Federal Motor Vehicle Safety Standards; Electric-Powered Vehicles: Electrolyte Spillage and Electrical Shock Protection, 12647-12676 [2016-05187]
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Federal Register / Vol. 81, No. 47 / Thursday, March 10, 2016 / Proposed Rules
accidents caused by OSA? With respect
to rail, how would any OSA regulations
and the current PTC requirements
interrelate?
4. Which categories of transportation
workers with safety sensitive duties
should be required to undergo screening
for OSA? On what basis did you identify
those workers?
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Cost & Benefits
5. What alternative forms and degrees
of restriction could FMCSA and FRA
place on the performance of safetysensitive duties by transportation
workers with moderate-to-severe OSA,
and how effective would these
restrictions be in improving
transportation safety? Should any
regulations differentiate requirements
for patients with moderate, as opposed
to severe, OSA?
6. What are the potential costs of
alternative FMCSA/FRA regulatory
actions that would restrict the safety
sensitive activities of transportation
workers diagnosed with moderate-tosevere OSA? Who would incur those
costs? What are the benefits of such
actions and who would realize them?
7. What are the potential improved
health outcomes for individuals
occupying safety sensitive
transportation positions and would
receive OSA treatment due to
regulations?
8. What models or empirical evidence
is available to use to estimate potential
costs and benefits of alternative
restrictions?
9. What costs would be imposed on
transportation workers with safety
sensitive duties by requiring screening,
evaluation, and treatment of OSA?
10. Are there any private or
governmental sources of financial
assistance? Would health insurance
cover costs for screening and/or
treatment of OSA?
Screening Procedures & Diagnostics
11. What medical guidelines other
than the AASM FAA currently uses are
suitable for screening transportation
workers with safety sensitive duties that
are regulated by FMCSA/FRA for OSA?
What level of effectiveness are you
seeing with these guidelines?
12. What were the safety performance
histories of transportation workers with
safety sensitive duties who were
diagnosed with moderate-to-severe
OSA, who are now successfully
compliant with treatment before and
after their diagnosis?
13. When and how frequently should
transportation workers with safety
sensitive duties be screened for OSA?
What methods (laboratory, at-home,
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split, etc.) of diagnosing OSA are
appropriate and why?
14. What, if any, restrictions or
prohibitions should there be on a
transportation workers’ safety sensitive
duties while they are being evaluated
for moderate-to-severe OSA?
15. What methods are currently
employed for providing training or other
informational materials about OSA to
transportation workers with safety
sensitive duties? How effective are these
methods at identifying workers with
OSA?
Medical Personnel Qualifications &
Restrictions
12647
State, local, or Tribal government or
communities.
(2) Create a serious inconsistency or
otherwise interfere with an action taken
or planned by another Agency.
(3) Materially alter the budgetary
impact of entitlements, grants, user fees,
or loan programs or the rights and
obligations of recipients thereof.
(4) Raise novel legal or policy issues
arising out of legal mandates, the
President’s priorities, or the principles
set forth in the E.O.
The Department has determined this
ANPRM is a ‘‘significant regulatory
action’’ under E.O. 12866, and
significant under DOT regulatory
policies and procedures due to
significant public interest in the legal
and policy issues addressed. Therefore,
this notice has been reviewed by OMB.
16. What qualifications or credentials
are necessary for a medical practitioner
who performs OSA screening? What
qualifications or credentials are
necessary for a medical practitioner who
performs the diagnosis and treatment of
OSA?
17. With respect to FRA should it use
Railroad MEs to perform OSA screening,
diagnosis, and treatment?
18. Should MEs or other Agencies’
designated medical practitioners impose
restrictions on a transportation worker
with safety sensitive duties who selfreports experiencing excessive
sleepiness while performing safety
sensitive duties?
Issued under the authority of delegations
in 49 CFR 1.87(f) and (i) and 49 CFR 1.89(a),
respectively:
T.F. Scott Darling III,
Acting Administrator, Federal Motor Carrier
Safety Administration.
Sarah Feinberg,
Administrator, Federal Railroad
Administration.
Treatment Effectiveness
DEPARTMENT OF TRANSPORTATION
19. What should be the acceptable
criteria for evaluating the effectiveness
of prescribed treatments for moderateto-severe OSA?
20. What measures should be used to
evaluate whether transportation
employees with safety sensitive duties
are receiving effective OSA treatment?
National Highway Traffic Safety
Administration
Rulemaking Analyses and Notices
Executive Order (E.O.) 12866
(Regulatory Planning and Review) and
DOT Regulatory Policies and
Procedures
Under E.O. 12866, ‘‘Regulatory
Planning and Review’’ (issued
September 30, 1993, published October
4 at 58 FR 51735, and discussed above
in the ‘‘Background’’ section), as
supplemented by E.O. 13563 and DOT
policies and procedures, if a regulatory
action is determined to be ‘‘significant,’’
it is subject to Office of Management
and Budget (OMB) review. E.O. 12866
defines ‘‘significant regulatory action’’
as one likely to result in a rule that may:
(1) Have an annual effect on the
economy of $100 million or more or
adversely affect in a material way the
economy, a sector of the economy,
productivity, competition, jobs, the
environment, public health or safety, or
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[FR Doc. 2016–05396 Filed 3–9–16; 8:45 am]
BILLING CODE 4910–EX–P
49 CFR Part 571
[Docket No. NHTSA–2016–0029]
RIN 2127–AL68
Federal Motor Vehicle Safety
Standards; Electric-Powered Vehicles:
Electrolyte Spillage and Electrical
Shock Protection
National Highway Traffic
Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking
(NPRM).
AGENCY:
NHTSA is proposing to
amend Federal Motor Vehicle Safety
Standard (FMVSS) No. 305, ‘‘Electricpowered vehicles: Electrolyte spillage
and electrical shock protection,’’ to
adopt various electrical safety
requirements in Global Technical
Regulation (GTR) No. 13, ‘‘Hydrogen
and fuel cell vehicles.’’ To expand the
standard’s performance requirements
beyond post-crash conditions, NHTSA
proposes to adopt electrical safety
requirements to protect against direct
and indirect contact of high voltage
SUMMARY:
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Federal Register / Vol. 81, No. 47 / Thursday, March 10, 2016 / Proposed Rules
sources during everyday operation of
electric-powered vehicles. Also, NHTSA
proposes to adopt an optional method of
meeting post-crash electrical safety
requirements consistent with that set
forth in GTR No. 13 involving use of
physical barriers to prevent direct or
indirect contact (by occupants or
emergency services personnel) with
high voltage sources. Today’s proposal
would facilitate the introduction of new
technologies including hydrogen fuel
cell vehicles and 48 volt mild hybrid
technologies, and responds not only to
GTR No. 13 but also to petitions for
rulemaking from Toyota Motor North
America Inc. (Toyota) and the Auto
Alliance (Alliance).
DATES: Comments must be received on
or before May 9, 2016.
Proposed compliance date: We
believe there is widespread
conformance of vehicles to the proposed
requirements. Accordingly, we propose
that the compliance date for the
amendments in this rulemaking action
would be 180 days after the date of
publication of the final rule in the
Federal Register. We propose to permit
optional early compliance with the
amended requirements.
ADDRESSES: You may submit comments
to the docket number identified in the
heading of this document by any of the
following methods:
• Federal eRulemaking Portal: Go to
https://www.regulations.gov. Follow the
online instructions for submitting
comments.
• Mail: Docket Management Facility,
M–30, U.S. Department of
Transportation, West Building, Ground
Floor, Rm. W12–140, 1200 New Jersey
Avenue SE., Washington, DC 20590.
• Hand Delivery or Courier: West
Building Ground Floor, Room W12–140,
1200 New Jersey Avenue SE., between
9 a.m. and 5 p.m. Eastern Time, Monday
through Friday, except Federal holidays.
• Fax: (202) 493–2251.
Regardless of how you submit your
comments, please mention the docket
number of this document.
You may also call the Docket at 202–
366–9324.
Instructions: For detailed instructions
on submitting comments and additional
information on the rulemaking process,
see the Public Participation heading of
the Supplementary Information section
of this document. Note that all
comments received will be posted
without change to https://
www.regulations.gov, including any
personal information provided.
Privacy Act: Please see the Privacy
Act heading under Rulemaking
Analyses and Notices.
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For
technical issues, you may call William
J. Sanchez, Office of Crashworthiness
Standards (telephone: 202–493–0248)
(fax: 202–493–2990). For legal issues,
you may call Deirdre Fujita, Office of
Chief Counsel (telephone: 202–366–
2992) (fax: 202–366–3820). Address:
National Highway Traffic Safety
Administration, U.S. Department of
Transportation, 1200 New Jersey
Avenue SE., West Building,
Washington, DC 20590.
SUPPLEMENTARY INFORMATION:
FOR FURTHER INFORMATION CONTACT:
Table of Contents
I. Executive Summary
II. FMVSS No. 305
III. The Global Technical Regulation
a. Overview of the Process
b. Overview of GTR No. 13
1. Electric Safety Requirements During
Normal Vehicle Operation
2. Electric Safety Requirements Post-Crash
Test
c. How does this proposal differ from GTR
No. 13?
IV. Battelle Study and Developments
V. Toyota Petition for Rulemaking
VI. Alliance Petition for Rulemaking
VII. Overview of Proposed Rule
VIII. Proposal Addressing Safety During
Normal Vehicle Operations
IX. Proposal Addressing Safety Post-Crash
X. Rulemaking Analyses and Notices
XI. Public Participation
I. Executive Summary
NHTSA is issuing this NPRM as part
of the agency’s ongoing effort to
harmonize vehicle safety standards
under the Economic Commission for
Europe 1998 Global Agreement (‘‘1998
Agreement’’). The efforts of the U.S. and
other contracting parties to the 1998
Agreement culminated in the
establishment of GTR No. 13,
‘‘Hydrogen and fuel cell vehicles.’’
NHTSA voted in June 2013 in favor of
establishing GTR No. 13. In this NPRM,
we are proposing requirements based on
the electrical safety requirements of
GTR No. 13. NHTSA will initiate
rulemaking in the future on other
aspects of GTR No. 13 directly
pertaining to the fuel system integrity of
hydrogen fuel cell vehicles.
One purpose of FMVSS No. 305 is to
reduce deaths and injuries from
electrical shock. The standard requires
vehicles with high voltage sources to
meet certain performance criteria to
protect vehicle occupants, rescue
workers and others who may come in
contact with the vehicle after a crash.
Among other things, FMVSS No. 305
requires that after a crash, high voltage
sources in a vehicle are either (a)
electrically isolated from the vehicle’s
chassis or (b) their voltage is below
specified levels considered safe from
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electric shock hazards. Since the
physiological impacts of direct current
(DC) are less than those of alternating
current (AC), the standard specifies
lower minimum electrical isolation
requirements for certain DC components
(100 ohms/volt) than for AC
components (500 ohms/volt).
GTR No. 13 also has requirements
intended to reduce deaths and injuries
from electrical shock. Unlike FMVSS
No. 305, GTR No. 13 has requirements
that reduce the risk of harmful electric
shock during normal vehicle operation.
This NPRM proposes to adopt those
requirements to expand FMVSS No.
305’s performance requirements beyond
post-crash conditions. In addition,
while the various post-crash compliance
options in GTR No. 13 are similar to
those in FMVSS No. 305, GTR No. 13
includes a compliance option for
electrical vehicle safety that prevents
direct and indirect contact of high
voltage sources by way of ‘‘physical
barriers.’’ NHTSA is now proposing to
amend FMVSS No. 305 to permit a
physical barrier compliance option.1
NHTSA tentatively believes that the
by-product of adopting a physical
barrier option would be more than
harmonizing vehicle standards.
Enhanced design innovation, reduced
CO2 emissions and increased fuel
economy would likely result. This
proposal would facilitate the
introduction of 48 volt mild hybrid
technologies and hydrogen fuel cell
vehicles, and responds not only to GTR
No. 13 but also to petitions for
rulemaking from Toyota and the
Alliance.
Petitioner Toyota believes that an
additional compliance option that
includes elements of the physical
barrier option in GTR No. 13 is needed
to allow hydrogen fuel cell vehicles
(HFCVs) to be offered for sale in the
U.S.2 HFCVs and other electric powered
1 Our proposed physical barrier option varies
slightly from GTR No. 13. GTR No. 13 provides
contracting parties discretion in whether to propose
the option in their domestic regulatory process. In
our proposal today, we are not proposing to adopt
GTR No. 13’s physical barrier option. However, as
further discussed, below, we are adopting a
modified physical barrier option that we believe
will also afford the compliance flexibility that GTR
No. 13 seeks to provide, while at the same time
providing a level of safety closer to the other postcrash compliance options. A small number of minor
additional provisions are proposed as well. These
additional provisions would not significantly alter
our incorporation of GTR No. 13 and are consistent
with the goal of incorporating a standard that is
harmonized with other international standards.
2 Subsequent to its submission of the petition for
rulemaking, Toyota submitted and was granted a
temporary exemption from FMVSS No. 305 for an
HFCV (see grant of petition, January 2, 2015 (80 FR
101)). Toyota incorporates electrical protection
barriers (conductively connected to the electric
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vehicles operate with their DC high
voltage sources (e.g. high voltage
battery) connected to the AC high
voltage sources (e.g. electric motor). In
a moderate to severe crash (e.g., crash
speeds at which an air bag would
deploy), electric powered vehicles are
generally designed with an automatic
disconnect mechanism that activates
and breaks the conductive link between
the electrical energy storage system and
the rest of the power train. Under these
crash conditions in which an automatic
disconnect mechanism activates, Toyota
states that its HFCVs would be able to
meet the electrical safety requirements
of FMVSS No. 305. However, in low
speed crashes where the automatic
disconnect mechanism is not designed
to activate so that the vehicle can be
driven away after a minor crash (fenderbender), Toyota states that its HFCVs
would not be able to meet the electrical
safety requirements in FMVSS No. 305.
The petitioner believes that the
additional compliance option requested
in its petition would solve this problem
and would not cause any reduction in
the level of electrical safety now
required by FMVSS No. 305.
Petitioner Alliance requests a physical
barrier compliance option to facilitate
the production of 48 volt mild hybrid
technologies as well as hydrogen fuel
cell vehicles. The petitioner asks
NHTSA to amend FMVSS No. 305 to
adopt a physical barrier option
incorporated in the Society of
Automotive Engineers (SAE) J1766 Jan
2014,3 section 5.3.4, for 48 volt mild
hybrid systems. The Alliance believes
that the provisions for physical barriers
in section 5.3.4 incorporate the
requirements of GTR No. 13 and provide
for physical barriers that ensure equal
levels of safety as that afforded by the
current FMVSS No. 305 electrical safety
requirements.
The petitioner states that while
vehicles with 48 volt mild hybrid
systems use mostly low-voltage
components that do not present any
danger of harmful electric shock, AC
voltage sources contained within the
system can exceed the 30 volt threshold
in FMVSS No. 305 for consideration as
a high voltage source. Since these
systems are grounded to the vehicle
chassis, they cannot meet FMVSS No.
chassis with low resistance) and maintains at least
a 100 ohms/volt electrical isolation into their
design. NHTSA granted the petition for exemption
on the basis that the exemption would make the
development or field evaluation of a low emission
(zero emission) vehicle easier and would not
unreasonably reduce the safety of the vehicle.
3 SAE J1766, ‘‘Recommended practice for electric,
fuel cell, and hybrid electric vehicle crash integrity
testing,’’ January 2014, SAE International, https://
www.sae.org.
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305’s existing electrical isolation option.
The petitioner states that while it is
feasible to design a 48 volt mild hybrid
system that is isolated from the chassis
and meets FMVSS No. 305’s electrical
isolation requirements, such designs
involve more complexity, higher
consumer costs, and higher mass
resulting in reduced fuel economy and
increased emissions. The petitioner
believes that these penalties are
inappropriate when there would be no
incremental safety benefit gained
beyond that associated with SAE J1766’s
physical barrier option.
NHTSA has undertaken this
rulemaking after carefully and
extensively examining the safety issues.
The agency previously decided against
consideration of a physical barrier
option earlier in the history of FMVSS
No. 305, when our knowledge about the
option was limited.4 Commenters to an
NPRM to upgrade electrical shock
protection requirements had asked
NHTSA to adopt the option in the final
rule, for reasons similar to those
provided by petitioners Toyota and the
Alliance. NHTSA declined, citing
concerns about the lack of notice for the
provision, the absence of developed test
procedures to ensure protection from
indirect contact, and uncertainty as to
whether the option would sufficiently
account for indirect contact failure
modes. NHTSA then decided to
undertake a research program (later
known as the Battelle study, discussed
below in this preamble) to better
understand the issues related to a
physical barrier option for electrical
safety.
Since that decision in 2010, a number
of developments led to today’s proposal.
GTR No. 13 was established, a product
of shared data and knowledge from
governing bodies and international
experts around the world. The Battelle
study was completed and the physical
barrier countermeasure design was
made more robust in response to its
findings, with SAE revising J1766 in
January 2014 to set forth more
protective safety practices than it had
before to address remote albeit lingering
concerns. Importantly, there have now
been years of worldwide recognition of
the physical barrier option as an
acceptable means of providing electrical
safety in electric powered vehicles, with
years of experience in design labs and
in the field showing no evidence of
associated safety problems. HFCVs, 48
volt mild hybrid technologies, and other
vehicle designs have become a reality,
4 See final rule, 75 FR 33515, June 14, 2010;
response to petitions for reconsideration, 76 FR
45436, July 29, 2011.
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and with them abundant potential for
the development of electrical
technologies that a physical barrier
option in FMVSS No. 305 can facilitate,
expedite and safeguard.
We estimate that adopting this NPRM
would come at essentially no cost to
consumers in the U.S. This proposal
closely mirrors the electrical safety
provisions of GTR No. 13, which have
been implemented by manufacturers in
this country.
