1. page 1 10. June 2015 OICA position on venting EVSTF-04-11e

2. page 2 10. June 2015 OICA position on venting – General remarks Abnormal conditions and/or abnormal use (overcharge, short circuit, the presence of an external heat source...) can cause increases in temperature and/or unwanted chemical reactions that might lead to increased cell pressure The gas pressure generated by decomposition of the electrolyte can lead to mechanical failures within the cell which can cause rupture of the outer casing of the cell In case of a pressure increase above a design threshold level, the cell vents to reduce internal pressure The purpose of " venting " is to prevent the occurrence of more severe incidents, e.g. uncontrolled bursting of the cell, which could be detrimental to the preservation of the mechanical integrity of the battery. This could potentially develop into a riskful situation for the occupant(s). Venting is a safety feature of the automotive battery

3. page 3 10. June 2015 OICA position on venting – General remarks Venting is an effective safety functions also for the events which may not be covered by regulations or standards such as manufacturing faults, deteriorations, multiple/complex failures It is not appropriate to make regulation favoring batteries without such an important safety feature “Occurrence of venting in everyday use” is not a safety issue, but a quality/reliability issue Venting is not synonymous with thermal runaway and can occur without uncontrolled overheating of the cell/battery

4. page 4 10. June 2015 OICA position on venting OICA position is that quantitative measurement of venting gas, if considered for EVS-GTR, must be based on realistic field scenarios and informed assessment of exposure risk to potentially harmful substances There is no standardized or generally accepted method for quantitative determination of constituents in venting gases from Li ion propulsion batteries Work towards development of a test method should be postponed to Phase 2 of the EVS-GTR  Clear definitions of the scope, purpose and justification of a potential “venting test” are required (What safety issue is being addressed?)  Research is required to develop a reliable and robust verification method for qualitative gas measurements of vented gas mixtures from a variety of battery types and designs expected on the market

5. page 5 10. June 2015 OICA position with regard to GOST R 51206-2004 Contrary to EVS-08-24e ”Gas Management/Venting EC Perspective”, there was never any intention from industry to propose GOST R 51206-2004 for inclusion in the EVS-GTR: EVS-08-24e should be amended to reflect this, or withdrawn GOST R 51206-2004 is inappropriate for use as part of EVS-GTR: GOST R 51206-2004 is a test standard for determining concentrations of pollutants formed continually during driving due to incomplete combustion of liquid fuel by the ICE Venting from Li ion batteries is not part of normal operation of the battery and the evolution of gas is a battery proprietary characteristic, not related to the engine’s operation, hence, it CANNOT be evaluated as continual process during driving mode GOST R 51206-2004 may provide some helpful guidance with regard to methodology for measuring cabin ingress of toxic gases, but significant development of the test methodology and procedures are required in order to be suitable for evaluation of REESS venting Measurement locations inside the cabin Optional method of gas sampling and analytical method for quantitative determination of gas concentration

6. page 6 10. June 2015 OICA position on venting – GTR EVS amendment Amended and new definitions 3.38 Electrolyte leakage: Escape of electrolyte from the REESS in the form of liquid. 3.39 Aqueous electrolyte: An aqueous electrolyte is an electrolyte based on water solvent for the compounds (e.g. acids, bases) providing conducting ions after its dissociation. 3.40 Non-aqueous electrolyte: A non-aqueous electrolyte is an electrolyte not based on water as the main solvent. 3.41 Venting means the release of gases due to excessive internal pressure from cell or battery in a manner intended by design to preclude rupture or explosion Proposed requirement (EVS-07-19e, based on JP proposal) 5.1.X.Management of the gases emitted from REESS Under vehicle operation including the operation with failures, the vehicle occupants shall not be exposed to any hazardous environment caused by emitted gases from REESS. (Verification method to be discussed.)

7. page 7 10. June 2015 OICA position on venting – back up back-up: venting technology

8. page 8 10. June 2015 OICA position on venting – technology

9. page 9 10. June 2015 OICA position on venting – technology