Federal Motor Vehicle Safety Standards for Electric Vehicles |
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Topics: National Highway Traffic Safety Administration, Federal Motor Vehicle Safety Standards
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Stanley R. Scheiner
Federal Register
September 30, 1994
[Federal Register: September 30, 1994]
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
49 CFR Part 571
[Docket No. 91-49; Notice 04]
RIN [2127-AF43]
Federal Motor Vehicle Safety Standards for Electric Vehicles
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Request for Comments.
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SUMMARY: The purpose of this notice is to solicit public comments to
help NHTSA assess the need to regulate electric vehicles (EVs) with
respect to battery electrolyte spillage in a crash or rollover, and
electric shock hazard in a crash or rollover and during repair or
maintenance. Comments are requested on the potential safety hazards
associated with each, and possible regulatory solutions, for original
equipment EVs and EV conversions.
DATES: Comments must be received by November 29, 1994.
ADDRESSES: Comments on the notice should refer to the docket number and
notice number shown above, and be submitted in writing to: Docket
Section, National Highway Traffic Safety Administration, Room 5109, 400
Seventh Street, SW., Washington, DC 20590. Telephone: (202) 366-4949.
Docket hours are 9:30 a.m. to 4 p.m., Monday through Friday.
FOR FURTHER INFORMATION CONTACT:
Mr. Gary R. Woodford, NRM-01.01, Special Projects Staff, Office of
Rulemaking, National Highway Traffic Safety Administration, 400 Seventh
Street, SW., Washington, DC 20590 (202-366-4931).
SUPPLEMENTARY INFORMATION:
I. Introduction
A sizeable increase in the number of alternatively fueled motor
vehicles, including electric vehicles (EVs), in the United States is
expected. This expectation stems from initiatives by the President,
Congress, State and local governments, and private interests, since
these vehicles could help reduce air pollution and conserve petroleum
fuel.
The Clean Air Act Amendments of 1990 include provisions that
promote the use of alternative fuels in motor vehicles. Under these
Amendments, fleet vehicles sold in geographic areas with the most
serious air pollution problems will be subject to emission standards
that will require the use of clean fuels, including methanol and
ethanol, reformulated gasoline, natural gas, liquefied petroleum gas,
and electric power.
In addition, the Energy Policy Act of 1992 (EPACT) requires
Federal, State, and alternative fuel provider fleets to acquire
increasing percentages of alternatively fueled vehicles. The Department
of Energy is in the process of initiating a rulemaking, as required by
EPACT, to determine if private fleets should also be required to
purchase certain percentages of alternatively fueled vehicles as part
of their new fleet acquisitions.
Executive branch initiatives will also encourage the increased use
of alternatively fueled vehicles. Executive Order 12844, dated April
21, 1993, directs that purchases of alternatively fueled vehicles by
the Federal government by substantially increased beyond the levels
required by current law. It also established the Federal Fleet
Conversion Task Force to accelerate the commercialization and market
acceptance of alternatively fueled vehicles throughout the country.
A primary impetus for introduction of large numbers of EVs in the
U.S. market is a regulation of the California Air Resources Board.
Similar regulations are under consideration by other States. The
California regulation requires that not less than two percent of a
manufacturer's sales in the State (roughly 40,000 vehicles total) must
be zero emission vehicles (ZEVs), beginning in model year 1998. This
requirement will increase to 10 percent or roughly 200,000 vehicles
beginning in model year 2003. The definition of a ZEV is a vehicle that
emits no exhaust or evaporative emission of any kind. Currently, the EV
is the only vehicle which meets these requirements.
The National Highway Traffic Safety Administration (NHTSA) is
authorized by law (49 U.S.C. 30101-30169) to regulate the safety
performance of motor vehicles and motor vehicle equipment through the
issuance of Federal motor vehicle safety standards (FMVSSs). In
addition, NHTSA has the authority to issue guidelines for States to use
in state motor vehicle inspection programs.
Supplementing this authority in the area of alternatively fueled
vehicle safety, the Energy Policy Act of 1992 requires that NHTSA must
``within three years after enactment promulgate rules setting forth
safety standards in accordance with [the agency's statutory authority]
applicable to all conversions.'' In addition, the Clean Air Act
Amendments of 1990 include a provision that NHTSA promulgate necessary
rules regarding the safety of vehicles converted to run on clean fuels.
