AHAM-PTI CommentsAHAM-PTI Comments

CEC Test ProcedureCEC Test Procedure

April 8, 2008April 8, 2008

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CEC Test ProcedureCEC Test Procedure

AHAM will confine its comments to AHAM will confine its comments to household-appliancehousehold-appliance battery battery chargers. We cannot comment on chargers. We cannot comment on industrial-commercial chargers (fork industrial-commercial chargers (fork lifts, wheelchairs, golf carts).lifts, wheelchairs, golf carts).

Our members have nearly 50 years Our members have nearly 50 years each of experience producing battery each of experience producing battery powered rechargeable products and powered rechargeable products and battery chargers.battery chargers.

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PGE-Ecos Test ProcedurePGE-Ecos Test Procedure

AHAM appreciates the work of PGE AHAM appreciates the work of PGE and Ecos on the Test Procedureand Ecos on the Test Procedure

This test procedure contains the This test procedure contains the basics of measurement of battery basics of measurement of battery charger energycharger energy

We appreciate the suggestion that We appreciate the suggestion that industrial chargers are different from industrial chargers are different from household chargershousehold chargers

No major issues on measurementNo major issues on measurement

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Our commentaryOur commentary

We have addressed the CEC in the We have addressed the CEC in the past about our concerns and past about our concerns and recommendations regarding BCS recommendations regarding BCS regulationregulation

While we have begun to consider While we have begun to consider possible approaches we have possible approaches we have restricted our comments to the test restricted our comments to the test procedure procedure • Represents the Phase I objectiveRepresents the Phase I objective

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General General AHAM and PTI represent AHAM and PTI represent

manufacturers of appliances and manufacturers of appliances and power tools power tools

PGE/Ecos test procedure attempts to PGE/Ecos test procedure attempts to address a broad range of product address a broad range of product categoriescategories

AHAM/PTI have previously requested AHAM/PTI have previously requested separate regulation of appliancesseparate regulation of appliances

We can only comment on the We can only comment on the suitability of the procedure to suitability of the procedure to appliances including toolsappliances including tools

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Scope Scope

Appliance battery charging systemsAppliance battery charging systems• ““system” should be defined in Title 20system” should be defined in Title 20

Employing detachable or integral Employing detachable or integral batteriesbatteries• Detachable – removed from appliance Detachable – removed from appliance

for chargingfor charging• Integral – non-removable, charged in Integral – non-removable, charged in

applianceappliance

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Definitions Definitions

Need specific definitions in Title 20 Need specific definitions in Title 20 for appliance battery chargersfor appliance battery chargers• (u1) for industrial-commercial battery (u1) for industrial-commercial battery

chargerschargers• (u2) for appliance battery chargers(u2) for appliance battery chargers

To take precedence over those in the To take precedence over those in the test proceduretest procedure

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Measurements - generalMeasurements - general

Concern about sampling errorsConcern about sampling errors• Increasing concern with technology Increasing concern with technology

advancementadvancement• Recommend approach of C381.2Recommend approach of C381.2

Test at 115V/60Hz onlyTest at 115V/60Hz only• All our BCS’s are powered as such in CAAll our BCS’s are powered as such in CA

Concern about access to batteryConcern about access to battery• Providing for technician safety while Providing for technician safety while

maintaining design confidentialitymaintaining design confidentiality

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Specific measurementsSpecific measurements

E24 – simplification: conduct all tests E24 – simplification: conduct all tests for 24 hoursfor 24 hours

Maintenance – simplification: always Maintenance – simplification: always use last 4 houruse last 4 hour• Except if periodicity of cycle introduces Except if periodicity of cycle introduces

error (see above)error (see above)

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Specific measurementsSpecific measurements

““No battery – reference previously as No battery – reference previously as “standby”“standby”• Detachable – remove battery, measure Detachable – remove battery, measure

average power as in procedureaverage power as in procedure• Integral – Integral –

Connector between separate power unit Connector between separate power unit (e.g. wall adapter) and product – disconnect(e.g. wall adapter) and product – disconnect

AC power cord – zero powerAC power cord – zero power

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Battery energy Battery energy

Manufacturers to report energy in Manufacturers to report energy in Watt HourWatt Hour• Manufacturers use Ecos methodManufacturers use Ecos method

But – discharge suspended if there is But – discharge suspended if there is electronic cut-off before end-of-discharge electronic cut-off before end-of-discharge voltagevoltage

Related to newer battery design, especially Related to newer battery design, especially Li-ionLi-ion

Simplification: no need to determine Simplification: no need to determine Amp Hour capacityAmp Hour capacity

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Power factorPower factor

Has no significance to energy Has no significance to energy efficiency of appliance battery efficiency of appliance battery charging systemscharging systems• No demonstrated need for regulationNo demonstrated need for regulation• Simplification – eliminate test for these Simplification – eliminate test for these

products products

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Reporting Reporting

Report only the data needed for the Report only the data needed for the standard on test report standard on test report

Report battery energy in Watt hoursReport battery energy in Watt hours• Consistent with new UN/DOT requirements for Consistent with new UN/DOT requirements for

Li-ion batteries shipped by airLi-ion batteries shipped by air Remove calculation of “efficiency” in test Remove calculation of “efficiency” in test

methodmethod• Reserved for standard levelReserved for standard level

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Next stepsNext steps

AHAM and PTI continue to offer our AHAM and PTI continue to offer our willingness to work with CEC staff on willingness to work with CEC staff on appliance standard frameworkappliance standard framework• Sets specifics of testing for our productsSets specifics of testing for our products

We could provide data based on the We could provide data based on the specific test requirementsspecific test requirements

Believe acceptance criteria should be Believe acceptance criteria should be established from this dataestablished from this data

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CEC Test ProcedureCEC Test Procedure

The test procedure must be finalized The test procedure must be finalized before we can proceed to:before we can proceed to:• Data CollectionData Collection• RegulationRegulation

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Thank youThank you

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