-
Working safely
PGS 37-2 directive for storage of lithium-based energy carriers: 6 things that are important to know
PGS 37-2 directive for storage of lithium-based energy carriers: 6 things that are important to know
Due to the increasing use of electric machinery and equipment, the safe storage of batteries (lithium-containing energy carriers) is also becoming increasingly important. That is why the government has developed the Hazardous Substances Publication Series 37-2. This guideline will eventually become part of the Environment Act. Fedecom will keep you informed of developments regarding this topic through its newsletter. In this edition of the newsletter, we highlight six key points that are currently important to know about PGS 37-2.
1. Compliance with the PGS 37-2 guideline is not yet required by law.
The text of the PGS37-2 guideline was officially adopted in December 2023 by the Administrative Environmental Council (Bob), chaired by State Secretary Vivianne Heijnen. The guideline has yet to be enshrined in law. PGS37-2 will eventually be incorporated into the Living Environment Activities Decree (Bal) as part of the Environment Act. This is expected to take place in 2025. Until then, compliance with the guideline is not yet legally required.
2. The guideline addresses the safe storage of lithium-containing energy storage devices.
In recent years, the number of electric machines and work equipment has increased dramatically. This electrification also entails risks related to their storage. A defective, damaged, or misused lithium-containing energy storage device can enter a thermal runaway if it overheats, for example during charging or discharging. This chemical reaction is difficult to stop and can lead to a fire, during which harmful gases may be released. Because there were limited laws and regulations governing the safe storage of lithium-containing energy storage devices, the government decided to develop a PGS guideline for this purpose. A PGS37-1 guideline for large-scale energy storage systems has been in place since 2023. Now there is a second part: the PGS37-2 guideline. This guideline applies to the storage of lithium-containing energy carriers and can be applied to a warehouse, showroom, workshop, or large outdoor area.
3. The guideline applies to various sectors and industries.
The directive applies to the storage of lithium-containing energy storage devices, i.e., batteries for electric machinery and work equipment such as forklifts, (mini) excavators, aerial work platforms, and telehandlers, as well as, of course, various electric garden and landscaping machines and tools. The guideline is intended for companies that display these machines and work equipment in their showrooms, store lithium-containing energy storage devices in their warehouses, or have a large outdoor area where electric machines are stored.
The PGS 37-2 guideline is not applicable to machinery and work equipment containing lithium-based energy storage devices that are being worked on—for example, for repair or modification—and that are stored for no longer than one week, either inside or outside the workshop.
4. Not every company that stores lithium-containing energy carriers is required to comply with the guideline.
The PGS37-2 guideline applies to your business if you have more than 333 kilograms of lithium-containing energy storage devices on your premises (per fire compartment). This threshold also applies to used or refurbished lithium-containing energy storage devices. For defective or damaged energy storage devices, the threshold is significantly lower.
5. PGS 37-2 outlines risk scenarios and measures.
The guideline outlines measures for the safe storage of lithium-containing energy carriers. The risks have been assessed for various types of storage. This assessment took into account the size of the storage facility: small (up to 300 m²), medium (up to 2,500 m²), and large (2,500 m² and above). Based on these risk scenarios, objectives and corresponding measures have been established to help you handle lithium-containing energy carriers as safely as possible. These range from simple measures, which you can implement within a few months, to more extensive (structural) measures for which you have up to five years (and, in exceptional, individual cases, up to ten years) to comply. Simple measures might include spacing out (groups of) electrical machines and work equipment. More extensive measures include using a fire-resistant cabinet or safe to store lithium-containing energy storage devices, or implementing fire compartments to ensure that a fire is contained for a certain period of time and cannot spread to other parts of your building.
6. You can already start implementing the PGS 37-2 guideline.
Compliance with the PGS37-2 guideline is not yet legally required. However, in the meantime, it is possible that, for example, an insurer might ask you to comply with the guideline. The permitting authority may also require this when you apply for an environmental or zoning permit. Furthermore, it may be wise to begin implementing the measures now for safety reasons. If a measure from the PGS37-2 guideline is difficult to implement in your business, you may also implement it in an equivalent manner in consultation with the competent authority (municipality).
At Fedecom , we will continue to assess the impact of this PGS 37-2 guideline and keep you informed of any developments. In any case, it is advisable to stay in close contact with your insurer regarding this matter.