NHTSA wishes to assure the safe introduction of EVs and other
alternatively fueled vehicles to the market without impeding technology
development.
II. Background
On December 27, 1991, the agency published in the Federal Register
an advance notice of proposed rulemaking (ANPRM) on EV safety (56 FR
67038). The purpose of the notice was to help NHTSA determine what
existing FMVSSs may need modification to better accommodate the unique
technology of EVs, and what new safety standards may need to be written
to assure their safe introduction. The ANPRM requested comments on a
broad range of potential EV safety issues including battery electrolyte
spillage and electric shock hazard, and elicited widespread public
interest. A total of 46 comments were received.
After reviewing all of the comments and information received in
response to the ANPRM, NHTSA concluded in a November 18, 1992 notice
(57 FR 54354) that it was premature to initiate rulemaking for new EV
safety standards at that time. In the areas of battery electrolyte
spillage and electric shock hazard in a crash, the agency concluded
that further research was needed.
In 1993 NHTSA conducted research and testing on two converted EVs.
The vehicles were tested relative to several FMVSSs, including a crash
test in accordance with FMVSS No. 208, Occupant Crash Protection. The
two vehicles were equipped with lead-acid batteries located in the
front and rear (engine and luggage compartments). One vehicle was
equipped with twelve 12-volt batteries (five in the front and seven in
the rear). The second vehicle was equipped with ten 12-volt batteries
(four in the front and six in the rear). The tests involved frontal
crashes into a fixed barrier at 48 kilometers per hour (kph). In both
crashes the front batteries sustained significant damage, spilling
large quantities of electrolyte. On one vehicle 10.4 liters of
electrolyte spilled from the front batteries as a result of the crash.
On the other vehicle 17.7 liters of electrolyte spilled from the front
batteries. In addition, several electrical arcs were observed under the
hood of one vehicle during the crash.
Based on the results of this research and the increasing interest
in using EVs to meet clean air requirements, the agency has decided to
reexamine through this notice the safety issues involving EV battery
electrolyte spillage and electric shock hazard. NHTSA notes that the
Society of Automotive Engineers (SAE) through its various committees is
also exploring possible voluntary industry standards and guidelines in
these two areas. The agency wishes to identify the magnitude of the
potential safety hazards involved, as well as possible solutions for
both original equipment EVs and EV conversions.
With respect to conversions, NHTSA's statutory authority
distinguishes between two populations of vehicle conversions. The
distinction is based on whether the vehicle is converted before or
after the first sale to the ultimate consumer.
When a vehicle is converted to an alternative fuel before the first
sale to the ultimate consumer, the converter is in the same position as
an original vehicle manufacturer. The converter must certify that the
vehicle still complies with all applicable FMVSSs, including any fuel
system integrity standards applicable to the alternative fuel. For
example, if a converter before the first sale converted a gasoline
powered vehicle to an EV, and if NHTSA has promulgated an electrolyte
spillage standard applicable to that model year EV, the converter would
need to certify that, among other requirements, the vehicle complied
with the electrolyte spillage requirements. In the case of a
noncompliance, the manufacturer or converter must recall and remedy the
noncompliant vehicles by repair or replacement; in addition, NHTSA has
the authority to impose a civil penalty of $1000 per violation up to a
maximum of $800,000.
By contrast, if a vehicle is converted after the first sale to a
consumer, different requirements apply. 49 U.S.C. 30122(b) provides
that:
A manufacturer, distributor, dealer, or motor vehicle repair
business may not knowingly make inoperative any part of a device or
element of design installed on or in a motor vehicle * * * in
compliance with an applicable Federal motor vehicle safety standard.
This includes a vehicle's fuel system. (The prohibition only
applies to a converter which is functioning as a ``manufacturer,
distributor, dealer, or motor vehicle repair business,'' not to an
individual or to a commercial entity which converts a vehicle for its
own purposes.) This provision differs from requirements before first
sale in that the converter does not ``certify'' compliance with the
standard, but instead must not ``knowingly make inoperative.''
