1. OICA Feedback on Proposed Test Procedure
EVSTF-08-63e
OICA Feedback on Proposed Test Procedure

2. General Comments
OICA is committed to identifying the most appropriate and effective method to minimize occupant safety risk due to single cell internal short circuit
The latest test proposal which includes substantive updates related to test methodology has been circulated on 6/13/16 allowing insufficient time to evaluate.
OICA continues to believe that the content of EVSTF-08-35e represents a solid foundation for evaluating a proposed test method.
Following is preliminary comparison of latest proposal to these criteria

3. Comparison (1 of 2) Criteria Comment
Vehicle or system level assessment 
Current proposal is based on REESS level or vehicle level test.
Applicable to current state-of-the-art, as well as reasonably anticipated in the foreseeable future   
In view of the rapid pace of changes, it has not been possible to make this evaluation yet. Once proposal is stabilized, OICA members will be able to conduct and report on such evaluations.
Fair
The 3 initiation methods are not equivalent evaluations, even within the defined parameters
Reasonable
While anecdotal field events have been mentioned as basis for concluding this test represents a typical and realistic scenario, many such examples of battery fires have been studied and shown to be related to events other than single cell thermal runaway initiation
Effective
No data presented which demonstrates systems meeting proposed criteria are demonstrably safer, compared with systems which do not meet the proposed criteria

4. Comparison (2 of 2) Criteria Comment Practicable
Insufficient time to complete evaluation
Repeatable
Insufficient time to complete evaluation, however proposed initiation methods (nail penetration, for example) is known to be a highly variable test method.
Reproducible
Not influenced by modification/alteration of tested device
Current description of allowable modification is not objective and subject to substantial variation. This also creates risk of unknown regulatory authority expectations which are opposed to manufacturer plans

5. Summary
OICA proposes that additional research be allowed to continue to address the remaining issues
Current research is underway (NHTSA) and under consideration (OICA members)
Completion of thorough research is consistent with other tests considered for GTR
Emphasis must be on an effective requirement, not expediency