NHTSA believes that this NPRM
would improve the level of safety
afforded to the public. Adopting the
provisions from GTR No. 13 that reduce
the risk of harmful electric shock during
normal vehicle operation would
improve FMVSS No. 305 by expanding
its performance requirements beyond
post-crash conditions. The proposed
requirements would provide post-crash
compliance options for new power train
configurations that ensure that those
configurations provide a comparable
level of post-crash safety compared to
existing electric vehicles.
Summary of Proposal
The proposed amendments are
summarized as follows. In furtherance
of implementing GTR No. 13 and in
response to the petitions for
rulemaking—
a. This NPRM proposes to add
electrical safety requirements for vehicle
performance during everyday
(‘‘normal’’) vehicle operations (as
opposed to during and after a crash), to
mitigate electric shock due to loss in
electrical isolation and direct or indirect
contact of high voltage sources. The
electrical safety requirements during
normal vehicle operations would
include requirements for:
1. Direct contact protection from high
voltage sources
i. IPXXD protection level 5 for high voltage
sources inside passenger and luggage
compartments. IPXXB protection level for
high voltage sources not in passenger and
luggage compartments.
ii. IPXXB protection level for service
disconnect that can be opened or removed
without tools.
iii. Markings on barriers of high voltage
sources that can be physically accessed,
opened, or removed without the use of tools.
5 IPXXB and IPXXD ‘‘protection levels’’ refer to
the ability of the physical barriers to prevent
entrance of a probe into the enclosure, to ensure no
direct contact with high voltage sources. ‘‘IPXXB’’
is a probe representing a small human finger.
‘‘IPXXD’’ is a slender wire probe. Protection degrees
IPXXD and IPXXB are International
Electrotechnical Commission specifications for
protection from direct contact of high voltage
sources.
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iv. Orange color outer covering for cables
of high voltage sources that are located
outside electrical protection barriers.6
2. Indirect contact protection from
high voltage sources
Exposed conductive parts of electrical
protection barriers would have to be
conductively connected to the chassis with a
resistance less than 0.1 ohms, and the
resistance between two simultaneously
reachable exposed conductive parts of
electrical protection barriers that are within
2.5 meters of each other would have to be
less than 0.2 ohms.
3. Electrical isolation of high voltage
sources
i. 500 ohms/volt or higher electrical
isolation for AC high voltage sources and 100
ohms/volt or higher for DC high voltage
sources.
ii. For conditions where AC and DC bus are
connected, AC high voltage sources would be
permitted to have electrical isolation of 100
ohms/volt or higher, provided they also have
the direct and indirect contact protection
described in 1 and 2, above.
iii. There would be an exclusion of 48 volt
hybrid vehicles from electrical isolation
requirements during normal vehicle
operation.
4. Electrical isolation monitoring
system for DC high voltage sources on
fuel cell vehicles.
5. Electrical safety during charging
involving connecting the vehicle to an
external electric power supply:
i. Minimum electrical isolation resistance
of one million ohm of the coupling system
for charging the electrical energy storage
system; and
ii. Conductive connection of the electric
chassis to earth ground before and during
exterior voltage is applied.
6. Mitigating driver error by—
i. Requiring an indication to the driver
when the vehicle is in active driving mode
upon vehicle start up and when the driver is
leaving the vehicle; and,
ii. Preventing vehicle movement by its own
propulsion system when the vehicle charging
system is connected to the external electric
power supply.
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b. This NPRM also proposes to amend
FMVSS No. 305’s post-crash electrical
safety requirements. The proposed postcrash electrical safety requirements
include:
1. Adding an additional optional method of
meeting post-crash electrical safety
requirements through physical barrier
protection from high voltage sources. The
proposed specifications of this optional
method of electric safety include
requirements ensuring that:
6 An electrical protection barrier is defined in
GTR No. 13 as the part providing protection from
direct contact with high voltage sources from any
direction of access. These may be physical barriers
that enclose high voltage sources.
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i. High voltage sources would be enclosed
in barriers that prevent direct human contact
with high voltage sources (IPXXB protection
level),
ii. Exposed conductive parts of electrical
protection barriers would be conductively
connected to the chassis with a resistance
less than 0.1 ohms, and the resistance
between any two simultaneously reachable
exposed conductive parts of electrical
protection barriers that are less than 2.5
meters from each other would be less than
0.2 ohms, and
iii. Voltage between a barrier and other
exposed conductive parts of the vehicle
would be at a low voltage level that would
not cause electric shock (less than 60 VDC 7
or 30 VAC).
2. Permitting an AC high voltage source
that is conductively connected to a DC high
voltage source to meet lower minimum
electrical isolation requirement of 100 ohms/
volt, provided the AC high voltage source
also has physical barrier protection specified
in 1, above.
II. FMVSS No. 305
FMVSS No. 305 currently establishes
requirements to reduce deaths and
injuries during and after a crash that
occurs because of electrolyte spillage
from electric energy storage devices,
intrusion of electric energy storage/
conversion device into the occupant
compartment, and electrical shock.
Among other things, FMVSS No. 305
requires that during and after the crash
tests specified in the standard, high
voltage sources in the vehicle must be
either (a) electrically isolated from the
vehicle’s chassis,8 or (b) their voltage is
below specified levels considered safe
from electric shock hazards.9
Many of these electrical shock
protection requirements were
established by a June 14, 2010 final rule
(75 FR 33515) that revised the standard
to align it more closely with the April
2005 version of SAE J1766. Commenters
to the NPRM preceding the June 14,
2010 final rule (viz., the Alliance and
Global Automakers) requested another
electrical safety compliance option,
called the ‘‘physical barrier option,’’ for
providing greater flexibility to allow
7 VDC is the voltage for direct current sources and
VAC is voltage for alternating current sources.
8 Under this electrical isolation option, since the
physiological impacts of DC are less than those of
AC, the standard permits DC high voltage sources
with an electrical isolation monitoring system to
have lower minimum electrical isolation (100
ohms/volt) than the 500 ohms/volt required for AC
high voltage sources. This level of electrical
isolation limits the current that could pass through
a human body (that is in contact with the vehicle)
to no more than 10 milliamperes (mA) DC or 2 mA
AC. These levels are considered to be safe levels of
current and would not cause any tissue damage, or
fibrillation.
9 Under this low voltage option, electrical
components are considered to be low voltage and
safe from electric shock hazard if their voltage is
less than or equal to 60 VDC or 30 VAC.
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introduction of advanced power train
technologies. In the physical barrier
option, high voltage sources are
enclosed in physical barriers (electrical
protection barriers) that do not permit
entrance of a finger probe into the
enclosure after the crash test to ensure
no direct contact with high voltage
sources. This option also requires the
physical barriers to be conductively
connected to the electric chassis to
ensure no electric shock due to indirect
contact in the event of loss in isolation
of a high voltage source.
In the June 14, 2010 final rule,
NHTSA declined to adopt the physical
barrier option, citing concerns about the
sufficiency of notice provided for the
provision, the absence of developed test
procedures to ensure protection from
indirect contact, and uncertainty as to
whether the option would sufficiently
account for indirect contact failure
modes. NHTSA stated that it would
undertake a research program (the
Battelle study) to better understand the
issues related to a physical barrier
option for electrical safety.
III. The Global Technical Regulation
a. Overview of the Process
The United States is a contracting
party to the ‘‘1998 Agreement’’ (the
Agreement concerning the Establishing
of Global Technical Regulations for
Wheeled Vehicles, Equipment and Parts
which can be fitted and/or be used on
Wheeled Vehicles). This agreement
entered into force in 2000 and is
administered by the UN Economic
Commission for Europe’s (UN ECE’s)
World Forum for the Harmonization of
Vehicle Regulations (WP.29). The
purpose of this agreement is to establish
Global Technical Regulations (GTRs).
GTR No. 13, ‘‘Hydrogen fuel cell
vehicles,’’ addresses hydrogen fuel cell
vehicle technology. NHTSA closely
collaborated with experts from
contracting parties to the 1998
Agreement, particularly Germany and
Japan, to develop a GTR for hydrogen
fueled vehicles that would establish
levels of safety that are equivalent to or
exceeds those for conventional gasoline
fueled vehicles. The collaborative effort
in this process led to the establishment
of GTR No. 13 in June 2013.
The U.S. voted on June 27, 2013 in
favor of establishing GTR No. 13. In
voting yes to establishing the GTR,
NHTSA is obligated to ‘‘submit the
technical Regulation to the process’’
used in the U.S. to adopt the
requirement into our law or regulation.
By issuance of this NPRM, NHTSA is
initiating the process for considering
adoption of GTR No. 13.
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Under the terms of the 1998
Agreement, NHTSA is not obligated to
adopt the GTR after initiating this
process. In deciding whether to adopt a
GTR as an FMVSS, we follow the
requirements for NHTSA rulemaking,
including the Administrative Procedure
Act, the National Highway and Motor
Vehicle Safety Act (Vehicle Safety Act),
Presidential Executive Orders, and DOT
and NHTSA policies, procedures and
regulations. Among other things,
FMVSSs issued under the Vehicle
Safety Act ‘‘shall be practicable, meet
the need for motor vehicle safety, and be
stated in objective terms.’’ 49 U.S.C.
30111.
This NPRM does not propose the
entirety of GTR No. 13 at this time. This
document only addresses the electrical
safety requirements in GTR No. 13 (i.e.,
the electrical isolation requirements,
physical barrier requirements, etc.). GTR
No. 13 also addresses hydrogen fuel
system and fuel container integrity
requirements and the agency’s plan is to
issue a separate proposal to seek
comment on incorporating those
portions of GTR No. 13 into the relevant
FMVSSs.
The fuel cell provides DC power
while the drive motors typically operate
on AC. Therefore, the power train has:
(a) Inverters to convert DC power to AC
to run the motors and (b) converters to
convert AC power generated in the drive
motor during regenerative braking to DC
to store energy in the batteries. In many
respects, the electric power train of an
HFCV is similar to that of electric and
hybrid electric vehicles. GTR No. 13, in
part, specifies electrical safety
requirements during normal vehicle
operation and after a crash test, to
protect against electric shock in the
event of a failure in the high voltage
propulsion system.
In general, the portions of GTR No. 13
that are relevant to this rulemaking are
the electric safety requirements
intended to protect against the potential
for electric shock during (a) normal
vehicle operation, and (b) after a crash.
We discuss these requirements in GTR
No. 13 in the sections below.
12651
prevent indirect contact of high voltage
sources; (3) electrically isolate the high
voltage sources from the electric chassis
(500 ohms/volt or higher for AC and 100
ohms/volt or higher for DC sources); and
(4) electrical isolation monitoring
system for HFCVs that warns the driver
in the event of loss in isolation.
The GTR also has the following
measures to reduce driver errors that
may result in potential unsafe
conditions: (1) Indication to the driver
when the vehicle is in possible active
driving mode at startup and when the
driver is leaving the vehicle, and (2)
prevent vehicle movement by its own
propulsion system when the vehicle
charging system is connected to the
external electric power supply.
Protection Against Direct Contact With
High Voltage Sources
For high voltage sources not in
passenger or luggage compartments,12
the GTR requires that they be enclosed
in protection systems such as solid
insulators, electrical protection barriers,
and enclosures that cannot be opened,
disassembled, or removed without the
use of tools, and that provide a
protection degree of IPXXB (as opposed
to IPXXD, referenced above). Protection
degree IPXXB is an IEC specification for
protection from direct contact of high
10 In other words, the focus of this ‘‘in-use’’
testing (unlike ‘‘post-crash’’ testing, discussed later)
deals with performance criteria that would be
assessed without first exposing the vehicle to a
crash test. This testing is aimed at evaluating what
the performance of the vehicle would be under
normal operating conditions.
11 IEC60529 Second edition 1989–11 + Am. 1
1999–11, EN60529, ‘‘Degrees of protection provided
by enclosures.’’
12 GTR No. 13 specifies direct contact protection
requirements for high voltage connectors (including
vehicle inlet) separately.
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b. Overview of GTR No. 13
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1. Electric Safety Requirements During
Normal Vehicle Operation
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Hydrogen fueled fuel cell vehicles
have an electric drive-train powered by
a fuel cell that generates electric power
electrochemically using hydrogen. The
hydrogen is electrochemically combined
with oxygen (from air) within the fuel
cell system to produce high-voltage
electric power. The electric power is
supplied to the electric drive motors
and/or used to charge batteries and
capacitors. HFCVs may also be
equipped with batteries to supplement
the output of fuel cells and may also
recapture energy during stopping
through regenerative braking, which
recharges batteries and thereby
improves efficiency.
These performance requirements in
GTR No. 13 are requirements intended
for protecting vehicle occupants (and
others that may interact with the
vehicle) against electric shock during
normal vehicle operation.10 For the
purposes of the GTR, normal vehicle
operations include those during driving
and charging.
The GTR requirements apply to all
high voltage sources (electric
components contained or connected to
the electric power train that have a
working voltage greater than 30 VAC or
60 VDC). It requires these high voltage
sources to have all four of the following
measures to protect against electric
shock during normal vehicle operations:
(1) Prevent direct contact of high voltage
sources (those operating with voltage
greater than 30 VAC or 60 VDC); (2)
For protection against direct contact
with high voltage sources, the GTR has
different requirements based on the
location of the high voltage source (i.e.,
if it is in the passenger or luggage
compartment of the vehicle or not).
The GTR requires high voltage
sources inside the passenger
compartment or luggage compartment to
be enclosed in protection systems such
as solid insulators, electrical protection
barriers, and enclosures that cannot be
opened, disassembled, or removed
without the use of tools and that
provide protection degree IPXXD.
Protection degree IPXXD is an
International Electrotechnical
Commission (IEC) specification for
protection from direct contact of high
voltage sources. IPXXD protection is
verified when a standard probe (rigid
test wire shown in Figure 1), 100
millimeters (mm) long and 1 millimeter
(mm) in diameter, does not contact high
voltage components when probed to
enter an electrical protection barrier or
enclosure.11
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protection barrier or enclosure.13 (See
Figure 2 below.)
In addition to barriers preventing
direct physical contact with high
voltage sources, GTR No. 13 also
requires protections for the ‘‘service
disconnect.’’ 14 These provisions protect
emergency personnel, persons
performing service/maintenance on the
vehicle, and vehicle occupants. The
GTR requires that a service disconnect
(which can be opened, disassembled or
removed without tools) be enclosed by
protection systems with protection
degree IPXXB when the service
disconnect is opened, disassembled, or
removed.
Further, the GTR requires that high
voltage sources be labeled using the
symbol shown in Figure 3, below. The
interior of the symbol is yellow and the
border and arrow symbol are black. This
requirement aims to provide a
standardized warning regarding the
presence of high voltage sources within
an enclosure that can be physically
accessed, opened or removed without
the use of tools. The GTR specifies that
the labels need to be on or near electric
energy storage/conversion devices and
on electrical protection barriers or
enclosures of high voltage sources that
can be physically accessed, opened, or
removed without the use of tools and
that are not located underneath the
vehicle floor. For connecters of high
voltage sources, the GTR makes this
requirement optional.
In the same vein, the GTR requires
cables to have a standardized warning
that high voltage cables are present. The
GTR requires that cables for high voltage
sources, which are not located within
enclosures, must have an orange outer
covering for identification.
Indirect contact of high voltage
sources 15 may occur when a high
voltage source experiences a loss in
electrical isolation and the physical
barrier or enclosure gets electrically
energized. This type of contact could
also lead to electrical shock. To address
this concern, the GTR requires, first,
that exposed conductive parts (parts
which may become electrically
energized under electrical isolation
failure and which can be contacted by
a human, such as electrical protection
barriers and enclosures) be conductively
connected to the electrical chassis such
that the resistance between all exposed
conductive parts and the electrical
chassis is less than 0.1 ohms when there
is current flow of at least 0.2 amperes
(A).16 This would ensure that in the
event of loss in electrical isolation, no
dangerous voltage potentials are
produced between exposed conductive
parts and the electrical chassis, and
therefore very low levels of current
would flow through a human body
contacting different parts of the
vehicle.17
Second, GTR No. 13 requires that
vehicles whose rechargeable energy
storage systems are charged by
conductively connecting to an external
grounded electric power supply have a
device that conductively connects the
electrical chassis to the earth ground
during charging. This ensures that if
there is a loss in electrical isolation of
a high voltage source during charging
and the vehicle chassis is contacted by
a human, the magnitude of current
13 IEC60529 Second edition 1989–11 + Am. 1
1999–11, EN60529, ‘‘Degrees of protection provided
by enclosures.’’ This test probe designed to simulate
a small human finger (12 mm) conforms to ISO
20653 ‘‘Road vehicles—Degrees of protection (IPCode)—Protection of electrical equipment against
foreign objects, water, and access (IPXXB).’’
14 A service disconnect is a device for
deactivation of an electrical circuit when
conducting checks and services of the electric
battery, fuel cell stack, or other high voltage
sources.
15 Contact of a conductive part which is energized
due to loss in electrical isolation of a high voltage
source is an indirect contact of the high voltage
source.
16 GTR No. 13 considers this requirement to be
met if visual inspection indicates that a conductive
connection has been established by welding.
NHTSA has concerns about this provision and is
requesting comments on it.
17 Since current flows through the path of least
resistance, most of the current flow would be
through the chassis rather than through the human
body which has a significantly higher resistance.
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Protection Against Indirect Contact
With High Voltage Sources
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mm long and 12 mm in diameter, does
not contact high voltage components
when probed to enter an electrical
EP10MR16.001
voltage sources. IPXXB protection is
verified when a standard probe
(resembling a small human finger), 80
Federal Register / Vol. 81, No. 47 / Thursday, March 10, 2016 / Proposed Rules
flowing through the person is very low
and in the safe zone.18
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Protection by Electrical Isolation
GTR No. 13 affords different electrical
isolation requirements for AC and DC
high voltage sources based on whether
they are conductively isolated from each
other or conductively linked together.