Using the above example of conversion from gasoline to EV, if a
converter after first sale to the consumer converted a gasoline-powered
vehicle to an EV, and if NHTSA regulated electrolyte spillage for that
model year vehicle, the converter need not certify compliance to the
electrolyte spillage standard. However, the converter could not
knowingly perform the conversion in such a way that the vehicle would
fail to meet the requirements of the electrolyte spillage standard. If
this standard was tested for compliance by means of crash tests, this
might be impractical for converters. Therefore, for aftermarket
conversions, NHTSA is exploring the promulgation of regulations which
would define ``make inoperative'' in terms of design requirements as a
surrogate for the FMVSS requirements. The penalty for noncompliance
with Section 30122(b)'s make inoperative provision is $1000 per
violation, up to a maximum of $800,000.
In addition to Federal motor vehicle safety standards, NHTSA has
the statutory authority to issue vehicle safety inspection standards
which can serve as guidelines for those States which conduct safety
inspection programs. The agency could issue such inspection standards
for EVs, which a State could voluntarily use if it opts to conduct
vehicle inspections for converted EVs.
Thus, in this notice NHTSA seeks comments on a variety of possible
approaches to address the potential safety hazards of EV battery
electrolyte spillage and electric shock hazard. Among the possible
options are:
(1) Federal safety regulation for EVs and EVs converted before the
first sale to a consumer. These would most likely be primarily
performance oriented requirements, such as in FMVSS No. 301, Fuel
System Integrity, which limits the amount of allowable fuel leakage for
liquid fuels after a barrier crash and rollover test. Although the
agency's goal in establishing safety standards is to have performance
oriented requirements, the agency does have some latitude to establish
design oriented requirements when necessary or more appropriate.
(2) Regulations to define the term ``make inoperative'' in Section
30122(b) as it applies to EVs converted after the first sale to a
consumer. These regulations would most likely be design oriented, since
it may not be practical for a converter to crash test, and thereby
destroy, the converted vehicle. Such regulations would help vehicle
converters understand what constitutes ``make inoperative'' in
converting a vehicle to electric power. An example of such regulations
could be where to locate or how to protect the EV batteries so as to
minimize battery damage and therefore minimize electrolyte spillage in
a crash.
(3) Vehicle safety inspection standards to serve as guidelines for
those States which conduct motor vehicle safety inspection programs.
The agency could issue such inspection standards for EVs, which a State
could voluntarily use if it chooses to conduct vehicle inspections of
EVs, both original equipment and conversions.
III. Potential Problem Areas and Possible Solutions
In this section of the notice NHTSA requests comments on the
potential safety hazards due to EV battery electrolyte spillage in a
crash or rollover, and due to electric shock in a crash or rollover and
during repair and maintenance. Information is also sought on possible
means to address such hazards through performance and design
requirements for original equipment EVs and EV conversions. Information
is requested separately for (1) EVs with a GVWR of 4536 kg or less and
all school buses, which is the population of vehicles NHTSA
traditionally has regulated for fuel system integrity, and for (2) EVs
with a GVWR greater than 4536 kg, excluding EV school buses, since
there may be potential safety hazards and possible approaches which are
unique to vehicles of this size and type. Finally, other information on
EVs is requested, including current and projected EV populations and
production, industry and State or local guidelines on EV safety, hybrid
EVs, charging, batteries, and starter interlock performance.
This section of the notice is organized as follows:
A. Battery Electrolyte Spillage
--Potential Safety Problem
--Possible FMVSS Performance Requirements
--Possible Requirements for Conversions After First Sale to
Consumers
--EVs With GVWR Greater Than 4536 Kilograms
B. Electric Shock Hazard
--Potential Safety Problem
--Possible FMVSS Performance Requirements
--Possible Requirements for Conversions After First Sale to
Consumers
--EVs With GVWR Greater Than 4536 Kilograms
C. Other
A. Battery Electrolyte Spillage
Potential Safety Problem
Currently-produced EVs carry onboard the vehicle a relatively large
number of batteries, and therefore a substantial amount of electrolyte
solution. Because of the hazards of electrolyte, there is the potential
in a crash or rollover for injury to vehicle occupants, bystanders, and
emergency rescue and clean-up personnel. The agency requests comments
on the potential safety hazards for EVs with a GVWR of 4536 kg or less,
and all EV school buses regardless of weight.
