Lithium Battery Storage Regulations: Understanding PGS 37-2
In today's rapidly evolving energy landscape, the safe storage and handling of lithium-bearing energy carriers have become increasingly crucial. Whether you're managing a warehouse, running a logistics operation, or overseeing a facility that uses lithium-ion batteries, understanding and complying with PGS 37-2 is essential for your business's safety and legal compliance.
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What is PGS 37-2?
PGS 37-2 is a regulation for the safe storage of lithium-bearing energy carriers. It is a guideline that outlines safe storage practices, including the charging and discharging of lithium-ion batteries, lithium metal batteries, and hybrid lithium batteries. If you would like to learn more about shipping of lithium batteries, we wrote this guide about just that.
How do I know if I have lithium batteries or accumulators in my storage facility?
PGS 37-2 applies to the storage of various types of lithium-bearing energy carriers, often identified by specific UN codes from the ADR (the European Agreement concerning the International Carriage of Dangerous Goods by Road).
These include:
- Lithium-ion batteries
- Lithium metal batteries
- Lithium batteries incorporated into devices (e.g., hoverboards, electric vehicles)
- Hybrid lithium batteries
Check the labels and documentation of the energy carriers in your facility to determine if these UN codes apply. If they do, PGS 37-2 is relevant to your operations.
Energy Source Handling Guide
1. Is the energy source without a device?
Who does PGS 37-2 apply to?
PGS 37-2 applies to anyone involved in the storage, charging, or discharging of lithium-bearing energy carriers, including:
- Warehouse and facility managers
- Logistics providers
- Retailers who store energy carriers (e.g., showrooms, shops)
- Companies that use lithium-bearing energy carriers in their products or processes
- Recycling and waste management companies handling end-of-life energy carriers
How does PGS 37-2 work?
PGS 37-2 takes a risk-based approach to ensuring safe storage practices. Here's a simplified overview:
- Identify the Risks: The guideline outlines potential hazards related to lithium-bearing energy carrier storage, such as fire, explosion, and the release of toxic substances.
- Categorize Energy Carriers: Energy carriers are grouped into different "typicals" based on factors like their type (lithium-ion, lithium metal, hybrid), status (new, used, damaged, refurbished), and the intended use (product reuse, material recycling). Different typicals have different storage requirements.
- Implement Measures: PGS 37-2 specifies a range of measures to mitigate identified risks, including:
- Storage conditions: Temperature control, ventilation, weather protection, segregation from incompatible materials
- Handling procedures: Ingress control, monitoring, emergency procedures
- Infrastructure requirements: Fire safety measures, emergency exits, signage
What are the specific requirements outlined in PGS 37-2?
PGS 37-2 provides detailed requirements for numerous aspects of lithium-bearing energy carrier storage. Here are some key areas the guideline covers:
- Storage Limits: The maximum permitted quantities of energy carriers that can be stored in different types of facilities are defined.
- Infrastructure and Construction: PGS 37-2 specifies requirements for building materials, fire resistance ratings, compartmentalization, ventilation, and lightning protection systems.
- Handling and Procedures: Detailed guidelines for handling, storage, charging, and discharging procedures are given, emphasizing safety and risk mitigation. There are specific rules for damaged or unstable energy carriers.
- Monitoring and Control: The guideline mandates regular inspection of energy carriers and storage conditions, recording relevant data, and developing internal emergency response plans.
- Staff Training and Competency: PGS 37-2 emphasizes the need for adequate training and competency of personnel handling lithium-bearing energy carriers.
Are there any exemptions from PGS 37-2?
Yes, PGS 37-2 specifically excludes certain scenarios from its scope. These include:
- Energy Storage Systems (ESSs) containing lithium-bearing energy carriers. These are covered under PGS 37-1. However, the storage of ESSs themselves still falls within the scope of PGS 37-2.
- The temporary storage of packaged lithium-bearing energy carriers that are kept outside of a regular storage facility prior to or after transport. This applies to packaged dangerous goods in unopened, UN-approved packaging that are clearly addressed to third parties and have a maximum storage duration of 48 hours. For lithium-bearing energy carriers received for use or storage within a company, they must be transferred to a suitable storage facility in accordance with PGS 37-2 within a reasonable timeframe (maximum of 12 hours). The maximum weight per loading/unloading point (docking station) is limited to 25,000 kg, with a maximum of four loading/unloading points. Between loading/unloading points containing lithium-bearing energy carriers, there must be a loading/unloading point without lithium-bearing energy carriers.
- Work stock consisting of more than one packaging unit, where it is permitted to store a work stock for the current workday plus one reserve packaging unit outside of a designated storage facility. For collection points handling returned energy carriers, the work stock is limited to a maximum of one in-use UN-approved collection container and one full UN-approved collection container.
- Unintentionally acquired lithium-bearing energy carriers in the waste stream at municipal waste facilities (hidden in household waste) or recycling and waste sorting companies (hidden in commercial or demolition waste). This guideline focuses on the active storage of lithium-bearing energy carriers that have been intentionally delivered to a processor.
- Vehicles, equipment, and two-wheelers containing lithium-bearing energy carriers that are being worked on, for example, for repair or modification, or are offered for that purpose. However, storage of vehicles, equipment, and two-wheelers for longer than a week in a fire compartment (shed or warehouse) that is not accessible to the public and is not being worked on, falls within the scope of this guideline if the limits specified in Table 2 (333 kg or 1,000 kg) are exceeded.
- Vehicles, equipment, and two-wheelers containing lithium-bearing energy carriers that are being rented out. However, if these vehicles, equipment, and two-wheelers are not actively being rented (for example, due to seasonal rental) and the limits specified in Table 2 (333 kg or 1,000 kg) are exceeded, then PGS 37-2 does apply.
- Charging (large quantities) of energy carriers for vehicles, equipment, and two-wheelers (e.g. electric bicycles or scooters for meal delivery services or shared scooter companies) that are in active use, when the energy carrier is charged inside the device.
Additionally, the guideline allows for the use of equivalent measures in certain circumstances. This means alternative approaches can be used if they achieve the same level of safety as the measures prescribed in PGS 37-2. However, equivalent measures must be justified and documented, and the responsible authority must approve them.