspections, verifying the certification mark of an NRTL 24
NRTL Primer What standards can an NRTL use in certifying products? An NRTL must use "appropriate" standards in certifying products for workplace safety (see Test Standard Approval Criteria in the NRTL Program Directive) International Electro-technical Commission (IEC), Underwriters Laboratories (UL), the National Fire Protection Association (NFPA), IEEE, and ASTM International, etc. 25
NRTL Primer Does OSHA accept the "CE Mark, or equipment certified by foreign testing organizations? The CE mark is a generic mark used in the European Union (EU) to indicate that a manufacturer has declared that the product meets EU safety requirements CE is unrelated to the requirements in the US In the US, the product must have the specific mark of a recognized NRTL However, data used to attain NRTL certification, may be applicable to declaration of compliance for CE marking 26
NRTL Primer Can an NRTL use other parties to do part of the work necessary in testing and certifying products? OSHA permits this, provided the NRTL has met certain criteria With appropriate controls in place, a NRTL may accept testing, evaluation data or certain contract services, from outside parties 27
NRTL Primer Do NRTLs recognize each other s product testing, certification, or approvals? OSHA has no authority to require such acceptance This is solely a business decision of each NRTL 28
NRTL Primer Does OSHA subsidize or indemnify NRTLs? NRTLs are private organizations or companies They are not financially or otherwise supported, subsidized, or indemnified by the Government in their capacity as an NRTL These organizations maintain the risks and liabilities for their actions 29
NRTL Primer Are OSHA recognized NRTLs equal in ability? Given that each NRTL has met the same requirements for recognition, OSHA considers NRTLs, recognized for the same product safety test standard, to be equivalent However, each NRTL is an independent business and will operate as such. They may provide different levels of service, costs, ongoing support, etc. 30
NRTL Primer How do I know whether an NRTL has certified a product? Each NRTL uses its own unique, registered certification mark(s) to designate conformance Each NRTL must register its certification mark(s) w/the US Patent & Trademark Office The manufacturer physically places the mark on the products An NRTL must ensure that its mark is applied to each unit, or if not feasible, to the smallest package containing each unit 31
NRTL Primer What does a safety mark tell me? Safety marks such as ETL, UL, and CSA signify that the product has been tested to, and found to comply with, national safety standards by a qualified, independent testing laboratory The presence of a safety mark also means the product is listed in the NRTL s directory public record. And, is part of an on-going follow-up program that ensures the products continued comply with the applicable standards 32
NRTL Primer What's the difference between the UL, CSA, and ETL marks? All of these Marks demonstrate that the product that bears it has met the minimum requirements of widely accepted product safety standards as determined through the independent testing The only real differences between the Marks are in the services of the testing laboratory behind them 33
NRTL Primer Aren't manufacturers required to use UL for their compliance testing? Isn't this mandated by the standards themselves? The simple answer to both questions is "no" In fact, this misconception has misled many manufacturers to believe that they don't have a choice in their third-party testing partner To satisfy the prerequisite of having your products tested by an independent organization, the true legal requirement is that the laboratory which performs the testing be a Nationally Recognized Testing Laboratory (NRTL) recognized by OSHA 34
NRTL Primer Where can I view the current list of NRTLs? www.osha.gov/dts/otpca/nrtl/index.html 35
NRTL Primer 36
Selecting a Third Party Test Lab Other Considerations? 37
Selecting a Third Party Test Lab Points of Distinction Among Test Labs: Equipment Capabilities (Safety/Performance/Analytical) Test Lab Capacity Location Technical Depth, Staff Experience Other Key Purchasing Drivers 38
Conclusions and Recommendations CONCLUSIONS: In general, test labs are common enough and you should have no problem finding one capable of providing your needs. However There are a few published battery tests which require unique test facilities which are beyond most commercial test lab capabilities. Still, even with these extreme test specifications, if a test exists in some standard or guideline, there will be at least 1-2 test lab options available to you. 39
Conclusions and Recommendations RECOMMENDATIONS: At the very least, Intertek recommends that your test lab of choice be ISO/IEC 17025 accredited. If product/component Certification, Listing or Recognition is required, you must use an NRTL. 40
Thank You Questions? Tom O Hara Global Business Manager / Advisory Services Energy Storage, Intertek tom.ohara@intertek.com /energy-storage Direct: +1 440 570 6288 41
Valued Quality. Delivered. 42
Why Intertek? Experienced Team 200+ years of collective experience and academic advanced degrees in the field of battery technology and applied electrochemistry Combination of advisory and testing experience World-Class Test Facilities Unique scope and breadth of testing capabilities We assess over 20,000 batteries each year, covering all chemistries and sizes Independently accredited laboratories Global reputation recognized for uncompromised independence and wellfounded advice the Sagentia Catella brand Global Network contacts in the battery industry and among leading research institutions 43