Fuel Cells/Micro/Regulatory Micro 051005
From the Fuel Cells 2005 Conference (June 2005)...
Regulatory Requirements for Micro Fuel Cells
by Donald Georgi
As fuel cells trudge the tortuous path to success, focus has been on two major concerns - cost and reliability. The units must be robust for long life, yet economical enough to compete with alternate technologies. An additional consideration was brought up by Jack Paterson at the Fuel Cell 2005 meeting in Minneapolis - regulatory requirements. Regulatory requirements for micro fuel cells interlock with technical progress, in that international safety and global standards and regulations must be defined and agreed upon prior to implementation.
The following report highlights information from the Paterson presentation, along with salient points which expand the status of DMFC standards and regulations.
Consideration of regulatory requirements for DMFC (Direct Methanol Fuel Cells) micro fuel cells in some ways is as formidable as the technical challenges, in that methanol’s fire safety and poisonous ingestion concerns complicate regulatory implementations. These concerns must be addressed from a global viewpoint. Within these geographical concerns, there are separate concerns for the manufacture, distribution and utilization of methanol. Tying all these interlocking requirements into a technology which meets safety requirements, is economical to produce and deliver, and maintains convenience is as necessary as building an affordable and rugged fuel cell.
Mr. Paterson noted that new technologies can fail in the commercialization phase if insufficient attention is paid to the concerns for regulatory safety and standards during the R & D phase. We can look back to the problems of drugs such as thalidomide in the 1950s as an example of a safety failure in the commercialization phase. Strangely, the potential safety problems of Lithium-ion batteries were contained by high standards by Sony Corporation as it released product in the 1990’s without detailed regulatory support. Despite nuisance problems and manufacturing ‘shortcuts,’ leading to numerous recalls as additional manufacturers produced the rechargeables, public acceptance has made Lithium-ion the standard of high-energy-density rechargeable power.
Methanol fuel, a separate yet integral concern
The field of DMFCs is populated by many potential manufacturers, and since the methanol is a replaceable fuel, it finds a place as an adjunct player in the technology. After the fuel cell is built, the supply of methanol cartridges may be produced by multiple third party global manufacturers.
Since methanol is already recognized for its flammable and poisonous properties, it has boundaries placed by the U.S. Consumer Product Safety Commission (CSPC). Household products containing more than a 4% concentration of methanol must be packaged in child resistant containers. In May of 2005, the CSPC identified a mislabeled Radio Shack cleaning solution containing methanol for recall. One and one half million dollars in penalties were assessed by the CSPC against Rain -X glass cleaner for having a hazardous (6%) solution of methanol in a container without proper safety packaging.
A fundamental purpose of the quest for alternative fuels and fuel cells is environmental air quality. The fuel cell by itself is a very supportive component to achieve cleaner air. Not only does the higher efficiency contribute to smaller emissions problems, but the fuel source also helps reduce emissions. Adding DMFCs will contribute to the cleaner air, but the complication of regulations coordinated with city, state, national and international governments must be in place before the fuel cells arrive.
There is not a blank check for fuels which power fuel cells. After the fuel is found technically viable for use in the fuel cell, the suitability for its manufacture, distribution and use falls into the realm of regulations and standards. One of the big constraints for the implementation of DMFCs is the time when they will be approved for use in airplane cabins. The methanol is already approved for storage in aircraft baggage compartments and 2007 is the anticipated time of approval for cabin use.
There also has to be some economy of production, delivery and use. In the case of methanol for portable electronics, the choice of disposable cartridges addresses both the child safety and convenience aspects. While pricing can be controlled, the variety of sizes will reduce production volumes, adding to cost and thereby price. Disposable cartridges are inherently more expensive than refillable containers. Even the concern for disposing of a partially filled cartridge must be fully defined.
In addition, there is the marketing aspect. By tightly controlling the proprietary configuration of ink refills, printer companies have been able to hold customers hostage with expensive replacement cartridges which contain only a few cents worth of ink. The difference between the printer market and the fuel cell market is that printers can be built dirt cheap and almost given away to create the immense aftermarket for high margin ink cartridges. Fuel cells in the foreseeable future are not going to be inexpensive enough to be ‘given away.’ Another marketing model is the ‘razor blade’ which supplies the income stream, allowing razor holders to be sold at rock bottom prices.