1. Describe the different types of propulsion batteries which are
expected to be used in EVs over the next five and ten years, including
the form (liquid or gel), chemical properties, and temperatures of the
various electrolyte solutions. Which of the electrolyte solutions are
acidic, basic, or water reactive, and to what extent? How many
batteries and what quantity of electrolyte are expected to be onboard
EVs over the next five and ten years? Where will the batteries be
located on EVs?
2. Is there a potential safety problem with electrolyte contacting
occupants, bystanders, rescue teams, or clean-up personnel as a result
of an EV crash or rollover? If so, what are the potential safety
consequences? Can chemical or thermal burns result? Is there the
potential for toxic or asphyxiant vapors? If so, from which
electrolytes and due to what quantities of spillage?
3. What is the potential fire hazard of spilled or sprayed
electrolyte in a crash or rollover? Could battery electrolyte ignite in
the same way as a fuel? If so, which electrolytes and in what
quantities, concentrations, or mixtures, and at what temperatures? What
is the likelihood that leaking electrolyte at a crash scene could serve
as an electrical conductor or short circuit, thereby creating a fire
hazard?
4. The agency understands that sodium-sulphur batteries operate
with liquid coolant at approximately 316 degrees C., which circulates
around the batteries and through a heat exchanger onboard the EV. The
temperature of liquid coolants for internal combustion engines on
conventional vehicles is much lower, approximately 91 degrees C.
Further, sodium-sulphur batteries require an extremely strong vacuum
insulated container to retain the heat and prevent spillage in an
accident. Sodium can explode if it comes into contact with water. Is
there a potential safety problem with high temperature battery coolants
contacting occupants, bystanders, rescue teams, or clean-up personnel
as a result of an EV crash or rollover? If so, what are the safety
concerns? Can burn injuries result? What types of coolants are used
with EV batteries, and what are their corresponding temperature ranges
during driving and charging operations?
5. Describe the likelihood and potential safety consequences of
having spilled electrolyte from an EV crash mix with a different
electrolyte or with other vehicle fluids, such as gasoline, diesel
fuel, engine coolant, or oil. Could a chemical fire or explosion occur,
and if so, with which electrolytes and fluids? Is there the potential
for toxic or asphyxiant vapors? Please discuss.
6. Describe all EV crashes or rollovers or noncrash events
involving spilled electrolyte, including the sequence of events, a
description of the EV, and the type of electrolyte which spilled. Were
there injuries or fatalities as a result of the spilled electrolyte? If
so, please describe.
7. Discuss the need for federal regulation to address the potential
safety hazards of battery electrolyte spillage in a crash or rollover,
or noncrash event.
Possible FMVSS Performance Requirements
One approach which the agency could use to address electrolyte
spillage in a crash or rollover is to limit the amount of allowable
spillage through a performance test. This could be similar to the
requirements in FMVSS No. 301, Fuel System Integrity, which limits the
amount of allowable liquid fuel spillage after barrier crash and static
rollover tests. FMVSS No. 303, Fuel System Integrity of Compressed
Natural Gas Vehicles, contains similar crash test limitation
requirements. FMVSS No. 301, for example, after barrier crash tests
requires that there be no more than (1) One ounce (28 grams) by weight
of liquid fuel loss from the time of barrier impact until vehicle
motion has ceased, (2) five ounces (142 grams) during the next five
minutes, and (3) one ounce (28 grams) per minute during the next 25
minutes. These requirements apply to vehicles of 10,000 pounds (4536
kg) GVWR or less when subjected to a 30 mph (48 kph) frontal fixed
barrier crash test, or 20 mph (32 kph) lateral or 30 mph (48 kph) rear
moving barrier crash test. For school buses with a GVWR greater than
10,000 pounds (4536 kg), FMVSS No. 301 requires a 30 mph (48 kph)
moving barrier impact at any point from any angle on the bus with the
same allowable fuel loss. FMVSS No. 301 has similar fuel spillage
limitations during a static rollover test, following a crash test, for
vehicles of 10,000 pounds (4536 kg) GVWR or less.
