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Federal Motor Vehicle Safety Standards for Electric Vehicles

American Government Special Collections Reference Desk

American Government Topics:  National Highway Traffic Safety Administration, Federal Motor Vehicle Safety Standards

Federal Motor Vehicle Safety Standards for Electric Vehicles

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

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