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Fuel Cells/Micro/Regulatory Micro 051005
From the Fuel Cells 2005 Conference (June 2005)...
Regulatory Requirements for Micro Fuel Cells
by Donald Georgi
The assembly consists of a portable radio frequency identification reader built by Intermec Technologies shown in the top horizontal position. It is powered by an MTI Micro Direct Methanol Fuel Cell (DMFC) located below the reader on the left. A hand holding frame integrates the reader and fuel cell. In the lower right foreground is an MTI Micro  methanol refill cartridge. MIT Micro’s proprietary DMFC MobionTM technology uses up to a 100% concentration of methanol fuel to maximize system energy density. The internal pump driver, control logic and a DC/DC converter are designed to minimize complexity and minimize size. The MobionTM technology has been applied to a prototype powerpack for a military radio (BA5590). Photo reprint permission is from MTI Micro with special assistance from Angelia Rossi. +

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.

Microsoft Excel ChartAccording to the research firm, NanoMarkets, LC, penetration of DMFCs into the traditional and new battery-powered markets is about to become significant in this decade. (See the above chart with data from the Sept. 15, 2005 story, “Fuel cells expected to be a $ 1.6 billion business by 2010,” Businesses interested in the market include 3M, Cabot, Cascio, Fujitsu, Hitachi, Johnson Matthey, Motorola, NEC Samsung, Sanyo, Sony and Toshiba  +

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.

Why is the DMFC Positioned for Rollout?

DMFC may be the first type of fuel cell to be commercially successful. Anyone who would be asked if they would like a 20 hour direct replacement for their notebook computer would eagerly say, “yes,” assuming the offer was made at no additional cost.

The demand side of the equation is in place, but the auto and stationary power markets would also like the cleaner fuels and higher efficiency of fuel cells. Why does the DMFC have this opportunity to be the initial fuel cell entry into the market?

First, the DMFC is targeted to the portable electronic industry which agonizingly needs longer run times. This market has conditioned consumers pay big bucks for computers, PDAs and cellphones with Lithium-ion batteries carrying high price tags for replacement. So the high cost of  market components eases the DMFC introduction at an equally high price.

Second, the technology is simple. Using methanol without a reformer means lower cost and smaller size required in cellphones and PDAs. The portable application does not need the longevity which an auto or stationary fuel cell would require. For a computer, people have grudgingly accepted software, hardware and batteries going south in months or a couple of years. If the DMFC can be modular enough to be a unit the customer can replace yearly, he/she may forgive the nuisance replacement because of the longer run time.

Third, the fuel itself has numerous attributes. While methanol is poisonous and flammable, it has better energy density than compressed hydrogen, and if properly handled, it is convenient and reasonably safe. Methanol is also not new. Users know what it looks like and the fuel can be easily carried  as a room temperature liquid. The protectiveness of regulatory and standards organizations only further enhances the possibility for success of DMFCs.

Today, methanol is commonly produced from natural gas, which at the beginning of 2005  was priced  at $5.53 MMBTUs. On the 28th of September 2005, it was selling for over $ 13. Certainly, natural gas costs are not going to ease, but methanol can also be produced from coal and biomass, so as the price of natural gas spikes, other processes may become more competitive.

All these features have spurred DMFC R&D globally by governments and businesses. As methanol becomes the ‘pot of gold’, large efforts attempt to reduce the  time to market.  DKG

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

Within the U.S., Underwriters Laboratories (UL)( 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) ( 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

Microsoft Excel ChartSupporting the argument for DMFC capabilities is the above  data from Research and Markets ( forecasting the dollar amounts of cells to be sold within the next eight years. Although significantly different than the previously presented NanoMarket 2008 data, it should be noticed that these are ‘best guesses’. Both projections do indicate that the markets begin to exist in the next two to three years and that alone is a major step up for an industry which has been fraught with ‘next-year-for-sure’ promises which have not come to fruition in the past. +

The International Civil Aviation Organization (ICAO) ( ) 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 (, 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.
Why Methanol?

All fuel cells need hydrogen as a fuel, but pure hydrogen gas has little volumetric energy density (405 Wh/l @ 150 Bar) compared to gasoline and methanol. Liquid hydrogen at -423 0F has about 6 times less energy density (2,600 Wh/l) than a gallon of gasoline (9,700 Wh/l). There is actually more  hydrogen in a gallon of gasoline than in a gallon of liquid hydrogen. Methanol is in-between gas and hydrogen with 4,600 Wh/l.

Convenience is another factor. A stationary fuel cell fed by pipeline gaseous hydrogen would have convenience comparable to household natural gas. But transferring hydrogen repeatedly in a pressurized automobile application is complicated by gas tight transfer connectors, not easily accommodated by a consumer with a handful of thumbs.