For AC and DC high voltage sources
that are conductively isolated from each
other, GTR No. 13 requires isolation
resistance between the high voltage
source and the electrical chassis to be a
minimum value of 100 ohms/volt of the
working voltage for DC high voltage
sources, and a minimum value of 500
ohms/volt of the working voltage for AC
high voltage sources. This requirement
is similar to the post-crash electrical
isolation requirement currently in
FMVSS No. 305. It ensures that in the
event high voltage sources are
contacted, the current flowing through
the body is less than or equal to 10 mA
DC or 2 mA AC—which is considered
to be safe.19
For AC and DC high voltage sources
that are conductively connected, GTR
No. 13 affords two options. The first
option is the vehicle may maintain an
isolation resistance between the high
voltage sources and the electrical
chassis at no less than 500 ohms/volt of
the working voltage. The second option
is it may provide an isolation resistance
between the high voltage sources and
the electrical chassis of no less than 100
ohms/volt of the working voltage and
provide physical barrier protection for
the AC high voltage sources to prevent
both direct and indirect contact, as
discussed above. (Note that a ‘‘physical
barrier’’ approach would be a new
concept in FMVSS No. 305.)
In addition, GTR No. 13 specifies
electrical isolation requirements for
charging electric vehicles whose
rechargeable energy storage system are
charged by conductively connecting to
an external power supply. GTR No. 13
requires that the isolation resistance
between the electrical chassis and high
voltage sources conductively connected
to the vehicle inlet which connects to
the external power supply to be at least
1 million (M) ohms when the charge
coupler is disconnected. This
requirement is in accordance with
18 Current will flow through the path of least
resistance and therefore most of the current
resulting from a loss of electrical isolation would
flow through the ground connection rather than
through the human body.
19 See IEC TS 60479–1 and TS 60479–2 Effects of
Current on Human Beings and Livestock—Part 1:
General Aspects, 2005–07, Reference Nos. CEI/IEC/
TS 60479–1:2005.
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IEC61851–1–2010 20 and International
Standards Organization (ISO) 6469–2 21
which prescribe electrical isolation for
electric vehicles that connect to the
power grid for charging. A typical
minimum allowable isolation
requirement for a grounded product
connected to the power grid is 1000
ohms/volt, which computes to 1M
ohms.
Protection by Electrical Isolation
Monitoring System
GTR No. 13 also contains provisions
for monitoring the electrical isolation
under certain conditions. In fuel cell
vehicles, GTR No. 13 requires DC high
voltage sources (other than the coupling
system for charging) to have an on-board
electrical isolation monitoring system,
together with a warning to the driver if
the isolation resistance drops below the
minimum required value of 100 ohms/
volt. FMVSS No. 305 specifies a similar
requirement except that FMVSS No. 305
applies this provision to vehicles that
are certified to the 100 ohms/volt
electrical isolation option 22 (rather than
to fuel cell vehicles specifically).
Protection by Mitigating Driver Error
GTR No. 13 also has provisions for
mitigating the likelihood of driver error
in operating electric vehicles. First, GTR
No. 13 requires that at least a
momentary indication be given to the
driver when the vehicle is in possible
active driving mode.23 Second, when
leaving the vehicle, the driver shall be
informed by an optical or audible signal
if the vehicle is still in possible active
driving mode. The third requirement is
that for vehicles where the on-board
rechargeable energy storage/conversion
device can be charged externally,
vehicle movement by its own
propulsion system shall not be possible
when the external electric power supply
is physically connected to the vehicle
inlet.
20 IEC 61851–1:2010 Electric vehicle conductive
charging system—Part 1: General requirements,
available at https://webstore.iec.ch/publication/
6029.
21 ISO 6469–2:2009 Electrically propelled road
vehicles—Safety specifications—Part 2: Vehicle
operational safety means and protection against
failures. Available at https://www.iso.org/iso/
catalogue_detail?csnumber=45478.
22 As discussed above, AC high voltage sources
are required under FMVSS No. 305 to have at least
500 ohms/volt of electrical isolation. DC high
voltage sources may have an electrical isolation of
100 ohms/volt or greater provided that they meet
conditions such as having an electrical isolation
monitoring system meeting the requirements of the
standard.
23 I.e., the vehicle mode when application of
pressure to the accelerator pedal or release of the
brake system causes the electric power train to
move the vehicle.
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12653
The first requirement does not apply
to vehicles with an internal combustion
engine that directly or indirectly
provides the vehicle’s propulsion on
startup. Since electric powered vehicles
operate quietly, an indication of the
vehicle in possible active driving mode
would assist the driver in reducing
operational errors that could have safety
implications. The third requirement
prevents the charger from getting ripped
out of the vehicle inlet during charging
that could cause electrical arcing.
2. Electric Safety Requirements PostCrash Test
The post-crash 24 electrical safety
requirements in GTR No. 13 apply to all
high voltage sources (electric
components contained or connected to
the electric power train that have a
working voltage greater than 30 VAC or
60 VDC). GTR No. 13 does not specify
the type of crash test and how it is
conducted. This is left to each
contracting party to develop appropriate
crash tests. After the crash test, to
provide adequate protection against
electric shock, GTR No. 13 affords three
potential options that a vehicle
manufacturer may use to protect against
potential human contact with high
voltage sources. GTR No. 13 specifically
gives contracting parties the choice not
to provide the physical barrier option in
their final domestic regulation.
Reduce the Voltage Levels of the High
Voltage Sources Such That They Are No
Longer High Voltage Sources
Reducing the high voltage sources’
voltage to a level below what is
considered a ‘‘high voltage source’’
means there is no further need to protect
against electrical shock from those
sources. Thus, in this option, GTR No.
13 requires that the voltages of each
high voltage source be reduced to less
than or equal to 30 VAC or 60 VDC
within 60 seconds after the impact. A
version of this option for electrical
safety is currently in FMVSS No. 305.
Use a Physical Barrier and Other
Techniques To Prevent Direct/Indirect
Contact 25 With High Voltage Sources
The physical barrier option protects
against electrical shock by preventing
24 In terms of ‘‘post-crash’’ we are referring to
assessing a vehicle’s electrical safety provisions
(electrical isolation, physical barrier, etc.) after the
vehicle is exposed to specified crash forces in a
crash test. This is different from the aforementioned
‘‘in-use’’ (or ‘‘normal operating conditions’’)
requirements where the vehicle is evaluated for
conformance with a performance requirement
without first being exposed to crash testing.
25 To reiterate, this option is one that contracting
parties may choose not to propose. In other words,
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any human contact (direct or indirect)
with the high voltage sources. The
physical barrier option for post-crash is
similar to the physical barrier option
that GTR No. 13 affords for its normal
vehicle operation requirement. The
requirements state that (post-crash) the
vehicle needs to prevent both direct and
indirect human contact with high
voltage sources through the use of: (1)
Physical barriers (i.e., prevent a finger
probe test device from contacting any
high voltage source); and (2) low
resistance conductive connection of the
physical barriers to the electrical chassis
(i.e., the resistance between all exposed
conductive parts and the electrical
chassis has to be less than 0.1 ohms
when there is a current flow of at least
0.2 A 26). The only major difference is
that GTR No. 13 uses protection degree
IPXXB (i.e., the IPXXB finger probe) for
its post-crash requirements (rather than
IPXXD).27 As noted earlier, FMVSS No.
305 currently contains no similar
provision for electric shock protection
through physical barriers.
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Electrically Isolate the High Voltage
Sources
This option protects against electric
shock by ensuring that a sufficient level
of electrical isolation resistance is
provided for the high voltage source.
GTR No. 13 provides two different sets
of requirements (based on whether the
vehicle’s AC and DC high voltage
sources are conductively connected) for
vehicles electing to use this option to
protect against electric shock.
If the AC and DC high voltage sources
are conductively isolated from each
other, then the minimum electrical
isolation of a high voltage source to the
chassis is 500 ohms/volt for AC
components and 100 ohms/volt for DC
components of the working voltage.
If AC and DC high voltage sources are
conductively connected, GTR No. 13
requires that electrical isolation of AC
and DC high voltage sources be no less
than 500 ohms/volt of the working
voltage, or the electric isolation of those
sources be no less than 100 ohms/volt
a contracting party that voted in favor of this GTR
may submit this GTR to their domestic rulemaking
process affording only two options for protecting
against post-crash electrical shock (i.e., reducing the
high voltage sources’ voltage so that they are no
longer considered high voltage; and maintaining the
required levels of electrical isolation of the high
voltage sources).
26 GTR No. 13 considers this requirement to be
met if visual inspection indicates that conductive
connection has been established by welding. The
minimum resistance requirement is only evaluated
in case of doubt.
27 Here the post-crash requirements in the GTR
use IPXXB because it is assumed unlikely that,
post-crash, someone would use a wire to probe the
enclosure.
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provided that the AC high voltage
sources (in addition to the minimum
100 ohms/volt electrical isolation) meet
the reduced voltage level requirements
discussed above (first option), or meet
the physical protection requirements
discussed above in the second option.
We note that while currently FMVSS
No. 305 contains different requirements
for AC high voltage sources and DC high
voltage sources, it does not distinguish
requirements based on whether the AC
and DC high voltage sources are
conductively linked. Thus, while the
requirements in GTR No. 13 for AC and
DC sources that are not conductively
connected are the same as those
currently in FMVSS No. 305, the
alternative requirements for
conductively connected AC and DC
sources are not.
c. How does this proposal differ from
GTR No. 13?
This NPRM proposes to add electrical
safety requirements during normal
vehicle operation in GTR No. 13 into
FMVSS No. 305. The proposal also adds
a modified version of physical barrier
protection that is specified in GTR No.
13 as a compliance option for meeting
post-crash electrical safety
requirements. However, this NPRM does
not propose to adopt all the
specifications in GTR No. 13. The
differences in electrical safety
requirements and associated test
procedures in the proposal and that in
GTR No. 13, along with an explanation
for these differences, are provided
below. Comments are requested on
NHTSA’s views.
Physical Barrier Protection During
Normal Vehicle Operation
This NPRM proposes to adopt GTR
No. 13’s physical barrier protection
requirement during normal vehicle
operation for direct contact. However,
for indirect contact protection, we
propose to use the proposed post-crash
indirect contact protection requirements
described above (which include two
additional requirements described
above in addition to that specified in
GTR No. 13).
Verification of Physical Barrier
Protection During Normal Vehicle
Operations
GTR No. 13 considers indirect contact
protection requirements during normal
vehicle operations to be met if a
galvanic connection 28 has been
established by welding between
28 A galvanic connection is a conductive
connection.
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exposed conductive parts and the
electrical chassis.
For conditions where the DC and AC
high voltage sources are connected
during normal vehicle operations, GTR
No. 13 permits the AC high voltage
sources to have a minimum electrical
isolation of 100 ohms/volt provided the
AC high voltage sources have either: (a)
Double or more layers of solid insulators
or electrical protection barriers that
meet the requirements for indirect
contact protection; or (b) Mechanically
robust protections that have sufficient
durability over vehicle service life such
as motor housings, electronic converter
cases or connectors.
These methods of verification consist
of mere visual inspection and do not
provide sufficient objectivity for use in
an FMVSS. Therefore, the agency’s
proposal does not consider indirect
contact protection requirements to be
met if galvanic connection has been
established between exposed
conductive parts and the electric
chassis. The agency is also not
proposing visual inspection methods to
permit AC high voltage sources that are
connected to a DC high voltage source
to have minimum electrical isolation of
100 ohms/volt during normal vehicle
operation.
High Voltage Markings
GTR No. 13 requires marking (yellow
high voltage symbol) for enclosures and
barriers of high voltage sources
(electrical protection barriers) that can
be physically accessed, opened, or
removed without the use of tools. These
markings are not required for electrical
protection barriers located underneath
the vehicle floor.
NHTSA tentatively concludes that the
exclusion is without merit. GTR No. 13
does not provide a justification for
exempting electrical protection barriers
located underneath the vehicle floor
from the high voltage marking
requirement. There is also no definition
of ‘‘vehicle floor’’ in GTR No. 13.
NHTSA does not believe electrical
protection barriers located under the
vehicle floor should be excluded
because it is possible that the high
voltage sources enclosed by these
barriers may be accessed in a rollover
crash or during vehicle maintenance.
Direct Contact Protection of Connectors
GTR No. 13 specifies direct contact
protection requirements for high voltage
connectors separately. Per GTR No. 13,
connectors do not need to meet IPXXB
protection if they are located
underneath the vehicle floor and are
provided with a locking mechanism, or
require the use of tools to separate the
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connector, or the voltage reduces to
below 30 VAC or 60 VDC within one
second after the connector is separated.
NHTSA does not believe connectors of
high voltage sources should be
excluded. If connectors are high voltage
sources and if they can be accessed,
opened, or removed without the use of
tools, regardless of whether they are
located under the floor, they should be
required to meet the same requirements
for voltage markings and direct contact
protection as electric protection barriers.
Additionally, the agency notes that
‘‘vehicle floor’’ and ‘‘connector’’ are not
defined in GTR No. 13. Therefore,
NHTSA would not exclude connectors
of high voltage sources.
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Post-Crash Physical Barrier Protection
Option
GTR No. 13 specifies that individual
contracting parties of the 1998
agreement may elect to propose the
physical barrier protection from direct
and indirect contact of high voltage
sources and live parts. According to
GTR No. 13, for protection against direct
contact, high voltage sources and live
parts are required to have protection
degree IPXXB. For protection against
indirect contact, GTR No. 13 requires
that the resistance between all exposed
conductive parts and electrical chassis
be lower than 0.1 ohm when there is
current flow of at least 0.2 A.
The physical barrier protection option
in this NPRM includes the same
provisions for direct and indirect
contact protection as that in GTR No. 13
but adds two additional requirements
for indirect contact protection (from
SAE J1766 January 2014).
This first additional requirement is
that the resistance between any two
simultaneously reachable exposed
conductive parts of the electrical
protection barriers that are less than 2.5
meters from each other is less than 0.2
ohms. This additional requirement
protects against indirect contact of high
voltage sources when two electrical
protection barriers are contacted
simultaneously. The second additional
requirement is that the voltages between
an electrical protection barrier enclosing
a high voltage source and other exposed
conductive parts are less than or equal
to 30 VAC or 60 VDC. This additional
requirement is included in SAE J1766
January 2014 to provide additional
protection from indirect contact of high
voltage sources, addressing the issues
raised in the Battelle research of the
physical barrier protection option.
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Verification of Post-Crash Indirect
Contact Protection
GTR No. 13 states that a high voltage
source is considered to have post-crash
indirect contact protection if the
electrical protection barrier enclosing
the high voltage source has a galvanic
connection to the chassis by welding.
This method of verification is a mere
visual inspection and lacks the
objectivity needed for an FMVSS. This
NPRM does not include this method of
verification and instead proposes to use
the test procedure in GTR No. 13
whereby a current of 0.2 A is passed
through the connection to determine its
resistance.
Physical Barrier Protection of AC High
Voltage Sources That Are Connected to
DC High Voltage Sources
This NPRM proposes to adopt the
physical barrier protection requirement
for direct contact specified in GTR No.
13 for both post-crash and during
normal vehicle operation. However, for
indirect contact protection, the proposal
uses the proposed post-crash indirect
contact protection requirements
described above (which include two
additional requirements described
above in addition to that specified in
GTR No. 13).
Optional Procedures for Evaluating
Electrical Isolation Post-Crash
FMVSS No. 305’s test procedure for
measuring electrical isolation of high
voltage sources is similar to that in GTR
No. 13. However, GTR No. 13 permits
the crash tests to be conducted without
energizing the electric power train while
FMVSS No. 305 does not. In conditions
where the high voltage sources are not
energized during the crash test, GTR No.
13 permits measuring electrical
isolation resistance of high voltage
sources by other means, including using
a megohmmeter.29 Yet, GTR No. 13 does
not specify a test procedure to measure
isolation resistance using a
megohmmeter.
NHTSA is not proposing to conduct
the crash test without energizing the
electric power train and so is not
permitting the use of the megohmmeter.
NHTSA stated its position on this
matter in final rules published on June
14, 2010 (75 FR 33515), July 29, 2011
(76 FR 45436), and January 16, 2015 (80
29 A megohmmeter is a specialized ohmmeter that
is primarily used to determine electrical isolation
resistance. This device operates by applying a
voltage or current to the item being tested. Because
externally applied voltages or currents can disrupt
its measurement (and/or cause damage to the
instrument) the megohmmer is used to test items
that are under an inactive and fully de-energized
state.
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FR 2320). In the January 16, 2015 final
rule, NHTSA noted that the agency’s
research on the feasibility of using a
megohmmeter for measuring electrical
isolation presented certain technical
questions that need to be resolved (i.e.,
the research showed that
megohmmeters could accurately
measure electrical isolation resistance of
DC high voltage sources in an inactive
state but did not consistently do so for
AC high voltage sources).
Additionally, electrical isolation
resistance measurement with a
megohmmeter is only possible when the
electrical power train is not energized,
such as when an inert gas is used in
hydrogen containers of a fuel cell
vehicle. NHTSA will address the issue
of the use of inert gas in hydrogen
containers of fuel cells vehicles when
conducting crash tests in a future
proposal to incorporate into FMVSSs
the fuel system and fuel container
integrity requirements of hydrogen fuel
cell vehicles in GTR No. 13. The agency
will address in that rulemaking the use
of alternative methods of measuring
isolation resistance in conditions where
the electric power train is not energized
in crash tests.
Procedures for Measuring Voltage PostCrash
FMVSS No. 305 specifies that all postcrash voltage measurements for
determining voltage and electrical
isolation of high voltage sources with
respect to the electric chassis be made
after a minimum of 5 seconds after the
vehicle comes to rest following impact.
GTR No. 13 specifies that for
determining post-crash electrical
isolation of high voltage sources, the
voltage measurements be made after a
minimum of 5 seconds after ‘‘impact.’’
GTR No. 13 also specifies that for
determining post-crash voltage (for
assessing compliance with the low
voltage option), the voltage
measurements be made after a minimum
of 5 seconds and no later than 60
seconds after impact.
