Finding an Independent Third Party
Battery Test Lab
Battery Power 2013
Denver, CO (06 June, 2013)
Tom O’Hara, Global Business Manager / Advisory Services
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Global Presence – Energy Storage
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USA
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Detroit, MI
Grand Rapids, MI
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San Antonio, TX
EMEA
Kaufbeuren, Germany
Leatherhead, UK
Kista, Sweden
APAC
Shanghai
Global Centers of Excellence
Taipei
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Introduction
So, you need an Independent, third party
Battery Test Lab…
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Introduction
WHY?
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Reasons for Third Party Testing
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Safety
Performance
Developing Specification Limits
Litigation
Opportunity Evaluations (the “O” in SWOT)
• Simple need for additional test resources
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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)
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Reasons for Third Party Testing - Performance
• Substantiation of Market Claims (New Product Launch)
• Validation of In-House Test Capabilities
• Generation of Investor Interest
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Reasons for Third Party Testing – Spec Limits
• Development of Cell/Battery Specification
• Application Specifications (user based)
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Reasons for Third Party Testing – Litigation
• Litigation of Performance / Market Claims
• Litigation of Accident / Failure
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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
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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
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Selecting a Third Party Test Lab
When selecting an Independent,
third party Battery Test Lab…
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Selecting a Third Party Test Lab
When selecting an Independent,
third party Battery Test Lab…
What should you look for?
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Selecting a Third Party Test Lab
Depends On Your Need!
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Selecting a Third Party Test Lab
Will any third party lab suffice?
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Selecting a Third Party Test Lab
Will any third party lab suffice?
Do you need ISO/IEC 17025 accreditation?
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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.
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Selecting a Third Party Test Lab
Do you require more?
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Selecting a Third Party Test Lab
Do you require more?
An NRTL?
(Nationally Recognized Test Lab)
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The Role of a Nationally Recognized
Testing Laboratory (NRTL)
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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)
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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
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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
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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
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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.
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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NRTL Primer
Where can I view the current list of NRTLs?
• www.osha.gov/dts/otpca/nrtl/index.html
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NRTL Primer
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Selecting a Third Party Test Lab
Other Considerations?
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Selecting a Third Party Test Lab
Points of Distinction Among Test Labs:
• Equipment Capabilities
(Safety/Performance/Analytical)
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Test Lab Capacity
Location
Technical Depth, Staff Experience
Other Key Purchasing Drivers…
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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.
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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.
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Thank You
Questions?
Tom O’Hara
Global Business Manager / Advisory Services
Energy Storage, Intertek
[email protected]
www.intertek.com/energy-storage
Direct: +1 440 570 6288
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Valued Quality. Delivered.
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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
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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
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