Refillable compressed hydrogen would not work well with a micro fuel cell in a consumer environment such as offices homes and airplane cabins. Unless a simplified disposable cartridge is used, messy or difficult refueling limits the acceptability of direct hydrogen as a fuel.

The simple and convenient fuel solution for micro fuel cells is  a liquid fuel such as methanol with high hydrogen content and with the ability to operate without front end reformation which would add cost and complexity, reducing reliability.

NASA/Cal Tech Jet Propulsion Laboratory and the University of Southern California  invented and developed the direct methanol fuel cell (DMFC) which accepts methanol at the platinized carbon anode electrode. The methanol is oxidized to produce electrons for the external circuit.  Carbon and oxygen from the methanol form carbon dioxide which is vented. Anode protons conduct through the polymer electrolyte membrane (PEM) to the cathode where they are reduced with externally returning electrons and oxygen from the air to form water.

Although ethanol’s higher volumetric energy density (6,100 Wh/l) is greater than methanol’s (4,600 Wh/l), the technical results of fuel cell progress heavily favor DMFCs since current ethanol fuel cells add  cost and size as well as complexity of the reformer.

But there are still technical concerns. Methanol is extremely flammable, producing a bluish flame with a flash  point of 11 0C. It  boils at 64.7 0C. It has an agreeable odor and burning taste so that it has often been used to replace ethanol in moonshine, resulting in permanent blindness. Ingested in a single dose, Kavet (1990) reported that 0.85 to 2.85 oz. of methanol could cause the death of a 154 pound human. Repeated exposure by breathing or skin contact can produce a number of illnesses including behavioral disturbances and heart disease. Methanol is used in the production of antifreeze, fomaldehyde, solvents and  the gasoline additive MTBE used to reduce photochemical smog. MTBE has been found to be a carcinogen.

Even with many challenges, methanol is the choice for micro fuel cells. Many companies and organizations are working to produce a
Net Zero or Net Negative ?

Cute little junior is the apple of Mom’s eye. After really ‘mudding it up,’ outside, he goes to the bathroom and cleans up. When Mom sees him, she is so overjoyed at his clean appearance that she gives him a big hug and a kiss. Little does she know that in the next ten minutes she will discover the bathroom covered with mud from stem to stern.

Clean transportation can be a similar experience. The fuel cell auto zips down the road, powered by pure hydrogen leaving only clean water in its wake. Media kudos abound! However, a less publicized fact is that if the hydrogen was drawn from a fossil fuel energy source such as coal, oil or natural gas,  the total carbon dioxide and carbon monoxide in the earth’s atmosphere would increase. One might say that the net environmental improvement would be negative. (There are now more carbon compounds in the air.)

If on the other hand the hydrogen had been obtained from sun-powered photovoltaic electrolysis, water on the earth would have been split into clean hydrogen and oxygen with only photonic energy. As the fuel cell auto zips down the  road, that stored photonic energy propels the vehicle, returning only clean water to the environment. No carbon compound emission was added to the atmosphere. Yes, the auto travel adds heat to the atmosphere, but if the photons had not been used for this transportation, they would have otherwise been converted directly into atmospheric heat or photosynthetically converted into biomass. Using sunlight directly to power vehicles does not increase  the net atmospheric quantity of carbon-based molecules. As a side issue, the use of sun-generated hydrogen in an IC vehicle does transform some of the atmosphere’s nitrogen to harmful NOX, adding to the argument for the superior cleanliness of a fuel cell powered vehicle.

Take the example one step further to a methanol-powered fuel cell, If the  methanol was produced in a natural gas extraction process, carbon compounds from under the earth’s surface would be added to the atmosphere in the conversion. Additional carbon dioxide would also be added to the atmosphere when the fuel cell utilized the methanol. Again, the net environmental effect would be negative.

However, if the methanol had been produced from the burning of wood  (methanol is also called wood alcohol), there would be no long-term net increase in atmospheric carbon because the wood was produced from an earlier, photosynthesis process which extracted the carbon dioxide and water from the atmosphere. As the fuel cell uses the methanol, the carbon dioxide produced comes from the wood which was initially produced from the carbon dioxide in the air, so no new carbon is added to the atmosphere; again - net zero! Of course, the myopic would argue that the smoke added to the atmosphere by the wood fire increased the airborne carbon, but the argument neglects the origin of that carbon.

Of course, the ‘net-zero-really-long-term’ protagonist would argue that the net carbon hydrogen and oxygen in oil, coal  or gas was transformed from sunlight and earth- sourced elements. It is important to note that significant carbon is not imported to the earth and its atmosphere, with the exception of an occasional meteor. ‘Clean’ might be viewed as a dynamic rather than  absolute condition. One choice is to increase the net airborne carbon compounds with respiratory challenges and  global warming, then adapt to the changes. The lesson to be learned is from the shark, not the dinosaur.               DKG