Comments are requested on possible approaches for addressing the
safety hazards of electrolyte spillage in a crash or rollover for EVs
with a GVWR of 4536 kg or less, and for all EV school buses regardless
of weight.
8. Discuss the appropriateness of using an approach similar to that
of FMVSS No. 301 to regulate the safe performance of EV electrolyte
spillage in a crash or rollover.
9. What would be an appropriate amount of electrolyte spillage to
allow after a crash or rollover test? Please discuss. Should it be
based on the number or type of batteries onboard the EV, or whether
spillage occurs inside or outside the passenger compartment or cargo
areas? If so, how much should be allowed? For example, should a ``level
of hazard'' be defined by battery type, which would allow spillage of
larger quantities of less harmful electrolytes and smaller quantities
of the more harmful electrolytes? Would it be appropriate to require no
spillage? Is there an amount that would approximate the no-spillage
condition?
10. Would it be appropriate to set similar requirements for the
spillage of high temperature liquid coolants from EV batteries? If so,
what should be the allowable amounts of spillage? What should be the
threshold temperature above which spillage requirements are needed?
11. Are there other performance requirements that should be
considered in addressing the safety hazards of EV battery electrolyte
spillage in a crash or rollover? If so, please describe them.
Possible Requirements for Conversions After First Sale to Consumers
In the case of EVs converted after first sale to a consumer, where
the ``make inoperative'' requirements apply, it may not be practical to
test for the safe performance of electrolyte spillage through a crash
test since this would destroy the converted vehicle. Design oriented
requirements may be more appropriate, such as defining where to locate
or how to protect the EV batteries in a crash or rollover. Comments are
requested on possible approaches for EVs with a GVWR of 4536 kg or
less, and all EV school buses regardless of weight.
12. For EVs converted after first sale to a consumer, would it be
appropriate to define the term ``make inoperative'' as being not able
to comply with the performance requirements of a crash standard? For
example, would it be appropriate to require such EV conversions to be
tested in accordance with any crash test requirements the agency may
establish relative to battery electrolyte spillage? please discuss.
13. Alternatively, would it be appropriate to establish separate
design requirements as a surrogate for performance requirements, to
address electrolyte spillage in a crash or rollover for EV after-first-
sale conversions? Please discuss. Would such requirements provide a
level of performance comparable to that of a vehicle crash test? If so,
please describe them.
14. Discuss the appropriateness of requiring that batteries be
placed onboard the EV at locations which minimize their damage in a
crash or rollover, or in a protective box. What locations would
minimize battery damage? What requirements should be placed on battery
box design, construction, or testing? Should the boxes be constructed
with dual walls to allow some crush of the outer wall in a crash or
rollover?
15. Would it be appropriate to require that all batteries be
equipped with threaded vent/filler caps, rather than friction-fit caps,
to minimize electrolyte spillage? Alternatively, should only sealed
batteries be used--those without vent/filler caps?
16. Discuss the need for EV labeling with respect to electrolyte
spillage. Should EVs be labeled with the type of battery electrolyte
onboard the vehicle to assist emergency rescue teams at a crash scene?
17. Would such design requirements be appropriate for States to use
as guidelines in conducting motor vehicle safety inspection programs:
If not, what requirements would be more appropriate? Please describe
them.
EVs With GVWR Greater Than 4536 Kilograms
In this section of the notice NHTSA requests comments in response
to items 1 through 17 above, as they apply to original equipment EVs
and EV conversions with GVWR greater than 4536 kilograms, excluding
school buses. These include transit buses, intercity buses, trucks, and
other heavy vehicles. NHTSA requests information on this group of
vehicles separately, since there may be potential electrolyte spillage
problems, and possible solutions, which are unique to such heavy
vehicles.
18. Please provide the information requested in Questions 1-17
above, as it applies to EVs with a GVWR greater than 4536 kg, excluding
school buses. Should these types of EVs be regulated for electrolyte
spillage in a crash or rollover? Are there unique safety hazards among
EVs of this size and type?
19. Should heavy EVs, other than school buses, be crash tested for
electrolyte spillage in the same way as heavy school buses in FMVSS No.