The agency is not proposing to change
the timing of voltage measurement postcrash in FMVSS No. 305 to harmonize
with GTR No. 13. The ‘‘after impact’’
interval specified in GTR No. 13 appears
less objective than FMVSS No. 305’s
measure and adopting the GTR No. 13
specified time for post-crash voltage
measurement may reduce the objectivity
of the test. Further, all-in-all we believe
this difference in the timing of voltage
measurement in FMVSS No. 305 and
GTR No. 13 is minor.
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Miscellaneous Differences Between the
Proposed Regulatory Text and GTR No.
13
There is some unnecessary or
redundant text in some sections of GTR
No. 13 that we have not included in this
proposal, to make the regulatory text
more concise. An example of this is in
the electrical isolation option for postcrash electrical safety, under conditions
when the AC and DC high voltage
sources are connected. GTR No. 13
specifies that the vehicle meet one of
the following requirements: (1)
Electrical isolation of the DC and AC
high voltage sources from the chassis be
no less than 500 ohm/volt; (2) electrical
isolation of the DC and AC high voltage
sources from the chassis be no less than
100 ohm/volt and the AC high voltage
sources also have physical barrier
protection; or (3) electrical isolation of
the AC and DC high voltage sources
from the chassis be no less than 100
ohm/volt and the AC high voltage
source is considered as a low voltage
source. We believe that the option (3)
requirement above is unnecessary,
because if the AC high voltage source is
considered as a low voltage source, it
already meets the low voltage electrical
isolation option. Thus, we determined it
is not necessary to provide option (3).
IV. Battelle Study and Developments
NHTSA initiated a research program
in 2010, using Battelle as a contractor,
to better understand the safety
implications of using a physical barrier
to protect against electric shock. The
objectives of the research were to: (a)
Determine failure modes associated
with electrical protection barriers that
could potentially result in electric shock
to occupants in the vehicle or to rescue
workers due to direct or indirect
contact, (b) evaluate the practicability
and feasibility of test procedures in
what was then a draft version 30 of GTR
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30 The electrical safety requirements in the 2010
draft version of GTR No. 13 are the same as those
in the GTR No. 13 that was established on June 27,
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No. 13 for direct and indirect contact
protection.
As discussed below (and in our
supporting technical document) 31 the
Battelle research indicates that the
physical barrier protection specified in
GTR No. 13 would protect against
electric shock when there is a single
point failure in the electrical safety
systems. However, if there were
multiple failures in the electrical safety
systems specified in GTR No. 13 for
normal vehicle operating conditions,32
the Battelle research indicates that a
person could receive an electric shock
when they contact the high voltage
sources in certain specific ways.
The Battelle study 33 identified
various scenarios of electrical safety
system failures, including direct contact
of high voltage source, indirect contact
of live parts of high voltage sources, loss
in conductive connection between
electrical protection barrier and chassis,
and a combination of these failures.
Direct contact of a high voltage source
could occur in the event of a crash that
results in mechanical failure of
protection barriers or penetration of
electrical insulation that would allow
fingers or conductive tools to enter
protection barriers and contact the high
2013. Henceforth, we refer to the draft version as
the adopted GTR.
31 Along with this document, we have placed in
the docket a supporting technical document
providing further information on our analysis of the
Battelle research and GTR No. 13.
32 Under GTR No. 13, during normal vehicle
operation, all high voltage sources contained or
connected to the power train are required to be
electrically isolated from the chassis (with
minimum electrical isolation of 500 ohms/VAC or
100 ohms/VDC) and enclosed by physical barriers
that prevent direct human contact. The physical
barriers enclosing these high voltage sources are
required to be conductively connected to the
chassis (with resistance less than 0.1 ohms) to
provide indirect contact shock protection.
33 Hydrogen Fuel Cell Vehicle—Electrical
Protective Barrier Option, Final Report, DOT HS
812134, May 2015. Available at https://
www.nhtsa.gov/Research/Crashworthiness/Alter
native%20Energy%20Vehicle%20Systems%20
Safety%20Research and in the docket for this
NPRM.
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voltage sources within the barrier.
Indirect contact of high voltage sources
could occur in the event of a crash in
which an electrical protection barrier is
energized due to loss in electrical
isolation of the high voltage source
within the barrier.
To illustrate failure modes associated
with electric protection barriers, Battelle
used the schematic shown in Figure 4
below in which a high voltage source
(shown on the left side of the figure) is
isolated from the vehicle chassis by
resistances RiH and RiL on the positive
and negative side, respectively, and
enclosed in an electrical protection
barrier (EPB1). The high voltage source
may be either DC or AC and may
represent a variety of components such
as a fuel cell, battery, motor, or
capacitor.
Also shown in Figure 4 are electrical
wirings from the positive side of the
high voltage source to its negative side
to complete the circuit. The schematic
shows two electric protection barriers
(EPB2 and EPB3) enclosing the wirings
on the positive and negative side,
respectively, and a body with resistance
Rb contacting these two protection
barriers. All three electrical protection
barriers in the figure are conductively
connected to the electrical chassis with
resistances RCh, RChH, and RChL.
For normal vehicle operation, GTR
No. 13 requires RiH and RiL resistances
to provide electrical isolation of at least
500 ohms/VAC or 100 ohms/VDC. It
also requires the electrical wiring to be
insulated. Further, it requires the three
electrical protection barriers (EPB1,
EPB2, and EPB3) to have protection
degree IPXXD or IPXXB and be
conductively connected to the chassis
such that the resistances RCh, RChH, and
RChL are less than 0.1 ohms. The lowest
possible value of body resistance Rb is
500 ohms.34
34 IEC TC–60479–I, ‘‘Effects of current on human
beings and livestock—Part I—General Aspects,’’
2005.
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contacts the electrical wiring from the
positive side, and also contacts the
electrical protection barrier EPB3
enclosing the wiring on the negative
side of the high voltage source (Figure
5). In this case, as long as the resistance
RiL or RiH is greater than or equal to 500
ohms/VAC or 100 ohms/VDC, the
current through the body (shown by
dashed lines) will be within safe limits.
• Case 2—Direct contact of a high
voltage source with electric shock
hazard. Electrical protection barriers
EPB2 and EPB3 of the wiring on the
positive and negative side of the high
voltage source are compromised and the
body contacts the positive and negative
wiring (Figure 6). For the worst Case 2
condition, a body resistance Rb equal to
500 ohms (lowest possible) is used. For
a DC high voltage source of 350V, the
minimum resistance value for RiL and
RiH is 35,000 ohms. Since the body
resistance Rb is significantly lower than
the electrical isolation RiL and RiH,
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isolation of the high voltage source
within the barrier and the body contacts
the electrical protection barriers as
shown in Figure 4. Examples of direct
and indirect contact scenarios are
presented below:
• Case 1—Direct contact of high
voltage source without electric shock
hazard. Protection barrier EPB2 is
compromised and the body directly
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Battelle’s analysis of the schematic in
Figure 4 identified scenarios of direct
contact and indirect contact of high
voltage sources. Direct contact occurs
when the electrical protection barriers
EPB2 and/or EPB3 are breached or
penetrated and the body contacts the
wiring enclosed within. Indirect contact
occurs when EPB2 and/or EPB3 are
energized due to loss of electrical
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resistance RiL or RiH is greater than or
equal to 500 ohms/VAC or 100 ohms/
VDC, the current through the body
(shown by dashed lines) will be within
safe limits.
• Case 4—Indirect contact of high
voltage source with possibility of
electric shock. The electric wiring of the
positive and negative sides of the high
voltage source lose electrical isolation to
the protective barriers EPB2 and EPB3,
respectively, and the body contacts the
two protective barriers EPB2 and EPB3
(Figure 8). Since RCh, RChH and RChL are
all very low values (less than 0.1 ohms
according to GTR No.13), this condition
would result in a short circuit of the
high voltage source that could activate
and open a short circuit fuse that is
generally equipped in electric
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protection barrier, EPB2, and the body
contacts the electrical protection
barriers EPB2 and EPB3 of the positive
and negative wiring (Figure 7). Similar
to Case 1, as long as the isolation
EP10MR16.006
dashed lines) is not limited and the
body would experience electric shock.
• Case 3—Indirect contact of high
voltage source without electric shock
hazard. The wiring on the positive side
of the high voltage source loses
electrical isolation to the electrical
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resistance is not significantly low
compared to the body resistance, then
the current through the body contacting
the protective barriers (shown by
dashed line) may not be within safe
limits and the body could experience
electric shock. This scenario is further
discussed in the Alliance petition for
rulemaking (infra) and in the supporting
technical document of this NPRM.
Battelle identified additional
scenarios, including those regarding loss
in electrical isolation RiL and/or RiH and
loss of electrical bonding of the
protective barriers with the chassis.35
These scenarios showed that, for
vehicles that meet the electrical
isolation and physical barrier protection
requirement in GTR No. 13 during
normal vehicle operation, electric shock
is not possible when there is only a
single point of failure in the electrical
safety systems. However, electric shock
is possible when at least two or three
failures of electrical safety systems
occur and a human body comes into
contact with two compromised
protective barriers on opposite sides of
the high voltage source to complete the
circuit. For example, in Case 2, electric
shock could occur if two electrical
protection barriers on the positive and
negative side of the high voltage source
are compromised and a body contacts
the positive and negative side of a high
voltage source by entering the two
compromised protection barriers. In
Case 4, electric shock could occur only
if at least four electric safety features
(loss in electrical isolation of electrical
protection barriers EPB2 and EPB3
which are on the positive and negative
side of the high voltage source and loss
in electrical isolation RiH and RiL of the
high voltage source) are compromised
and the body contacts both
compromised barriers, EPB2 and EPB3.
To address the concern of electric
shock from indirect contact, GTR No. 13
specifies that the physical barriers
enclosing high voltage sources should
be conductively connected with low
resistance (less than 0.1 ohms) to the
electrical chassis, so that if one segment
of the high voltage source should lose
electrical isolation, all contactable
surfaces of the vehicle chassis and
protective barriers will be at the same
voltage and thereby prevent electric
shock to a person touching two different
protective barriers or parts of the
electrical chassis.
Battelle also evaluated the maximum
resistance (0.1 ohms) of the electric
bonds between electrical protection
barriers and the electrical chassis that is
specified in GTR No. 13. Battelle found
that in the event of multiple electrical
safety system failures (loss in electrical
isolation of both segments of the high
voltage source to their electrical
protection barriers) and a person
touching both the barriers to complete
the circuit, the resistance of 0.1 ohms
between the protective barrier and
electrical chassis would not be
sufficient to prevent electric shock to
the person contacting the protective
barriers.36
35 Details of these scenarios are presented in the
Battelle final report, DOT HS 812 134, May 2015,
which is available in the docket of this NPRM.
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V. Toyota Petition for Rulemaking
On December 23, 2013, Toyota
submitted a petition for rulemaking to
amend FMVSS No. 305 by adding an
additional compliance option for
electrical safety to allow HFCVs to be
offered for sale in the US. Toyota notes
that the requested compliance option
includes elements of the electrical
protection barrier that is currently in
GTR No. 13. Toyota notes that many
countries, including the European
Union, Japan, and South Korea, already
include electrical protection barrier as a
compliance option for electrical safety
in their standards.
Toyota explains its reasons for
petitioning as follows.37 FMVSS No. 305
36 This issue is further explained in the
supporting technical document in the docket of this
NPRM.
37 Honda Motor Co. Ltd. and American Honda
Motor Co. Inc. (Honda) echoed these concerns in its
comments on NHTSA’s notice of receipt of Toyota’s
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propulsion vehicles. If a fuse activates,
then no current will flow and so no
electrical shock would occur. However,
if the fuse does not activate, and if the
electrical isolation RiL and RiH are
reduced to low levels and the chassis
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requires compliance with electrical
safety requirements following impacts
‘‘at any speed up to and including’’ the
specified test speeds. Toyota notes that
for electric powered vehicles, including
fuel cell vehicles, the DC high voltage
sources (e.g. high voltage battery) will
be connected to the AC high voltage
sources (e.g. electric motor) during
normal vehicle operation and in low
speed crashes where the automatic
disconnect does not operate.38 In such
conditions, when the AC and DC high
voltage sources are connected, the
isolation resistance at the AC high
voltage source is in parallel with the
isolation resistance of the DC high
voltage source. Therefore, even if the
electrical isolation provided for the AC
high voltage source is significantly
greater than the required 500 ohms/volt,
the effective isolation resistance
measured at the AC high voltage source
can be, at most, as high as that provided
for the DC high voltage source.
Toyota explains that in current battery
electric vehicles, manufacturers are able
to provide electrical isolation for the
high voltage battery in excess of 500
ohms/volt, even though FMVSS No. 305
permits DC high voltage sources to have
100 ohms/volt with an electrical
isolation monitoring system. On the
other hand, it is difficult to maintain
electrical isolation greater than 500
ohms/volt for the fuel cell stack in an
HFCV due to the presence of fuel cell
coolant.39 Therefore, when the DC and
AC high voltage sources are connected
in an HFCV, it may not be possible to
achieve the required 500 ohms/volt
electrical isolation for AC high voltage
sources.
Toyota states that NHTSA said in the
June 14, 2010 final rule (75 FR 33515)
that the agency was issuing the final
rule to facilitate the development and
introduction of fuel cell vehicles. One
provision provided by the final rule was
to specify lower minimum electrical
isolation requirements for DC than AC
high voltage sources (500 ohms/volt for
AC and 100 ohms/volt for DC sources).
Toyota further asserts that this
flexibility offered for HFCVs is not
useful unless a provision is made for the
condition when the AC and DC high
voltage sources are connected, such as
exemption petition, supra. See Docket No. NHTSA–
2014–0068.
38 Toyota noted that the automatic disconnect
mechanism is not activated in low speed crashes,
such as minor fender benders that may occur in a
parking lot and in conditions where the inverters
in the fuel cell auxiliary system may continue to
operate.
39 The fuel cell coolant may get ionized during
repeated operation and may reduce the electrical
isolation provided.
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after a low speed crash.40 Since such a
provision is currently not available,
HFCVs are essentially required to
provide electrical isolation levels at or
in excess of 500 ohms/volt at the fuel
cell stacks.
Toyota asks that NHTSA adopt an
alternative provision for electrical safety
through isolation of high voltage sources
that involves electrical protection
barriers to address post-crash conditions
where the AC and DC high voltage
sources are connected. The petitioner
suggests adopting GTR No. 13’s
specification that the electrical isolation
of the high voltage source may be
greater or equal to 100 ohms/volt for an
AC high voltage source if that AC source
is conductively connected to a DC high
voltage source, provided that the AC
high voltage source meets the specified
post-crash physical barrier protection
requirements in GTR No. 13.41 The
petitioner suggests specific regulatory
text for the requirements and test
procedures that are based on the
specifications in GTR No. 13 for
modifying FMVSS No. 305 to include
the petitioner’s requested compliance
option.
Toyota also requests that NHTSA
amend S6.4 of FMVSS No 305 which
requires vehicles to satisfy all of the
post-crash performance requirements
‘‘after being rotated on its longitudinal
axis to each successive increment of 90
degrees . . . . .’’ to indicate that
compliance with electrical isolation and
physical barrier protection requirements
would be evaluated after the vehicle is
rotated a full 360 degrees. Toyota notes
that the vehicle conditions related to the
electrical isolation and physical barrier
protection requirements do not change
at various increments of a rollover and
that it would be unreasonably
dangerous for laboratory personnel to
conduct the specified tests with the
vehicle at 90 degree increments.
VI. Alliance Petition for Rulemaking
On November 10, 2014, the Alliance
submitted a petition for rulemaking to
update and upgrade FMVSS No. 305 to
incorporate a physical barrier
compliance option to provide protection
40 FMVSS No. 305 requires that the electrical
safety requirements in FMVSS No. 305 be met after
front, rear, and side crash tests that include low
speeds. In such conditions (which includes ‘‘fender
benders’’), the automatic disconnect is designed to
remain closed so that the vehicle remains
operational and so the driver can continue driving
the vehicle.
41 The requirements for post-crash physical
barrier protection option for electrical safety in GTR
No. 13 are that after a crash test, high voltage
sources have protection level IPXXB and that the
resistance between all exposed conductive parts
and the electrical chassis be lower than 0.1 ohm
when there is a current flow of at least 0.2 amperes.
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against electric shock. The Alliance
states that the implementation of a
physical barrier compliance option is
especially critical to facilitate both the
introduction of complying HFCVs as
well as 48 volt mild hybrid
technologies.42 The petitioner also
believes the amendments would enable
safe design innovation for all electrified
vehicles, as well as reduce CO2
emissions and increase fuel economy.
The Alliance states that the physical
barrier compliance option is essential
for FMVSS No. 305 certification of
HFCVs in low speed crashes where the
automatic disconnect is not designed to
operate. The Alliance also states that in
such crashes, the DC high voltage source
can impinge on the AC high voltage
sources through the inverter, making it
impractical to achieve 500 ohms/volt
electrical isolation for the AC high
voltage source.
The Alliance explains that while it
would seem that 48 volt mild hybrid
systems would not be within the
intended scope of FMVSS No. 305,43
these systems typically convert DC
voltage into three-phase AC voltage that
can exceed the 30 VAC voltage
threshold for consideration as a high
voltage source in FMVSS No. 305.44 The
42 48 volt mild hybrid systems are generally
internal combustion engines and a 48 volt battery
equipped with an electric machine (one motor/
generator in a parallel configuration) allowing the
engine to be turned off whenever the car is coasting,
braking, or stopped, yet restart quickly. These mild
hybrids may employ regenerative braking and some
level of power assist to the internal combustion
engine, but do not have an exclusive electric-only
mode of propulsion.
43 FMVSS No. 305 considers electrical sources
operating at voltages greater than or equal to 30
VAC or 60 VDC as high voltage sources that are
subject to FMVSS No. 305 electrical safety
requirements.