One alternative which has been relativly unsuccessful allows the consumer to refill his/her own ink cartridge. Unfortunately; replacement ink recipies are not suitable, leading to printer clogging. However, the possibility of creating ways to refill methanol cartridges by users may be easier since the big requirement may be for high concentration methanol. Again, that scenario must have specifications and standards .
Dangerous Goods Issues
Since methanol is already recognized as having health and safety concerns, the problems of its treatment as a hazardous material already is in place. Once the fuel cells and methanol containers are defined, there are special concerns about transportation to address. It is one thing to ship a methanol cartridge, and it is another thing to ship a methanol cartridge integral with electronics which can produce sparks.
Shipping is also relative. One method of shipping is to place many methanol containers in a big box; a different scenario is having multiple cartridges in a traveler’s briefcase.
Regulatory and Standards Organizations
Mobile PC Extended Battery Life Working Group: This group includes Intel and STMicroelectronics. It has issued a document detailing the requirements a fuel cell would need to power a mobile PC which is intended to speed the development of longer lasting fuel cell power sources for notebooks and other mobile computers. The guidelines cover size and power issues as well as electrical, mechanical , control, thermal, environmental and regulatory aspects of fuel cell designs in both internal and external configurations. See www.elblwg.org/index.asp.
Within the U.S., Underwriters Laboratories (UL)(www.ul.com) has been building a standard titled “Hand Held or Hand Transportable Fuel Cell Power Unit With Fuel Containers.” It carries the designation UL Subject 2265 and includes compressed hydrogen, formic acid, butane and hydrides. There is also a 2265A investigative standard which focuses on DFMF micro devices. UL is primarily focused on safety in all its work. UL standards are voluntary but form a basis for non-compliant legal assault in cases of damage or injury. UL coordinates with the Canadian Standards Association (CSA) and the American National Standards Institute (ANSI) to develop a combined standard ‘ANSI/UL 2265/CSA America FC’.
The International Electrotechnical Commission (IEC) (www.iec.ch) initiated a document TC 105 in 2002 which addresses standards for safety, performance and intechangeability. Contributions from the fuel cell industry and UL will hopefully provide global standardization for requirements.
The Consumer Product Safety Commission, as previously mentioned, has experience in regulating methanol products and will continue to apply existing requirements and potentially new requirements for DMFCs where the unique features of DMFCs require such attention. CPSC standards are mandatory.
The United Nations transportation agencies have their UN Committee of Experts on the Transport of Dangerous Goods (UNTDG). Enacted in 2004, it addresses “fuel cell cartridges containing flammable liquids” for methanol cartridges (UN 3473, Class 3 Packaging instruction P003). It is used for addressing vessel, aircraft plus European road and rail cargo packaging instructions. There is also a UN 3363 ‘Dangerous Goods In Machinery or Apparatus’ document which is appropriate for cargo shipment of fuel cell-powered electronic products containing fuel. (See www.unece.org/trans/danger/danger.htm)
The International Civil Aviation Organization (ICAO) (http://icao.int/ ) has been presented with a briefing by the U. S. Department of Transportation on methanol fuel cells and cartridges recommending allowance for use by airline passengers. The U. S. and Japan are likely to review issues of aircraft cargo shipments and passenger use with the ICAO.
An interesting component of global standards is that requirements can escalate. If there is a UN standard for using a DMFC in an aircraft passenger compartment, the Federal Aviation Administration (FAA) can impose an even greater requirement, and of course, for a ship or airplane, ultimate regulation is applied by the captain or pilot in command since he/she is responsible for the safety of the passengers. To minimize confusion, interconnection of all codes and standards would be ideal.
Of major concern at the local level is waste management. The Environmental Protection Agency (www.epa.gov), the Rochester Institute of Technology and the U. S. Fuel Cell Consortium are completing a study on micro fuel cell waste management which addresses solid vs. hazardous waste, recycling and product life cycle logistics options.
Special combinations or variations of regulations and standards will develop as utilization begins. For example, medical applications will require concerns for patient safety and utilization in environments from hospital operating rooms to public transportation. In the past, UL and IEC have accommodated these special concerns, and it is reasonable to assume that from their base of experience they will continue to do so with new DMFC products. There will also be definitive standards by military organizations both for global concerns and product specific applications.
For specific legal interpretations in the field of DMFC regulations and standards, contact the Office of John A. Paterson, Attorney; e-mail: [email protected].
For the evolving status of DMFC regulations and standards, contact the organizations mentioned in this article.