301, Fuel System Integrity, where a contoured barrier traveling at 48
kph strikes the vehicle at any point and angle? Please discuss. Are
there other approaches which would be more appropriate for addressing
electrolyte spillage in heavy EVs? For example, what type of design
standard or alternative approach would be necessary to provide a level
of safety equivalent to that of FMVSS No. 301, and how would this be
evaluated?
B. Electric Shock Hazard
Potential Safety Problem
The electric propulsion systems for current technology EVs operate
at a relatively high level of electric power. In the case of the two EV
conversions which the agency crash tested in 1993, the nominal voltage
levels for the electric propulsion systems were 120 and 144 volts with
a maximum battery system current limit (controlled by fuse) of 400 and
350 amps for the Sebring and Solectria vehicles, respectively. Current
technology EVs have battery voltage levels up to 400 volts or more, and
maximum current ratings up to 400 amps. Because of these high levels of
electric power, there is the potential for electric shock to occupants
and rescue teams as a result of an EV crash or rollover. There is also
the potential for electric shock to persons performing EV repair and
maintenance.
The agency requests information on the potential safety hazards of
electric shock for EVs with a GVWR of 4536 kg or less, and all EV
school buses regardless of weight.
20. What levels of voltage (volts) and current (amps) are expected
to be used in EV propulsion systems over the next five and ten years?
Do these levels depend on vehicle size or the type of electric drive
system onboard the EV (AC or DC)? Please describe.
21. Describe the potential for electric shock to vehicle occupants
and rescue teams as a result of an EV crash or rollover. How could
electric shock be incurred by each? What technologies and designs are
being incorporated by EV manufacturers to minimize or eliminate such
hazard?
22. Describe the potential for electric shock to trained service
personnel and ``do-it-yourself'' persons while performing EV repair and
maintenance. How could electric shock be incurred by each? What
technologies, designs, instructions or labeling are being incorporated
by EV manufacturers and converters to minimize or eliminate such
hazard?
23. Provide the minimum levels of electric shock to the human body
in terms of current, time, and voltage (up to 600 volts), which can
produce injuries and fatalities. Describe the types of injuries that
can be incurred, along with the corresponding levels of current, time,
and voltage. Can such injuries be related to the Abbreviated Injury
Scale (AIS) for automotive medicine? What levels and time periods can
cause fatal injury? Do these vary based on whether the current is AC or
DC, or on the age, weight, and general health of the person? Please
discuss.
24. Describe the potential for an electrical fire as a result of an
EV crash or rollover. How could an electrical fire occur? Is it
possible for a high power electrical connector or conductor onboard the
EV to become short circuited to another object, become overheated, and
thereby cause a fire? What is the likelihood of this?
25. Describe all incidents of electric shock to occupants or rescue
teams as a result of an EV crash or rollover or noncrash event, or to
persons performing EV repair or maintenance. Include a description of
the circumstances, the vehicles and persons involved, and what type and
severity of injury or fatality that occurred due to electric shock.
26. Discuss the need for federal vehicle regulation to address
electric shock hazard as a result of an EV crash or rollover, noncrash
event, or during EV repair or maintenance.
Possible FMVSS Performance Requirements
NHTSA requests comments on possible approaches for addressing the
safety hazards of electric shock in a crash or rollover, and during
repair and maintenance, for EVs with a GVWR of 4536 kg or less, and all
EV school buses regardless of weight.
27. Would it be appropriate to require EV circuit interrupter
performance in a crash or rollover, which would automatically
disconnect the propulsion batteries from all other electrical circuits
and thereby prevent high voltage and current flow to other parts of the
vehicle? Such response would be similar in timing and deceleration
level to that of an occupant protection airbag in a crash. Does the
technology exist to require such performance of a circuit interrupter
for EV propulsion batteries in a crash or rollover? Please discuss.
28. What time period, deceleration level, and vehicle attitude
should be required for circuit interrupter performance of EV propulsion
batteries in a crash or rollover? Should these be related to the
minimum injury levels for electric shock discussed earlier, or whether
the EV drive system is AC or DC? What types of circuit interrupter
device should be required? Please discuss.