44 We have also considered information provided
by Mercedes-Benz in a briefing to the agency on
June 2, 2015. As explained by Mercedes-Benz, the
AC–DC inverter converts the DC current from the
48 V battery into AC for the 3-phase AC motor.
Mercedes-Benz showed that the voltage between the
electrical chassis and each of the phases of the AC
electric motor is switched DC voltage (voltage
between 0 and 48 volts). Since that voltage is less
than 60 volts, it is considered low DC voltage under
FMVSS No. 305. However, Mercedes-Benz noted
that the voltage between two phases of the AC
motor is AC, and may be slightly greater than 30
VAC under certain circumstances, which can be
considered a high voltage AC source under the
standard. Mercedez-Benz explained its view that
physical barrier protection around the AC motor,
and around cables from the inverter to the motor,
would mitigate human contact with these AC high
voltage sources, and thereby mitigate the likelihood
of electric shock. Additionally, the presenter
showed that electrical protection barriers enclosing
the AC high voltage sources could be conductively
connected to the chassis with resistance less than
0.1 ohms, and thereby provide electric shock
protection from indirect contact of the high voltage
sources. See the memorandum in the docket for this
NPRM on Mercedes-Benz, Daimler AG, input on 48
V mild hybrid systems.
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Alliance states that these 48 volt mild
hybrid systems are grounded to the
vehicle chassis and so cannot viably
meet the existing isolation resistance
option as well as the pretest
measurement for isolation resistance.
The Alliance notes that while it is
feasible to design a 48 volt mild hybrid
system that meets FMVSS No. 305
electrical isolation requirements,
isolated systems inherently involve
more complexity, higher consumer
costs, and higher mass resulting in
reduced fuel economy and increased
emissions. The Alliance suggests that
these results are particularly
inappropriate since there is no
incremental safety benefit provided by
an isolated system compared to physical
barriers. The Alliance states that as a
result, it is requesting modifications to
FMVSS No. 305 to permit the
introduction 48 volt mild hybrid
systems and HFCVs into the U.S.
The Alliance notes that in NHTSA’s
July 29, 2011, response to petitions for
reconsideration of the 2010 final rule,45
NHTSA deferred consideration of the
physical barrier protection option
pending additional research. The
Alliance states that the agency’s
research on the physical barrier
option 46 showed that electric shock
from indirect contact in a crash could
only be possible, if the following
conditions were met (see Case 4
described above and illustrated in
Figure 8):
(1) A loss of electrical isolation within
the enclosure of a high voltage source,
(2) a loss of electrical isolation within
a second (different) high voltage source
enclosure,
(3) these two distinct losses in
isolation (specified in (1) and (2)) occur
on opposite rails (positive and negative)
of the high voltage source,
(4) the overcurrent devices do not
automatically open the circuit as a
result of the simultaneous loss of
isolation on the positive and negative
rails to ground (the Alliance states that
the normal design practice is for the
overcurrent devices to automatically
open under the circumstances outlined
in (3)),
(5) a person has access to these two
enclosures in the crashed vehicle, and
(6) a person touches these two
enclosures simultaneously.
45 76
FR 45436.
Fuel Cell Vehicle—Electrical
Protective Barrier Option,’’ DOT HS 812134, May
2015, is available at https://www.nhtsa.gov/
Research/Crashworthiness/Alter
native%20Energy%20Vehicle%20
Systems%20Safety%20Research and in the docket
for this NPRM.
46 ‘‘Hydrogen
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The Alliance believes that the
likelihood of each of the above 6 events
occurring is remote and that the
simultaneous occurrence of these events
in real world situations is even more
remote and exceedingly small. The
Alliance believes that the other
scenarios identified in the Battelle final
report as having potential safety
concerns similarly require multiple
failures in the system to occur, followed
by what the petitioner believes to be
unlikely human contacts and a lack of
fuses or other electrical safety
protection. Nevertheless, the Alliance
states that, despite the extremely low
likelihood of a safety issue from any of
the scenarios in the final Battelle report,
the updated version of SAE J1766
(January 2014) 47 includes performance
requirements that safeguard against all
safety critical scenarios identified in the
Battelle report.
The Alliance expresses its support of
the December 23, 2013 petition for
rulemaking from Toyota to modify
FMVSS No. 305 to facilitate the sale of
HFCVs in the U.S. (petition discussed
infra) and notes that the January 2014
version of SAE J1766 also includes
provisions for a modified isolation
requirement for AC systems with
physical barriers, as Toyota requests in
its petition for rulemaking. The Alliance
states that SAE J1766 January 2014 also
has provisions for a ‘‘stand-alone’’
physical barrier protection compliance
option that is needed for facilitating the
development of 48 volt mild hybrid
systems, since electrical components of
these systems are conductively
connected to the chassis and so cannot
viably satisfy electrical isolation
requirements. The Alliance believes that
this ‘‘stand-alone’’ physical barrier
compliance option provides sufficient
protection to address potential
(although unlikely, states the petitioner)
safety critical scenarios identified in the
Battelle report.
The Alliance asserts that while
FMVSS No. 305 only evaluates
electrical safety in post-crash condition,
auto manufacturers also design for high
voltage safety under normal operating
conditions. The petitioner states that
providing physical barriers is the most
common method of protection against
high voltage contact in the automotive
industry, as well as other industries that
use high voltage electric circuits. The
Alliance believes it is reasonable that
this method of protection against
electric shock hazard can also be used
47 SAE J1766, ‘‘Recommended practice for
electric, fuel cell, and hybrid electric vehicle crash
integrity testing,’’ January 2014, SAE International,
https://www.sae.org.
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for post-crash shock protection provided
these physical barriers remain intact
post-crash, and that either the voltage
between exposed conductive parts is
below 30 VAC or 60 VDC, or resistance
between exposed conductive parts of
the barriers and electrical chassis is
below specified resistance levels.
The Alliance states it is urgent to
update FMVSS No. 305 to facilitate the
introduction of HFCVs and 48 volt mild
hybrid technology vehicles that are
necessary to accommodate compliance
with Corporate Average Fuel Economy
(CAFE) standards. Consequentially, the
petitioner states that it is not
additionally requesting adoption of the
low energy compliance option that is
also included in SAE J1766 January
2014. Instead the petitioner requests
that the low energy compliance option
be considered for the electric vehicle
safety (EVS) GTR that is currently in
process.
SAE J1766 January 2014 also changes
the time criterion for initiating
verification of post-crash electrical
safety from 5 seconds after the vehicle
comes to rest (similar to the
specification currently in FMVSS No.
305) to 10 seconds after initial impact.
The Alliance states that given the
urgency necessary to facilitate the
introduction of HFCVs and 48 volt mild
hybrid technology, it is limiting its
petition for rulemaking to only include
the post-crash physical barrier
protection compliance option in SAE
J1766 January 2014 into FMVSS No.
305.
Specifically, the Alliance requests
including section 5.3.4 of SAE J1766
January 2014 into FMVSS No. 305. This
section provides two options for postcrash electrical safety by means of
physical barriers.
The first option (Option 1 for physical
barrier protection) is similar to the postcrash physical barrier protection option
for electrical safety in GTR No. 13,48 but
includes an additional requirement that
the resistance between the high voltage
source enclosed by the physical barrier
and the exposed conductive parts of the
electrical protection barrier be greater
than 0.01 ohms/volt for DC high voltage
sources and 0.05 ohms/volt for AC high
voltage sources.
The second option for electrical safety
through electrical protection barriers
(Option 2 for physical barrier
protection) in SAE J1776 January 2014
48 Protection against direct contact with high
voltage sources is provided by protection degree
IPXXB and protection against indirect contact of
high voltage sources is provided by requiring the
resistance between exposed conductive parts and
the electrical chassis to be lower than 0.1 ohm
when there is a current flow of at least 0.2 amperes.
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20, 2015, which provided an analysis of
its proposal for electrical safety through
physical barriers.49 Figure 9, below,
presents the circuit diagram the
petitioner provided for the
representation of a high voltage source
(e.g., battery) with voltage of 1,000 VAC
or 1,500 VDC, enclosed in physical
barriers that are conductively connected
to the electrical chassis with resistance
less than or equal to 0.1 ohms. The
circuit diagram also has a representation
of a human body with a minimum
resistance of 500 ohms 50 contacting
protective barriers enclosing opposite
rails of the high voltage source. The
resistances R1 and R2 in Figure 9
represent the resistance between the
high voltage source and the protective
physical barriers that enclose it. This
circuit diagram is a representation of the
indirect contact Battelle scenario, Case
4, in the event that electrical isolation
of the high voltage source to the chassis
is lost and RiH and RiL are equal to zero.
According to Option 1 of the electrical
protection barrier in the Alliance
submission, the combined resistance 51
of R1 and R2 is required to be less than
or equal to 0.05 ohms/VAC or 0.01
ohms/VDC. Under Option 2, the voltage
difference between barrier #1 and
barrier #2 is required to be less than or
equal to 30 VAC or 60 VDC. The
Alliance observes that its analysis using
the model in Figure 9 demonstrates that
the proposed physical barrier protection
option provides equivalent levels of
safety as the electrical isolation option 52
currently in FMVSS No. 305 in all the
safety critical scenarios identified in the
Battelle study, including the scenario
Case 4 for indirect contact.
The Alliance also states that the
Option 1 electrical protection barrier is
the same as that of Option 2 since the
conditions that meet the Option 1
requirements also meet the Option 2
requirements. The Alliance
acknowledges that it is difficult to
measure the resistance between a high
voltage source and the exposed
conductive parts of the electrical
protection barrier that encloses the high
voltage source, as is needed to evaluate
the Option 1 electrical protection
barrier.53 The Alliance recommends that
NHTSA incorporate Option 2 (direct
contact protection degree IPXXB and
voltage between electrical protection
barrier and exposed conductive parts
less than or equal to 30 VAC or 60 VDC)
into FMVSS No. 305 since its analysis
indicates that compliance with Option 1
would also entail compliance with
Option 2.
The Alliance specifies the following
test procedures from Appendix C in
SAE J1766 January 2014: (1) Section C.1
for verifying IPXXB protection degree of
physical barriers, which is similar to the
procedure in GTR No. 13, (2) Section
C.2.1 for verifying that the resistance
between electrical protection barriers
and electrical chassis is less than 0.1
49 The Alliance analysis of the physical barrier
protection option proposed for electrical safety
(October 2014) is in the docket of this NPRM.
50 According to IEC TC–60479–I, ‘‘Effects of
current on human beings and livestock—Part I—
General Aspects,’’ 2005, the lowest possible
electrical resistance of a human body is 500 ohms.
51 R1 and R2 resistances are in a parallel
configuration.
52 The current through the body Ib (shown in
Figure 9) is less than or equal to 10 mA of direct
current or 2 mA of alternating current.
53 The resistance level is too low to measure
accurately and in order to access a high voltage
source enclosed in the physical barrier, some
disassembly of the barrier may be required in some
cases.
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is through protection from direct contact
by protection degree IPXXB, and that
the voltage between the electrical
protection barrier and other exposed
conductive parts and the electrical
chassis is less than or equal to 30 VAC
for AC high voltage sources and 60 VDC
for DC high voltage sources. The
Alliance states that Option 2 is similar
to the low voltage option already in
FMVSS No. 305.
The Alliance supplemented its
petition by a submission dated October
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ohms, and (3) Section C.2.3 to verify
that the voltage difference between any
two exposed conductive parts of the
electric chassis (including physical
barriers) is less than or equal to 30 VAC
or 60 VDC. The Alliance also specifies
Section C.2.2 in SAE J1766 January 2014
for verifying that the resistance between
a high voltage source and the electrical
chassis 54 is greater than or equal to 0.05
ohms/VAC or 0.01 ohms/VDC. We note,
however, that section C.2.2 does not
provide a specific method of
measurement and instead states, ‘‘The
measurement may be performed by any
means that provides sufficient accuracy
for the post-crash situation.’’
These test procedures are further
discussed in a later section analyzing
the petitions for rulemaking to modify
FMVSS No. 305.
VII. Overview of Proposed Rule
NHTSA is initiating rulemaking to
consider adopting GTR No. 13 into
FMVSS No. 305, as appropriate under
the Vehicle Safety Act, and to address
the issues raised by the Alliance and
Toyota in their respective petitions. We
request comment on the decisions put
forth in this NPRM, including those
regarding minor additional provisions
that the agency is considering to address
the concerns of the petitioners.
NHTSA believes that this NPRM
would improve the level of safety
afforded to the public. Adopting the
provisions from GTR No. 13 that reduce
the risk of harmful electric shock during
normal vehicle operation would
improve FMVSS No. 305 by expanding
its performance requirements beyond
post-crash conditions. The proposed
requirements would provide post-crash
compliance options for new power train
configurations that ensure that those
configurations provide a comparable
level of post-crash safety compared to
existing electric vehicles.
The proposed amendments are
summarized as follows. In furtherance
of implementing GTR No. 13 and in
response to the petitions for
rulemaking—
a. This NPRM proposes to add
electrical safety requirements for vehicle
performance during normal vehicle
operations (as opposed to during and
after a crash), to mitigate electric shock
due to loss in electrical isolation and
direct or indirect contact of high voltage
54 Since the resistance between a protective
physical barrier and the electrical chassis is
required to be less than or equal to 0.1 ohm (a very
low value), the resistance between a high voltage
source and the physical barrier would be the same
as or only slightly lower than the resistance
between the high voltage source and the electrical
chassis.
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sources. The electrical safety
requirements during normal vehicle
operations would include requirements
for:
1. Direct Contact Protection From High
Voltage Sources
i. IPXXD protection level for high voltage
sources inside passenger and luggage
compartments. IPXXB protection level for
high voltage sources not in passenger and
luggage compartments.
ii. IPXXB protection level for service
disconnect that can be opened or removed
without tools.
iii. Markings on barriers of high voltage
sources that can be physically accessed,
opened, or removed without the use of tools.
iv. Orange color outer covering for cables
of high voltage sources that are located
outside electrical protection barriers.
2. Indirect Contact Protection From
High Voltage Sources
Exposed conductive parts of electrical
protection barriers would have to be
conductively connected to the chassis with a
resistance less than 0.1 ohms, and the
resistance between two simultaneously
reachable exposed conductive parts of
electrical protection barriers that are within
2.5 meters of each other would have to be
less than 0.2 ohms.
3. Electrical Isolation of High Voltage
Sources
i. 500 ohms/volt or higher electrical
isolation for AC high voltage sources and 100
ohms/volt or higher for DC high voltage
sources
ii. For conditions where AC and DC bus are
connected, AC high voltage sources would be
permitted to have electrical isolation of 100
ohms/volt or higher, provided they also have
the direct and indirect contact protection
described in 1 and 2, above.
iii. There would be an exclusion of 48 volt
hybrid vehicles from electrical isolation
requirements during normal vehicle
operation.
4. Electrical Isolation Monitoring System
for DC High Voltage Sources on Fuel
Cell Vehicles
5. Electrical Safety During Charging
Involving Connecting the Vehicle to an
External Electric Power Supply
i. Minimum electrical isolation resistance
of one million ohms of the coupling system
for charging the electrical energy storage
system; and
ii. Conductive connection of the electric
chassis to earth ground before and during
exterior voltage is applied.
6. Mitigating Driver Error by—
i. Requiring an indication to the driver
when the vehicle is in active driving mode
upon vehicle start up and when the driver is
leaving the vehicle; and,
ii. Preventing vehicle movement by its own
propulsion system when the vehicle charging
system is connected to the external electric
power supply.
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b. This NPRM proposes to amend
FMVSS No. 305’s post-crash electrical
safety requirements. The post-crash
electrical safety requirements would
include:
1. Adding an additional optional method of
meeting post-crash electrical safety
requirements through physical barrier
protection from high voltage sources. The
proposed specifications of this optional
method of electric safety include
requirements ensuring that:
i. High voltage sources would be enclosed
in barriers that prevent direct human contact
with high voltage sources (IPXXB protection
level),
ii. Exposed conductive parts of electrical
protection barriers would be conductively
connected to the chassis with a resistance
less than 0.1 ohms, and the resistance
between two simultaneously reachable
exposed conductive parts of electrical
protection barriers that are less than 2.5
meters from each other would be less than
0.2 ohms, and
iii. Voltage between a barrier and other
exposed conductive parts of the vehicle
would be at a low voltage level that would
not cause electric shock (less than 60 VDC or
30 VAC).
2. Permitting an AC high voltage source
that is conductively connected to a DC high
voltage source to meet lower minimum
electrical isolation requirement of 100 ohms/
volt provided the AC high voltage source also
has physical barrier protection specified in 1,
above.
VIII. Proposal Addressing Safety
During Normal Vehicle Operations
We first discuss the proposed
requirements for vehicle performance
during normal vehicle operations,
followed by those for performance postcrash.
a. Direct Contact Protection From High
Voltage Sources
GTR No. 13 specifies safety measures
to ensure that high voltage sources
cannot be contacted. This safety
measure is to enclose high voltage
sources in physical barriers (electrical
protection barriers) to prevent direct
human contact. NHTSA is proposing to
include in FMVSS No. 305 the direct
contact protection requirements
specified in GTR No. 13 for the
passenger and luggage compartments
and other areas.55
NHTSA is proposing to assess
protection against direct contact with
high voltage sources contained inside
the passenger and luggage
compartments using a 1.0 mm diameter
and 100 mm long test wire probe
(IPXXD). This test probe ensures that
any gaps in the protective barriers are
55 GTR No. 13 assesses the potential for direct
contact with high voltage components using test
probes specified in ISO 20653.
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no larger than 1 mm and that any live
components contained within are no
closer to the gap than 100 mm. This
ensures that body parts, miscellaneous
tools or other slender conductive items
typically present in a passenger or
luggage compartment cannot penetrate
any gaps/seams in the protective
enclosures and contact high voltage
components contained within.
For assessing protection against direct
contact with high voltage sources in
areas other than the passenger and
luggage compartments under normal
operating conditions, NHTSA is
proposing to use the test probe IPXXB,
representing a test finger. In areas other
than the passenger and luggage
compartments, the barrier would not
likely contact tools and other slender
conductive items. Therefore, protection
using the test wire probe IPXXD would
not be necessary and the test finger
probe IPXXB would be appropriate to
prevent inadvertent contact with high
voltage components contained in the
protective enclosures, by persons such
as mechanics.
GTR No 13 also requires that a service
disconnect that can be opened,
disassembled, or removed without tools
requires IPXXB protection when it is
opened, disassembled, or removed.
NHTSA is proposing to include this
requirement into FMVSS No. 305, as
well as a definition for a service
disconnect.
NHTSA is proposing marking (yellow
high voltage symbol) for enclosures and
barriers of high voltage sources that can
be physically accessed, opened, or
removed without the use of tools,
similar to GTR No. 13. As explained
earlier in this preamble, we are not
excluding some barriers as GTR No. 13
does.
NHTSA is proposing that cables for
high voltage sources which are not
located within electrical protection
barriers to be identified by an orange
color outer covering, similar to GTR No.
13. However, as explained earlier in this
preamble, we are not excluding some
connectors as GTR No. 13 does.
As noted earlier in this preamble,
GTR No. 13 specifies direct contact
protection requirements for high voltage
connectors separately, and has
exclusions with which we do not agree.
Per GTR No. 13, connectors do not need
to meet IPXXB protection if they are
located underneath the vehicle floor and
are provided with a locking mechanism,
or require the use of tools to separate the
connector, or the voltage reduces to
below 30 VAC or 60 VDC within one
second after the connector is separated.
For the reasons given earlier, NHTSA
does not believe that the exclusions are
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warranted and does not anticipate
adopting them in a final rule.
b. Indirect Contact Protection From
High Voltage Sources
Under GTR No. 13, exposed
conductive parts (parts that can be
contacted with the test probes, IPXXD or
IPXXB, and become electrically
energized under electrical isolation
failure conditions) have to be protected
against indirect contact during normal
vehicle operation. GTR No. 13 requires
electrical protection barriers or
enclosures of high voltage sources to be
conductively connected to the electrical
chassis with resistance of no more than
0.1 ohms during normal vehicle
operations. This requirement would
provide protection from electric shock
by shunting 56 any harmful electrical
currents to the vehicle chassis should
any electrically charged components
lose isolation within the protective
barrier.
For indirect contact protection, we
propose to apply the same indirect
contact protection requirements and test
procedures as would apply under postcrash conditions (see discussion in next
section, below). The proposed indirect
contact protection requirements would
be for exposed conductive parts of
electrical protection barriers to be
conductively connected to the chassis
with a resistance less than 0.1 ohms and
that the resistance between two
simultaneously reachable exposed
conductive parts of electrical protection
barriers that are within 2.5 meters of
each other be less than 0.2 ohms. These
resistances would be measured by
passing a current of at least 0.2 A
between exposed conductive parts and
the electrical chassis. For the reasons
previously discussed, NHTSA is not
including GTR No. 13’s provision that
permits visual inspection of welds as a
method of assessing compliance of
indirect contact protection.
c. Electrical Isolation of High Voltage
Sources
This NPRM would require that under
normal operating conditions, all high
voltage sources of the power train and
those connected to the power train have
sufficient electrical isolation resistance
56 Shunting is when a low-resistance connection
between two points in an electric circuit forms an
alternative path for a portion of the current. If a
human body contacts an electrical protection
barrier that is energized due to loss in electrical
isolation of a high voltage source enclosed in the
barrier, most of the current would flow through the
chassis rather than through the human body
because the current path through the chassis has
significantly lower resistance (less than 0.1 ohm)
than the resistance of the human body (greater or
equal to 500 ohm).
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measured against the electrical chassis
to ensure that current flowing through a
human body in contact with the vehicle
is not dangerous.
For conditions where DC and AC high
voltage sources are isolated from each
other, DC high voltage sources would be
required to have a minimum electrical
isolation of 100 ohms/volt and AC high
voltage sources would be required to
have a minimum of 500 ohms/volt.
For conditions where DC and AC high
voltage sources are connected, AC and
DC high voltage sources would be
permitted to have a minimum electrical
isolation of 100 ohms/volt, provided the
AC high voltage source has direct and
indirect contact protection in a. and b.
above.
We proposed to exclude 48 volt
hybrid vehicles from these electrical
isolation requirements during normal
vehicle operation. Since electric
components in 48 volt mild hybrid
systems are conductively connected to
the electric chassis, these systems
would not be able to comply with
electrical isolation requirements both
during normal vehicle operations and
after a crash. Therefore, we believe that
the ‘‘normal use’’ requirements in GTR
No. 13 need to be modified to permit the
introduction of 48 volt mild hybrid
systems.
The United Nations Economic
Commission for Europe Regulation 100
(ECE R.100) 57 normal operation
requirements were modified on June 10,
2014 to facilitate the development and
sale of 48 volt mild hybrid systems.
Under these changes, 48 volt mild
hybrid systems that are conductively
connected to the electrical chassis are
exempt from the in-use electrical
isolation requirements. However,
electrical protection barriers are still
required during normal vehicle
operations for high voltage components
of these 48 volt mild hybrid systems so
as to provide direct and indirect contact
protection. As discussed in a later
section for post-crash electrical safety
requirements, we believe that these 48
volt mild hybrid systems with electrical
protection barriers for all high voltage
components in the system would not
pose concerns regarding electric shock.
Therefore, NHTSA proposes to include
a similar exclusion from in-use
electrical isolation requirements for 48
volt mild hybrid systems that are
conductively connected to the electrical
chassis.
57 Uniform Provisions Concerning the Approval
of Vehicles with Regard to Specific Requirements
for the Electric Power Train, ECE R.100–02, June 24,
2014.
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d. Electrical Isolation Monitoring
System for DC High Voltage Sources on
Fuel Cell Vehicles
GTR No. 13 requires that DC high
voltage sources (other than the coupling
system for charging) in HFCVs have an
on-board electrical isolation monitoring
system, together with a warning to the
driver if the isolation resistance drops
below the minimum required value of
100 ohms/volt. Similarly, FMVSS No.
305 currently specifies that DC high
voltage sources that comply with
electrical safety requirements by the
electrical isolation of 100 ohms/volt
must have an electrical isolation
monitoring system to warn the driver.
SiCnce most HFCVs would comply with
the electrical isolation requirements in
FMVSS No. 305 using the 100 ohms/
volt option,58 these HFCVs, which must
have an electrical isolation monitoring
system under GTR No. 13, would also
be required by FMVSS No. 305 to have
the monitoring system.
Nonetheless, to ensure that the intent
of GTR No. 13 and FMVSS No. 305 are
met, the agency is proposing to amend
FMVSS No. 305 to indicate expressly
that each DC high voltage source in fuel
cell vehicles would need to be equipped
with an electrical isolation monitoring
system.
e. Protection From Electric Shock
During Charging
GTR No. 13 requires electric vehicles
whose rechargeable energy storage
system are charged by conductively
connecting to an external power supply
to have a device to enable conductive
connection of the electrical chassis to
the earth ground during charging.
Additionally, GTR No. 13 requires the
isolation resistance between the high
voltage source and the electrical chassis
to be at least 1 million ohms when the
charge coupler is disconnected. The first
requirement ensures that in the event of
electrical isolation loss during charging,
a person contacting the vehicle does not
form a ground loop with the chassis and
sustain significant electric shock. The
second requirement ensures that the
magnitude of current through a human
body when a person contacts a vehicle
undergoing charging is low and in the
safe zone. NHTSA believes these two
normal use charging safety requirements
are warranted and proposes to include
them in FMVSS No. 305.
f. Mitigating Driver Error
Consistent with GTR No. 13, we
propose amending FMVSS No. 305 to
58 In fuel cell vehicles, the presence of fuel cell
coolant may not permit electrical isolation levels of
500 ohms/volt of the DC source.
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add requirements that mitigate the
likelihood of driver error in operating
electric vehicles. First, we propose
requiring vehicles to provide an
indication to the driver when the
vehicle is in an active driving mode
upon vehicle start up and when the
driver is leaving the vehicle.59 Second,
we propose requiring vehicles to
prevent vehicle movement by its own
propulsion system when the vehicle
charging system is connected to the
external electric power supply.
IX. Proposal Addressing Safety PostCrash
FMVSS No. 305 requires that after a
crash, each high voltage source in the
vehicle are either electrically isolated
from the vehicle’s chassis, or their
voltage is reduced to levels considered
safe from electric shock hazards (i.e.,
less than 30 VAC or less than 60 VDC).
As noted in earlier sections, GTR No.
13 specifies that vehicles may meet
regulatory requirements by having no
high voltage levels (see (a) below), meet
physical barrier protection requirements
(see (b)) below, or meet electrical
isolation requirements (see (c) below):
a. Voltage levels: The voltages of the high
voltage source must be less than or equal to
30 VAC or 60 VDC within 60 seconds after
the impact. (This option for electrical safety
is currently in FMVSS No. 305.)
b. Electrical protection barrier: The
physical protection requirement is an option
each contracting party of the 1998 agreement
may elect to adopt. The provision is similar
to the electrical safety requirements during
normal operations except that the protection
degree IPXXB applies rather than IPXXD.
(The provision for electrical protection
through physical barriers is currently not in
FMVSS No. 305.)
i. Protection from direct contact: Protection
from direct contact of high voltage sources
with protection degree IPXXB required.
ii. Protection from indirect contact: The
resistance between all exposed conductive
parts and electrical chassis is required to be
less than 0.1 ohms when there is a current
flow of at least 0.2 A.60
c. Electrical isolation:
i. If the AC and DC high voltage sources
are conductively isolated from each other,
then the minimum electrical isolation of a
high voltage source to the chassis is 500
ohms/volt for AC components and 100 ohms/
59 We note that an NPRM issued on FMVSS No.
114, ‘‘Theft protection and rollaway prevention’’
(76 FR 77183) proposes to require vehicles with
keyless ignition controls to provide an audible
warning to the driver exiting the vehicle while the
propulsion system is operating. We request
comment on whether the FMVSS No. 114
requirement, if adopted, would satisfy this
provision in the GTR.
60 GTR No. 13 considers this requirement to be
met if visual inspection indicates that conductive
connection has been established by welding. The
minimum resistance requirement is only evaluated
in case of doubt.
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volt for DC components of the working
voltage.
ii. If AC and DC high voltage sources are
conductively connected, the minimum
electrical isolation of AC and DC high voltage
sources must be—
• 500 ohms/volt of the working voltage, or
• 100 ohms/volt of the working voltage
with the AC high voltage sources meeting the
physical protection requirements in (b) or
have no high voltage as specified in (a).
(FMVSS No. 305 does not distinguish
AC and DC high voltage sources that are
conductively connected from those that
are isolated. Thus, the method above for
complying with electrical isolation
requirements when AC and DC high
voltage sources are connected post-crash
(see c. ii. above) is not now available in
FMVSS No. 305.)
Proposal
This NPRM proposes to amend the
isolation resistance compliance option
in FMVSS No. 305 to harmonize with
GTR No. 13. We are proposing to add an
optional method of meeting post-crash
electrical isolation requirements for an
AC high voltage source that is
connected to a DC high voltage source.
In such condition, the required
minimum electrical isolation for the AC
high voltage source is 100 ohms/volt
provided the AC high voltage source
meets the post-crash physical barrier
protection requirements.
We are also proposing to add a
physical barrier protection option for
post-crash electrical safety that includes
requirements specifying that:
i. High voltage sources must be enclosed in
barriers that prevent direct human contact
with high voltage sources (IPXXB protection
level),
ii. Electrical protection barriers must be
conductively connected to the chassis with a
resistance less than 0.1 ohms, and the
resistance between two simultaneously
reachable exposed conductive parts of
electrical protection barriers that are less
than 2.5 meters of each other must be less
than 0.2 ohms, and
iii. Voltage between a barrier and other
exposed conductive parts of the vehicle must
be at a low voltage level that would not cause
electric shock (less than 60 VDC or 30 VAC).
Electrical Isolation Resistance Option
Currently, FMVSS No. 305’s electrical
isolation option requires that vehicles
with high voltage sources meet different
isolation requirements based on
whether the vehicle is an AC or a DC
high voltage source. Electric powered
vehicles are required to electrically
isolate AC and DC high voltage sources
from the chassis with electrical isolation
no less than 500 ohms/volt, but the DC
high voltage source can have electrical
isolation no less than 100 ohms/volt if
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the DC high voltage source has an
electrical isolation monitoring system.
GTR No. 13 differs from FMVSS No.
305 by distinguishing between
situations where AC and DC high
voltage are conductively isolated from
each other or are conductively
connected. GTR No. 13 states that when
AC and DC high voltage sources are
isolated from each other, the AC high
voltage sources need to maintain
electrical isolation no less than 500
ohms/volt and DC sources need to
maintain electrical isolation no less than
100 ohms/volt. This is similar to
FMVSS No. 305.61
When the AC and DC sources are
conductively connected, GTR No. 13
affords three different methods for these
high voltage sources to achieve
compliance:
(1) All AC and DC sources maintain
minimum electrical isolation of 500
ohms/volt (this is basically the approach
of FMVSS No. 305);
(2) AC high voltage sources that are
linked to a DC high voltage source may
have a minimum of 100 ohms/volt
instead of 500 ohms/volt if the AC high
voltage source also has physical barrier
protection from direct and indirect
contact of high voltage sources; 62 or
(3) all AC and DC sources maintain a
minimum isolation resistance of 100
ohms/volt and all AC sources meet lowvoltage requirements in GTR No. 13.
Need for Amendment
After reviewing the Toyota petition
and other information, NHTSA
understands petitioners’ concern about
FMVSS No. 305’s electrical isolation
requirements for AC high voltage
sources under the conditions when the
AC and DC bus are conductively
connected. We tentatively believe that
an amendment is warranted to facilitate
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61 We
note that GTR No. 13 permits DC high
voltage sources to have 100 ohms/volt minimum
electrical isolation without specifying that the DC
high voltage sources must be equipped with an
electrical isolation monitoring system. While this
appears to differ from FMVSS No. 305, we do not
believe there is a practical difference. The only
vehicles needing to use FMVSS No. 305’s 100
ohms/volt electrical isolation compliance option for
DC high voltage sources are fuel cell vehicles. In
this NPRM, the agency is proposing to require all
DC high voltage sources of fuel cell vehicles to be
equipped with an electrical isolation monitoring
system. Therefore, while we propose to adopt the
post-crash electrical isolation requirements for DC
high voltage sources in GTR No. 13 into FMVSS No.
305 to further harmonization efforts, we do not
believe there would be an effect on vehicle design
or safety.
62 FMVSS No. 305 does not distinguish when the
AC and DC sources are connected from when AC
and DC sources are separated. The standard
specifies that all AC high voltage sources must have
a minimum electrical isolation of 500 ohms/volt.
The condition involving connected AC and DC high
voltage sources is germane to the Toyota petition.
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the manufacture of fuel cell and other
vehicles.
If FMVSS No. 305 were not amended,
the electrical isolation for fuel cell
stacks would need to be 500 ohms/volt
or greater to comply with FMVSS No.
305, which may not be technically
feasible.
Proposal for Electrical Isolation Option
In consideration of the above, NHTSA
is proposing to add an option that
would permit an AC high voltage source
that is connected to a DC high voltage
source post-crash to have electrical
isolation no less than 100 ohms/volt
provided the high voltage source also
meets physical barrier protection
requirements. Specifically, the electrical
isolation option for electrical safety in
the proposal requires that the electrical
isolation of a high voltage source be
greater than or equal to one of the
following:
(1) 500 ohms/volt for an AC high
voltage source; or
(2) 100 ohms/volt for an AC high
voltage source if it is conductively
connected to a DC high voltage source,
but only if the AC high voltage source
meets the physical barrier protection
requirements; or
(3) 100 ohms/volt for a DC high
voltage source.
NHTSA tentatively believes that
adding this option into the existing
FMVSS No. 305 requirements
essentially harmonizes with the
electrical isolation option in GTR No.
13. When an AC and DC high voltage
source are conductively connected, the
electrical isolation measured will be the
same for both high voltage sources and
approximately equal to the lower
electrical isolation measurement of the
two. Accordingly, the combined
electrical isolation of conductively
connected AC and DC high voltage
sources can be greater than or equal to
500 ohm/volt only if the electrical
isolation of each AC and DC high
voltage sources are greater than or equal
to 500 ohms/volt. Therefore the first
option for electrical isolation in GTR
No. 13 when an AC and DC high voltage
source are conductively connected is
redundant to what is already in FMVSS
No. 305 since it is equivalent to the
electrical isolation requirement when
the AC and DC high voltage sources are
conductively isolated from each other.
The third option for electrical isolation
in GTR No. 13 is unnecessary because
if an AC high voltage source meets low
voltage requirements, there is no need to
meet the electrical isolation
requirements.
We note, however, that the physical
barrier protection requirement in the
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proposed regulatory language to
accommodate a lower electrical
isolation level for a AC high voltage
source that is conductively connected to
a DC high voltage source is not the same
as that specified in GTR No. 13. The
physical barrier protection requirement
is an option each contracting party of
the 1998 agreement may elect to adopt.
As explained in the following section,
although our proposal in this document
chooses not to adopt the physical barrier
option in GTR No. 13 per se, we are
proposing to adopt a modified physical
barrier option. Based on the information
from the Battelle research, the Alliance
petition, the Toyota petition and other
sources, we tentatively believe that our
proposed physical barrier option will
afford the compliance flexibility that the
manufacturers desire while providing a
level of safety that is more comparable
to the other post-crash electric shock
compliance options.