29. What is an appropriate method of compliance testing circuit
interrupter performance of EV propulsion batteries in a crash or
rollover? Would an EV crash test (front, side, or rear) and static
rollover test, as in FMVSS No. 301, be appropriate, where performance
of the circuit interrupter could be measured over time at a certain
deceleration or vehicle attitude? Alternatively, could a component test
of the circuit interrupter be conducted, which would eliminate the need
for a vehicle crash test? Please discuss.
30. Would it be appropriate to require that EV batteries,
connectors, cables, and wiring be located, routed, and insulated so as
to minimize or eliminate electric shock hazard due to a crash or
rollover, or during repair and maintenance? Similarly, should there be
a requirement for minimum wire size in EV circuits? For example, what
should be the minimum wire sizes for AC and DC propulsion drive
circuits ranging from 120 to 600 volts? Should there be a requirement
that EV propulsion circuits not be grounded to the vehicle chassis
(electrically isolated)? What standards and guidelines are being used
by current EV manufacturers and converters? Please discuss.
31. Would it be appropriate to require EVs to have a means of
manually disconnecting the propulsion batteries from other EV circuits
for safety during repair or maintenance? Additionally, should circuit
interruption performance be required of EV circuits through means such
as fuses, circuit breakers, or ground fault interrupters? What types
should be required? Are EV controllers typically equipped with
capacitors which can remain energized even after the main power circuit
has been disconnected? What technologies are available? Please discuss.
32. Would it be appropriate to require EV labeling and written
instructions to minimize electric shock hazard as a result of a crash
or rollover, or during repair or maintenance? Should an EV be labeled
as ``Electric Vehicle,'' along with labels or instructions on the
location and method of manually disconnecting the propulsion batteries?
Please discuss.
33. Should there be requirements for battery container dielectric
strength? If so, what levels should be established and how should this
be tested? What standards currently exist? Please discuss.
34. Are there other performance requirements that should be
considered in addressing the safety hazards of electric shock in EVs as
a result of a crash or rollover, or during repair or maintenance? If
so, please describe them.
Possible Requirements for Conversions After First Sale to Consumers
In the case of EVs converted after first sale to a consumer, where
the ``make inoperative'' requirements apply, it may not be practical to
test for electric shock safety through a crash test since this would
destroy the converted vehicle. Design oriented requirements may be more
appropriate. Comments are requested on possible approaches for EVs with
a GVWR of 4536 kg or less, and all EV school buses regardless of
weight.
35. Please provide the information requested in Questions 27-34
above, as it applies to EVs converted after the first sale to a
consumer.
36. Are there other design requirements that should be considered
in addressing the safety hazards of electric shock in EV conversions as
a result of a crash or rollover, or during repair or maintenance? If
so, please describe them.
EVs With GVWR Greater Than 4536 Kilograms
In this section comments are requested in response to items 20
through 36 above, as they apply to original equipment EVs and EV
conversions with GVWR greater than 4536 kilograms, excluding EV school
buses. These include transit buses, intercity buses, trucks, and other
heavy vehicles. NHTSA requests information on this group of vehicles
separately, since there may be potential electric shock hazards, and
possible solutions, which are unique to such heavy vehicles.
37. Please provide the information requested in Questions 20-36
above, as it applies to EVs with a GVWR greater than 4536 kg, excluding
EV school buses.
38. Are there unique safety hazards among EVs of this size and
type? Should these types of EVs be regulated for electric shock hazard
in a crash or rollover, or during repair and maintenance? If so, how?
C. Other
Other information on EVs is requested for both original equipment
EVs and EV conversions of all sizes, addressing hybrid electric
vehicles, standards and guidelines, EV populations, charging,
batteries, and starter interlock performance, as follows:
Hybrid Electric Vehicles
39. Are there unique safety problems presented by hybrid electric
vehicles (HEV) relative to electrolyte spillage or electric shock? An
HEV is one which can operate on electric power, another fuel such as
gasoline, or both. Are there any unique safety problems which could
occur when both fuel sources are being utilized? Are there other
potential safety problems which should be considered relative to HEVs,
or EVs equipped with range extenders? Please discuss.