Physical Barrier Protection
Need for Amendment
The Alliance petition for rulemaking
requested updates to FMVSS No. 305 for
facilitating the development and sale of
not only HFCVs but also 48 volt mild
hybrid vehicles. Because 48 volt
batteries are considered low voltage, the
48 volt mild hybrid systems are
designed with conductive connection to
the electric chassis and so are unable to
provide electrical isolation. While most
parts of the 48 volt mild hybrid system
would be considered low voltage per the
measurement to the chassis, the voltage
between different phases of the 3-phase
AC motor can be slightly greater than 30
VAC and so would be considered a high
voltage source.
The Alliance Petition
The agency has considered the
information provided by the Alliance
and by Mercedes-Benz 63 and tentatively
concludes that without an electrical
protection barrier option, 48 volt mild
hybrids will not be a practical
consideration for improving fuel
economy. In the absence of such an
option, these systems will need to be
electrically isolated from the chassis
and thereby result in higher mass,
reduced fuel economy, increased
emissions, and higher consumer costs.
Regarding the Battelle study, we first
begin by noting that we agree with the
Alliance’s analysis that for electric
63 We discussed the Mercedes-Benz information
earlier in this preamble, in the section describing
the Alliance’s petition for rulemaking, supra. 48 V
Systems—Powerful Innovative Technologies for
2020 FC Targets, Mercedes-Benz, Daimler AG, June
2, 2015. Available in the docket for this NPRM.
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powered vehicles that meet the
electrical isolation and physical barrier
protection requirement in GTR No. 13
during normal vehicle operation, there
is a very low likelihood that the various
safety critical scenarios identified in the
Battelle report with electric shock
potential would occur. The scenarios
would only be possible if multiple
failures of safety systems occurred,
along with human contact to very
specific locations. Be that as it may, the
Alliance petition also suggested
modifications to the electrical
protection barrier provisions in GTR No.
13, which it states provide the same
level of protection as the electrical
isolation option for electrical safety in
FMVSS No. 305 along with protection
from the safety critical scenarios
identified in the Battelle report.
The physical barrier protection option
in the Alliance petition specifies two
optional methods of providing physical
barrier protection from direct and
indirect contact of high voltage sources.
The first method (Option 1) requires an
AC or DC high voltage source to have:
1. Direct contact protection degree
IPXXB,
2. All exposed conductive parts of
electrical protection barriers are
conductively connected to electrical
chassis with resistance less than 0.1
ohms, and
3. The electrical isolation between the
high voltage source and the electrical
protection barrier enclosing it is greater
than or equal to 0.05 ohms/VAC or 0.01
ohms/VDC.
The second method (Option 2)
requires an AC or DC high voltage
source to have:
1. Direct contact protection degree
IPXXB.
2. The voltage between the electrical
protection barrier and other exposed
conductive parts is low voltage (30 VAC
or 60 VDC).
mstockstill on DSK4VPTVN1PROD with PROPOSALS
Technical Analysis
The physical barrier protection
provides electrical safety via electrical
protection barriers that are placed
around high voltage components to
insure that there is no direct or indirect
human contact with live high voltage
sources during normal vehicle operation
or after a vehicle crash. For protection
against contact with live parts in postcrash conditions, a test probe designed
to simulate a small human finger (12
mm) conforming to ISO 20653 ‘‘Road
vehicles—Degrees of protection (IPCode)—Protection of electrical
equipment against foreign objects,
water, and access (IPXXB)’’ is specified
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in GTR No. 13.64 The agency notes that
protection against direct contact of high
voltage sources is currently not
specified in FMVSS No. 305 and so
adding such a provision into FMVSS
No. 305 would further enhance
protection from electric shock. The
IPXXB finger probe is utilized in other
standards 65 for protecting electrical
maintenance personnel from
inadvertently contacting high voltage
during servicing of electrical equipment.
Therefore, NHTSA tentatively believes
protection level using the simulated
human finger probe (IPXXB) to prohibit
inadvertent contact by passengers and
first responders with high voltage
components contained within protective
enclosures is appropriate.66
NHTSA reviewed 67 the Alliance’s
proposal for a post-crash electrical
protection barrier option for FMVSS No.
305 and confirmed that the electric
current Ib through the body (with
minimum resistance of 500 ohms) in
Figure 9, supra, is less than or equal to
10 mA DC or less than or equal to 2 mA
AC under various scenarios, as long as
the three requirements for the Alliancesuggested Option 1 for post-crash
physical barrier protection are met.
These are: 1. Direct contact protection
degree IPXXB, 2. all exposed conductive
parts are conductively connected to
electrical chassis with resistance less
than 0.1 ohms, and 3. the combined
resistance of R1 and R2 and the
resistance of the conductive connection
of the electrical protection barrier to the
chassis is greater than or equal to 0.05
ohms/VAC or 0.01 ohms/VDC. When all
three conditions in the Option 1
physical barrier protection suggested by
Alliance are met, the agency’s analysis
showed that in the event of loss in
electrical isolation, the body current is
limited to safe levels under the various
safety critical scenarios identified in the
Battelle study. The agency’s analysis
64 IEC60529 Second edition 1989–11 + Am. 1
1999–11, EN60529, ‘‘Degrees of protection provided
by enclosures.’’
65 For example, IEC 60479, ‘‘Low voltage
switchgear and control gear assemblies,’’ uses
IPXXB level protection for preventing contact with
high voltage sources by maintenance personnel.
The voltage levels considered in IEC 60479 are
similar to those in automotive application.
66 The use of the IPXXB finger probe as opposed
to the IPXXD wire probe for evaluating direct
contact protection after a crash test is appropriate.
The IPXXD is intended to evaluate contact with
high voltage sources inside the passenger or luggage
compartment during normal vehicle operation to
ensure that body parts, miscellaneous tools or other
slender conductive items typically encountered in
a passenger or luggage compartment cannot
penetrate any gaps/seams in the protective
enclosures and contact high voltage components
contained within.
67 Supporting technical document in the docket of
this NPRM.
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12667
also confirmed that when the above
conditions are met, the voltage between
barrier #1 and barrier #2 in Figure 9 is
less than or equal to 30 VAC or 60 VDC,
as the Alliance noted.68
The specification that the conductive
connection between a protection barrier
and the chassis be less than 0.1 ohm
provides protection from electric shock
by shunting any harmful electrical
currents through the vehicle chassis
(rather than through a human contacting
the protection barrier) should any
electrically charged components lose
isolation within the protective barrier.
The 0.1 ohms resistance level for
electrical bonding (or conductive
connection) is well established in
international standards both in and out
of the automotive industry (e.g. MIL_B_
5087, NASA Technical Standard NSA–
STD–P023 ‘‘Electrical Bonding for
NASA Launch Vehicles, Payloads, and
Flight Equipment,’’ ISO6469, ECE–
R100, and IEC 60335–1 ‘‘Household and
Similar Electrical Appliances’’ Part 1:
General Requirements). For these
reasons, NHTSA accepts that the
resistance of the conductive connection
between the protective barrier and the
electrical chassis be less than 0.1 ohms.
However, the agency sought
clarification on the indirect contact
protection requirement of Option 1
suggested by the Alliance, which states
that, ‘‘The resistance between exposed
conductive parts of the electrical
protection barrier(s) and the electrically
conductive chassis is less than 0.1 ohms
where there is a current flow of at least
0.2 A.’’ NHTSA noted that the
maximum allowable resistance for the
electrical chassis was not specified and
asked the Alliance how its suggested
Option 1 would afford adequate indirect
contact protection when exposed
conductive parts of two electrical
protection barriers were contacted
simultaneously instead of simultaneous
contact of an electrical protection
barrier and the chassis.
68 For example, an analysis of the circuit in Figure
9 was conducted using the following values for the
components in the circuit: Vb = 1000 VDC, bonding
resistance bond #1 and bond #2 equal to 0.1 ohm,
R1 and R2 resistances equal to 20 ohms, and body
resistance equal to 500 ohms. This resulted in a
combined resistance of R1 and R2 and bonding
resistance to chassis of 10.05 ohms (or 0.01005
ohms/volt electrical isolation from the chassis) and
current through the body of 9.95 mA (<10 mA
considered as safe level of current). The analysis
also showed that in this example, the voltage
between barrier #1 and barrier #2 is equal to 4.97
volt (<60 volt is considered to be low voltage). This
is further explained in the supporting technical
document in the docket of this NPRM.
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In response,69 the Alliance
acknowledged that the effective
resistance between two exposed
conductive parts of the electrical
protection barriers was not well defined
in its proposal. The petitioner stated
that in order to address the fact that
there are no resistance specifications for
the electrically conductive chassis, it
recommends the addition of a
performance requirement that limits the
maximum resistance between any two
exposed conductive parts of the
electrical protection barriers to less than
0.2 ohms (which corresponds to the
requirement that maximum resistance
between the protective physical barrier
and the electrical chassis is less than 0.1
ohms). The Alliance also stated that the
resistance measurements between any
two exposed conductive parts of the
electrical protection barriers should be
limited to those that can be
simultaneously contacted by a human.
The petitioner stated its belief that
limiting the resistance measurement to
a distance of 2.5 meter 70 would ensure
that any surfaces that can be
simultaneously contacted by a human
be subjected to the proposed
performance requirements. The
petitioner noted that such a distance
limitation would significantly reduce
the test burden (number of test points)
while maintaining the same level of
safety. Accordingly, the Alliance offered
the following modification to the text in
SAE J1766 regarding indirect contact
protection requirements and requested
that NHTSA seek comment on it in an
NPRM.
mstockstill on DSK4VPTVN1PROD with PROPOSALS
[Petitioner’s suggested requirement]
S5.3.4(2)—The bonding resistance between
any exposed conductive parts of the
electrical protection barriers and the
vehicle’s electrical chassis shall not exceed
0.1 ohms. This requirement is deemed
satisfied if the galvanic connection has been
made by welding and the weld is intact after
each of the specified crash tests. In addition,
the bonding resistance between any two
simultaneously reachable exposed
conductive parts of the electrical protection
barriers in a distance of 2.5 meters shall not
exceed 0.2 ohms. See C.2.1 for the applicable
test procedure.
The agency tentatively concludes that
this modification responds to NHTSA’s
concern about the lack of resistance
specification for the electrical chassis
and the lack of low resistance
69 Alliance’s response to NHTSA’s questions is in
the docket of this NPRM.
70 This distance specification was obtained from
IEC 60364–4–41. ‘‘Low-voltage electrical
installations—Part 4–4—Protection against electric
shock.’’: Annex B (Obstacles and Placing out of
Reach), and ISO6469–3,:2011, ‘‘Electrically
propelled road vehicles—Safety specifications—
Part 3: Protection of persons against electric shock.’’
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specification between two electrical
protection barriers that can be contacted
simultaneously.71 However, we note
that the requirement in the suggested
S5.3.4(2) above is for the resistance to be
less than or equal to 0.1 ohms and 0.2
ohms, while SAE J1766 January 2014
and GTR No. 13 specify that the
resistance be less than 0.1 ohms. For
purposes of harmonization with GTR
No. 13, the agency proposes to use ‘‘less
than 0.1 ohms’’ and ‘‘less than 0.2
ohms.’’
The proposed modification suggested
by the Alliance also states, ‘‘This
requirement is deemed satisfied if the
galvanic connection has been made by
welding and the weld is intact after each
of the specified crash tests.’’ We believe
that such a method of assessing
compliance of indirect contact
protection by visually inspecting the
welding lacks objectivity that is needed
for FMVSS. Therefore, NHTSA proposes
not including this method for evaluating
compliance. Instead, the agency
proposes to include the test procedure
in GTR No. 13 and SAE J1766 January
2014 that determines the resistance
between an electrical protection barrier
and the chassis and between two
electrical protection barriers by passing
through a current of at least 0.2 A.
NHTSA seeks comment on its proposal
not to include assessing compliance of
a conductive connection by means of
visual inspection.
The agency’s review had also
indicated that the Alliance’s proposed
Option 2 for physical barrier protection
(direct contact protection degree IPXXB
and the voltage between barrier #1 and
barrier #2 is less than or equal to 30
VAC or 60 VDC) does not guarantee that
the current through the body is less than
10 mA DC and 2 mA AC for all
scenarios.72 NHTSA requested that the
Alliance provide clarification on this
71 NHTSA’s analysis using 0.2 ohm resistance
(instead of 0.1 ohm) between two protective barriers
along with IPXXB protection and isolation between
high voltage source and the protective barrier of
0.01 ohm/VDC or 0.05 ohm/VAC results in safe
current levels through the body (10 mA DC or 2 mA
AC). See details of NHTSA’s analysis in the
supporting technical document in the docket of this
NPRM.
72 For example, an analysis of the circuit in Figure
9 was conducted using the following values for the
components in the circuit: Vb = 1000 VDC, bonding
resistance bond #1 and bond #2 equal to 0.1 ohm,
R1 and R2 resistances equal to 1.6 ohms, and body
resistance equal to 500 ohms. This resulted in a
combined resistance of R1 and R2 and bonding
resistance to chassis of 0.85 ohms (or 0.00085
ohms/volt electrical isolation from chassis) and
current through the body of 117 mA (>10 mA is
considered an unsafe level of current). The analysis
also showed that in this example, the voltage
between barrier #1 and barrier #2 is equal to 58.52
volt (<60 volt is considered to be low voltage). This
is further explained in the supporting technical
document in the docket of this NPRM.
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matter. The Alliance responded 73 that
FMVSS No. 305 already recognizes
these low voltage thresholds, both with
respect to the applicability of the
standard and with respect to the
electrical safety provisions of the
standard. The Alliance also noted that
GTR No. 13 and numerous other
government regulations and industry
standards recognize these low voltage
threshold levels for automotive
applications.74 The Alliance observed
that for voltage below or equal to 30
VAC and 60 VDC, the potential body
current is below the let-go limit 75 and
below the limit for electric shock with
non-reversible harm. The Alliance
stated that it is for these reasons that
voltage levels below 30 VAC and 60
VDC are designated worldwide as low
voltage without safety concern.76
NHTSA tentatively agrees with the
clarification provided by the Alliance
that voltage levels at or lower than 30
VAC and 60 VDC are already specified
as low voltage in FMVSS No. 305 and
at these voltage levels, the potential
body current is below the limit for
electric shock. Currently, the European
Union, Japan, and Korea, permit
compliance for electrical safety using
the electrical protection barrier option
in GTR No. 13 and NHTSA is not aware
of any incidence of electrical shock
during normal operation and after a
crash.
The Alliance suggested adopting
Option 2 for physical barrier protection
rather than Option 1 because it is
difficult to measure electrical isolation
between the high voltage source and
exposed conductive parts of its
electrical protection barrier, which is
needed to assess compliance with
Option 1.77 Additionally, the agency’s
analysis confirms that of the Alliance’s,
that if the three conditions of Option 1
are met, the two conditions of Option 2
would also be met and in the event of
loss of electrical isolation, the current
through a body contacting electrical
protection barriers is within safe levels
73 Alliance’s response to NHTSA’s questions is in
the docket of this NPRM.
74 Electrical safety requirements in Europe, Japan,
and Korea and SAE J1766 recognize voltage levels
less than or equal to 30 VAC or 60 VDC as low
voltage.
75 Maximum value of touch current at which a
person holding electrodes can let go of the
electrodes.
76 The Alliance also noted its belief that the
indirect contact scenarios identified in the Battelle
study are extremely rare and that in setting
appropriate safety measures, the probability of
faults, probability of contact with live parts, and the
ratio of touch voltage and fault voltage needs to be
considered.
77 The Alliance did not specify a test procedure
to determine electrical isolation between the high
voltage source and its electrical protection barrier.
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(same level of safety as that afforded by
post-crash electrical isolation
requirements).
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NHTSA’s Proposal for Physical Barrier
Protection
In consideration of the above
technical analysis, the agency is
proposing to combine Alliance’s
suggested Option 1 and Option 2
requirements for electrical protection
barriers. Specifically, the agency
proposes the following requirements for
an electrical protection barrier of a high
voltage source:
(1) Direct contact protection degree
IPXXB,
(2) indirect contact protection
(electrical protection barriers are
conductively connected to the chassis
with resistance less than 0.1 ohms and
resistance between two electrical
protection barriers that are accessible
within 2.5 meters is less than 0.2 ohms),
and
(3) low voltage of 30 VAC or 60VDC
between the electrical protection barrier
and other exposed conductive parts.
The first two conditions are specified
in GTR No. 13 and (1) and (3) together
is the same as Option 2 suggested by the
Alliance. We concur that there is merit
to the third condition since FMVSS No.
305 already recognizes voltages less
than or equal to 30 VAC and 60 VDC as
low voltage. Our technical analysis
confirms that the proposed post-crash
physical barrier protection option (with
the first two requirements in GTR No.
13 and an additional third requirement
that electrical protection barriers be low
voltage) affords the same level of safety
as the post-crash electrical isolation
option currently in FMVSS No. 305.
NHTSA seeks comment on the
proposed inclusion of the physical
barrier protection option into FMVSS
No. 305. NHTSA also seeks comment on
its proposed physical barrier protection
requirements which combine the
requirements in GTR No. 13 and Option
2 in the Alliance petition. The agency
also seeks comment on the proposed
test procedures for assessing physical
barrier protection.
Toyota’s Request for Amending PostCrash Test Procedure
In its December 23, 2013 petition for
rulemaking, Toyota requests that
NHTSA amend S6.4 of FMVSS No. 305,
which requires a vehicle to satisfy all of
the post-crash performance
requirements ‘‘after being rotated on its
longitudinal axis to each successive
increment of 90 degrees. . . .’’ Toyota
recommends that the tests to evaluate
electrical isolation and physical barrier
protection requirements be performed
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after the vehicle is rotated a full 360
degrees. Toyota states that the vehicle
conditions related to these requirements
do not change at various increments of
a rollover, and it would be increasingly
dangerous for laboratory personnel to
conduct the specified tests with the
vehicle at other 90 degree increments.