Standards and Guidelines
40. Describe industry, State, or local standards or guidelines that
could be used to address the safety hazards of EV battery electrolyte
spillage or electric shock. Are there standards or guidelines for
industrial or recreational vehicles, such as forklifts or golf carts,
which could be applied to EVs? Please describe.
41. Which States require motor vehicle safety inspection of EVs,
and what are the requirements? Please describe.
EV Populations
42. Provide estimates of the number of EVs in operation within the
United States today, and the number expected within the next five and
ten years. Please categorize by vehicle type. For vehicles with GVWR
less than or equal to 4536 kg, categorize by passenger car, pickup
truck, van, and other. For vehicles with GVWR greater than 4536 kg,
categorize by school bus, transit bus, intercity bus, heavy truck, and
other. What portions of these represent original equipment EVs, EV
conversions before the first sale to a consumer, and EV conversions
after first sale? Which types of EV propulsion batteries are expected
to be used? Please describe.
43. What is the likelihood that there will be an EV conversion
industry for used vehicles, i.e., those converted after first sale to a
consumer? Please discuss.
Charging
44. Describe the technology and potential safety problems
associated with EV recharging. Should there be federal safety
requirements? Should these include requirements for battery box venting
or flame arrestor performance, to protect against emissions of
explosive battery gases during recharging and other times of vehicle
operation? What standards, guidelines, or design practices are being
followed by manufacturers and converters to assure EV safety in this
area? Please discuss.
Batteries
45. Is there a potential safety hazard with EV batteries becoming
projectiles in a crash or rollover? Should there be federal
requirements for battery restraints? What standards, guidelines, design
practices, or other requirements are currently being followed by
manufacturers and converters? Please discuss.
46. What Federal, State, and local requirements currently exist for
the disposal, recycling, and transport of EV batteries? Do the
requirements distinguish between batteries which are damaged and leak,
and those which do not leak? Please discuss.
Transmission Starter Interlock
47. The agency understands that some EVs have a forward, neutral,
and reverse switch, while others have no neutral position or other
means such as a clutch for disconnecting the drive train from the
propulsion motor. Is there a potential safety problem with inadvertent
starting and unwanted vehicle motion among those EVs which have no
means of disconnecting the drive train? Please discuss.
48. What types of EV drive train designs are expected over the next
five and ten years? Is there a need for requiring EV starter interlock
performance, similar to that required on automatic transmissions in
FMVSS No. 102, Transmission Shift Level Sequence, Starter Interlock,
and Transmission Braking Effect? FMVSS No. 102 requires that the engine
starter be inoperative when the transmission shift level is in a
forward or reverse drive position. Please discuss.
Submission of Comments
The agency invites written comments from all interested parties. It
is requested that 10 copies of each written comment be submitted.
No comment may exceed 15 pages in length. (49 CFR 553.21).
Necessary attachments may be appended to a comment without regard to
the 15-page limit. This limitation is intended to encourage commenters
to detail their primary arguments in a concise fashion.
If a commenter wishes to submit specified information under a claim
of confidentiality, three copies of the complete submission, including
purportedly confidential business information, should be submitted to
the Chief Counsel, NHTSA, at the street address given above and seven
copies from which the purportedly confidential information has been
deleted should be submitted to the Docket Section. A request for
confidentiality should be accompanied by a cover letter setting forth
the information specified in the agency's confidential business
information regulation, 49 CFR part 512.
All comments received before the close of business on the comment
closing date indicated above for the proposal will be considered, and
will be available for examination in the docket at the above address
both before and after the closing date.
To the extent possible, comments filed after the closing date will
also be considered. NHTSA will continue to file relevant information as
it becomes available in the docket after the closing date, and it is
recommended that interested persons continue to examine the docket for
new material.
Those persons desiring to be notified upon receipt of their
comments in the rules docket should enclose a self-addressed, stamped
postcard in the envelope with their comments. Upon receiving the
comments, the docket supervisor will return the postcard by mail.
(49 U.S.C. 322, 30111, 30115, 30117, and 30166; delegations of
authority at 49 CFR 1.50)
Issued on: September 26, 1994.
Stanley R. Scheiner,
Acting Associate Administrator for Rulemaking.
[FR Doc. 94-24165 Filed 9-29-94; 8:45 am]
BILLING CODE 4910-59-M