NHTSA has evaluated Toyota’s
request and is denying it. NHTSA does
not agree with Toyota’s assessment that
the vehicle conditions related to
electrical safety requirements do not
change at various increments of
rollover. Post-crash direct contact
protection is assessed by first opening,
disassembling, or removing electrical
protection barriers, solid insulator, and
connectors without the use of tools, and
then the IPXXB probe is used to
determine if high voltage sources can be
contacted. This evaluation may yield
different results for the different
attitudes of the vehicle. For example,
high voltage sources may be more
accessible when the vehicle is rotated
90 degrees than when upright. NHTSA
is not aware of unreasonably dangerous
conditions to laboratory personnel in
conducting the specified tests with the
vehicle at 90 degree increments. Toyota
did not provide any supporting data to
substantiate its case. NHTSA seeks
comment on this issue.
X. Rulemaking Analyses and Notices
Executive Order 12866 and DOT
Regulatory Policies and Procedures
This rulemaking document was not
reviewed by the Office of Management
and Budget under E.O. 12866. It is not
considered to be significant under E.O.
12866 or the Department’s Regulatory
Policies and Procedures. The
amendments proposed by this NPRM
would have no significant effect on the
national economy, as the requirements
are already in voluntary industry
standards and international standards
that current electric powered vehicles
presently meet.
This NPRM proposes to update
FMVSS No. 305 to incorporate the
electrical safety requirements in GTR
No. 13. This proposal also responds to
petitions for rulemaking from Toyota
and the Alliance to facilitate the
introduction of fuel cell vehicles and 48
volt mild hybrid technologies into the
vehicle fleet. The proposal adds
electrical safety requirements in GTR
No. 13 that involves electrical isolation
and direct and indirect contact
protection of high voltage sources to
prevent electric shock during normal
operation of electric powered vehicles.
Today’s proposal also provides an
additional optional method of meeting
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post-crash electrical safety requirements
in FMVSS No. 305 that involves
physical barriers of high voltage sources
to prevent electric shock due to direct
and indirect contact with live parts.
Since there is widespread conformance
with the requirements that would apply
to existing vehicles, we anticipate no
costs or benefits associated with this
rulemaking.
Regulatory Flexibility Act
NHTSA has considered the effects of
this NPRM under the Regulatory
Flexibility Act (5 U.S.C. 601 et seq., as
amended by the Small Business
Regulatory Enforcement Fairness Act
(SBREFA) of 1996). I certify that this
NPRM would not have a significant
economic impact on a substantial
number of small entities. Any small
manufacturers that might be affected by
this NPRM are already subject to the
requirements of FMVSS No. 305.
Further, the agency believes the testing
associated with the requirements added
by this NPRM are not substantial and to
some extent are already being
voluntarily borne by the manufacturers
pursuant to SAE J1766. Therefore, there
will be only a minor economic impact.
National Environmental Policy Act
NHTSA has analyzed this rulemaking
action for the purposes of the National
Environmental Policy Act. The agency
has determined that implementation of
this action will not have any significant
impact on the quality of the human
environment.
Executive Order 13132 (Federalism)
NHTSA has examined today’s NPRM
pursuant to Executive Order 13132 (64
FR 43255; Aug. 10, 1999) and concluded
that no additional consultation with
States, local governments, or their
representatives is mandated beyond the
rulemaking process. The agency has
concluded that the proposal does not
have sufficient federalism implications
to warrant consultation with State and
local officials or the preparation of a
federalism summary impact statement.
The proposal does not have ‘‘substantial
direct effects on the States, on the
relationship between the national
government and the States, or on the
distribution of power and
responsibilities among the various
levels of government.’’
NHTSA rules can have preemptive
effect in two ways. First, the National
Traffic and Motor Vehicle Safety Act
contains an express preemption
provision:
When a motor vehicle safety standard
is in effect under this chapter, a State or
a political subdivision of a State may
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prescribe or continue in effect a
standard applicable to the same aspect
of performance of a motor vehicle or
motor vehicle equipment only if the
standard is identical to the standard
prescribed under this chapter. 49 U.S.C.
30103(b)(1).
It is this statutory command that
preempts any non-identical State
legislative and administrative law 78
addressing the same aspect of
performance, not today’s rulemaking, so
consultation would be inappropriate.
Second, the Supreme Court has
recognized the possibility, in some
instances, of implied preemption of
State requirements imposed on motor
vehicle manufacturers, including
sanctions imposed by State tort law.
That possibility is dependent upon
there being an actual conflict between a
FMVSS and the State requirement. If
and when such a conflict exists, the
Supremacy Clause of the Constitution
makes the State requirements
unenforceable. See Geier v. American
Honda Motor Co., 529 U.S. 861 (2000),
finding implied preemption of state tort
law on the basis of a conflict discerned
by the court,79 not on the basis of an
intent to preempt asserted by the agency
itself.
NHTSA has considered the nature
(e.g., the language and structure of the
regulatory text) and objectives of today’s
NPRM and does not discern any existing
State requirements that conflict with the
rule or the potential for any future State
requirements that might conflict with it.
Without any conflict, there could not be
any implied preemption of state law,
including state tort law.
Executive Order 12988 (Civil Justice
Reform)
With respect to the review of the
promulgation of a new regulation,
section 3(b) of Executive Order 12988,
‘‘Civil Justice Reform’’ (61 FR 4729; Feb.
7, 1996), requires that Executive
agencies make every reasonable effort to
ensure that the regulation: (1) Clearly
specifies the preemptive effect; (2)
clearly specifies the effect on existing
Federal law or regulation; (3) provides
a clear legal standard for affected
conduct, while promoting simplification
and burden reduction; (4) clearly
specifies the retroactive effect, if any; (5)
specifies whether administrative
proceedings are to be required before
78 The issue of potential preemption of state tort
law is addressed in the immediately following
paragraph discussing implied preemption.
79 The conflict was discerned based upon the
nature (e.g., the language and structure of the
regulatory text) and the safety-related objectives of
FMVSS requirements in question and the impact of
the State requirements on those objectives.
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parties file suit in court; (6) adequately
defines key terms; and (7) addresses
other important issues affecting clarity
and general draftsmanship under any
guidelines issued by the Attorney
General. This document is consistent
with that requirement.
Pursuant to this Order, NHTSA notes
as follows. The issue of preemption is
discussed above. NHTSA notes further
that there is no requirement that
individuals submit a petition for
reconsideration or pursue other
administrative proceedings before they
may file suit in court.
Privacy Act
Please note that anyone is able to
search the electronic form of all
comments received into any of our
dockets by the name of the individual
submitting the comment (or signing the
comment, if submitted on behalf of an
association, business, labor union, etc.).
You may review DOT’s complete
Privacy Act Statement in the Federal
Register published on April 11, 2000
(65 FR 19477–78), or online at https://
www.dot.gov/privacy.html.
Paperwork Reduction Act
Under the Paperwork Reduction Act
of 1995 (PRA), a person is not required
to respond to a collection of information
by a Federal agency unless the
collection displays a valid OMB control
number. There are no information
collection requirements associated with
this NPRM.
National Technology Transfer and
Advancement Act
Section 12(d) of the National
Technology Transfer and Advancement
Act of 1995 (NTTAA), Public Law 104–
113, as amended by Public Law 107–107
(15 U.S.C. 272), directs the agency to
evaluate and use voluntary consensus
standards in its regulatory activities
unless doing so would be inconsistent
with applicable law or is otherwise
impractical. Voluntary consensus
standards are technical standards (e.g.,
materials specifications, test methods,
sampling procedures, and business
practices) that are developed or adopted
by voluntary consensus standards
bodies, such as the Society of
Automotive Engineers (SAE). The
NTTAA directs us to provide Congress
(through OMB) with explanations when
the agency decides not to use available
and applicable voluntary consensus
standards. The NTTAA does not apply
to symbols.
FMVSS No. 305 has historically
drawn largely from SAE J1766, and does
so again for this current rulemaking,
which proposes revisions to FMVSS No.
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305 to facilitate the development of fuel
cell and 48 volt mild hybrid
technologies. It is based on GTR No. 13
and the latest version of SAE J1766
January 2014.
Unfunded Mandates Reform Act
Section 202 of the Unfunded
Mandates Reform Act of 1995 (UMRA),
Public Law 104–4, requires Federal
agencies to prepare a written assessment
of the costs, benefits, and other effects
of proposed or final rules that include
a Federal mandate likely to result in the
expenditure by State, local, or tribal
governments, in the aggregate, or by the
private sector, of more than $100
million annually (adjusted for inflation
with base year of 1995). Adjusting this
amount by the implicit gross domestic
product price deflator for the year 2013
results in $142 million (106.733/75.324
= 1.42). This NPRM would not result in
a cost of $142 million or more to either
State, local, or tribal governments, in the
aggregate, or the private sector. Thus,
this NPRM is not subject to the
requirements of sections 202 of the
UMRA.
Executive Order 13609 (Promoting
Regulatory Cooperation)
The policy statement in section 1 of
Executive Order 13609 provides, in part:
The regulatory approaches taken by
foreign governments may differ from
those taken by U.S. regulatory agencies
to address similar issues. In some cases,
the differences between the regulatory
approaches of U.S. agencies and those of
their foreign counterparts might not be
necessary and might impair the ability
of American businesses to export and
compete internationally. In meeting
shared challenges involving health,
safety, labor, security, environmental,
and other issues, international
regulatory cooperation can identify
approaches that are at least as protective
as those that are or would be adopted in
the absence of such cooperation.
International regulatory cooperation can
also reduce, eliminate, or prevent
unnecessary differences in regulatory
requirements.
The agency participated in the
development of GTR No. 13 to
harmonize the standards of fuel cell
vehicles. As a signatory member,
NHTSA is proposing to incorporate
electrical safety requirements and
options specified in GTR No. 13 into
FMVSS No. 305.
Regulation Identifier Number
The Department of Transportation
assigns a regulation identifier number
(RIN) to each regulatory action listed in
the Unified Agenda of Federal
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Regulations. The Regulatory Information
Service Center publishes the Unified
Agenda in April and October of each
year. You may use the RIN contained in
the heading at the beginning of this
document to find this action in the
Unified Agenda.
Plain Language
Executive Order 12866 requires each
agency to write all rules in plain
language. Application of the principles
of plain language includes consideration
of the following questions:
• Have we organized the material to
suit the public’s needs?
• Are the requirements in the rule
clearly stated?
• Does the rule contain technical
language or jargon that isn’t clear?
• Would a different format (grouping
and order of sections, use of headings,
paragraphing) make the rule easier to
understand?
• Would more (but shorter) sections
be better?
• Could we improve clarity by adding
tables, lists, or diagrams?
• What else could we do to make the
rule easier to understand?
If you have any responses to these
questions, please write to us with your
views.
XI. Public Participation
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How do I prepare and submit
comments?
Your comments must be written and
in English. To ensure that your
comments are correctly filed in the
Docket, please include the docket
number of this document in your
comments.
Your comments must not be more
than 15 pages long. (49 CFR 553.21). We
established this limit to encourage you
to write your primary comments in a
concise fashion. However, you may
attach necessary additional documents
to your comments. There is no limit on
the length of the attachments.
Comments may also be submitted to
the docket electronically by logging onto
the Docket Management System Web
site at https://www.regulations.gov.
Follow the online instructions for
submitting comments.
Please note that pursuant to the Data
Quality Act, in order for substantive
data to be relied upon and used by the
agency, it must meet the information
quality standards set forth in the OMB
and DOT Data Quality Act guidelines.
Accordingly, we encourage you to
consult the guidelines in preparing your
comments. OMB’s guidelines may be
accessed at https://www.whitehouse.gov/
omb/fedreg/reproducible.html.
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How can I be sure that my comments
were received?
If you wish Docket Management to
notify you upon its receipt of your
comments, enclose a self-addressed,
stamped postcard in the envelope
containing your comments. Upon
receiving your comments, Docket
Management will return the postcard by
mail.
comments in the docket. See
www.regulations.gov for more
information.
How do I submit confidential business
information?
If you wish to submit any information
under a claim of confidentiality, you
should submit three copies of your
complete submission, including the
information you claim to be confidential
business information, to the Chief
Counsel, NHTSA, at the address given
above under FOR FURTHER INFORMATION
CONTACT. In addition, you should
submit a copy, from which you have
deleted the claimed confidential
business information, to the docket at
the address given above under
ADDRESSES. When you send a comment
containing information claimed to be
confidential business information, you
should include a cover letter setting
forth the information specified in our
confidential business information
regulation. (49 CFR part 512)
12671
PART 571—FEDERAL MOTOR
VEHICLE SAFETY STANDARDS
Will the agency consider late
comments?
We will consider all comments
received before the close of business on
the comment closing date indicated
above under DATES. To the extent
possible, we will also consider
comments that the docket receives after
that date. If the docket receives a
comment too late for us to consider in
developing a final rule (assuming that
one is issued), we will consider that
comment as an informal suggestion for
future rulemaking action.
How can I read the comments submitted
by other people?
You may read the comments received
by the docket at the address given above
under ADDRESSES. The hours of the
docket are indicated above in the same
location. You may also see the
comments on the Internet. To read the
comments on the Internet, go to https://
www.regulations.gov. Follow the online
instructions for accessing the dockets.
Please note that even after the
comment closing date, we will continue
to file relevant information in the docket
as it becomes available. Further, some
people may submit late comments.
Accordingly, we recommend that you
periodically check the Docket for new
material. You can arrange with the
docket to be notified when others file
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List of Subjects in 49 CFR Part 571
Imports, Motor vehicles, Motor
vehicle safety.
In consideration of the foregoing,
NHTSA proposes to amend 49 CFR part
571 as follows:
1. The authority citation for part 571
continues to read as follows:
■
Authority: 49 U.S.C. 322, 30111, 30115,
30117, and 30166; delegation of authority at
49 CFR 1.95.
2. In § 571.305:
a. Revise S1 and S2;
b. Under S4:
i. Add in alphabetical order
definitions for ‘‘Charge connector’’,
‘‘Direct contact’’, ‘‘Electrical protection
barrier’’, ‘‘Exposed conductive part’’,
‘‘External electric power supply’’, ‘‘Fuel
cell system’’, ‘‘Indirect contact’’, ‘‘Live
part’’, ‘‘Luggage compartment’’,
‘‘Passenger compartment’’, and
‘‘Possible active driving mode’’;
■ ii. Revise the definition of
‘‘Propulsion system’’; and
■ iii. Add in alphabetical order
definitions for ‘‘Protection degree
IPXXB’’, ‘‘Protection degree IPXXD’’,
‘‘Service disconnect’’, and ‘‘Vehicle
charge inlet’’;
■ c. Revise S5.3 and S5.4; and
■ d. Add S5.4.1, S5.4.1.1, S5.4.1.1.1,
S5.4.1.2, S5.4.1.3, S5.4.1.4, S5.4.2,
S5.4.2.1, S5.4.2.2, S5.4.3, S5.4.3.1,
S5.4.3.2, S5.4.3.3, S5.4.4, S5.4.5, S5.4.6,
S5.4.6.1, S5.4.6.2, S5.4.6.3, S9, S9.1,
S9.2, S9.3, and figures 6, 7a, 7b, and 8.
The revisions and additions read as
follows:
■
■
■
■
§ 571.305 Standard No. 305; Electricpowered vehicles: electrolyte spillage and
electrical shock protection.
S1. Scope. This standard specifies
requirements for limitation of
electrolyte spillage and retention of
electric energy storage/conversion
devices during and after a crash, and
protection from harmful electric shock
during and after a crash and during
normal vehicle operation.
S2. Purpose. The purpose of this
standard is to reduce deaths and injuries
during and after a crash that occur
because of electrolyte spillage from
electric energy storage devices,
intrusion of electric energy storage/
conversion devices into the occupant
compartment, and electrical shock, and
to reduce deaths and injuries during
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normal vehicle operation that occur
because of electric shock.
*
*
*
*
*
S4. Definitions.
*
*
*
*
*
Charge connector is a conductive
device that, by insertion into a vehicle
charge inlet, establishes an electrical
connection of the vehicle to the external
electric power supply for the purpose of
transferring energy and exchanging
information.
Direct contact is the contact of
persons with high voltage live parts.
*
*
*
*
*
Electrical protection barrier is the part
providing protection against direct
contact with live parts from any
direction of access.
Exposed conductive part is the
conductive part that can be touched
under the provisions of the IPXXB
protection degree and becomes
electrically energized under isolation
failure conditions. This includes parts
under a cover that can be removed
without using tools.
External electric power supply is a
power supply external to the vehicle
that provides electric power to charge
the propulsion battery in the vehicle.
Fuel cell system is a system
containing the fuel cell stack(s), air
processing system, fuel flow control
system, exhaust system, thermal
management system, and water
management system.
*
*
*
*
*
Indirect contact is the contact of
persons with exposed conductive parts.
Live part is a conductive part of the
vehicle that is electrically energized
under normal vehicle operation.
Luggage compartment is the space in
the vehicle for luggage accommodation,
separated from the passenger
compartment by the front or rear
bulkhead and bounded by a roof, hood,
floor, and side walls, as well as by the
electrical barrier and enclosure
provided for protecting the power train
from direct contact with live parts.
Passenger compartment is the space
for occupant accommodation that is
bounded by the roof, floor, side walls,
doors, outside glazing, front bulkhead
and rear bulkhead or rear gate, as well
as electrical barriers and enclosures
provided for protecting the occupants
from direct contact with live parts.
Possible active driving mode is the
vehicle mode when application of
pressure to the accelerator pedal (or
activation of an equivalent control) or
release of the brake system causes the
electric power train to move the vehicle.
Propulsion system means an assembly
of electric or electro-mechanical
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components or circuits that propel the
vehicle using the energy that is supplied
by a high voltage source. This includes,
but is not limited to, electric motors,
inverters/converters, and electronic
controllers.
Protection degree IPXXB is protection
from contact with high voltage live
parts. It is tested by probing electrical
protection barriers or enclosures with
the jointed test finger probe, IPXXB, in
Figure 7b.
Protection degree IPXXD is protection
from contact with high voltage live
parts. It is tested by probing electrical
protection barriers or enclosures with
the test wire probe, IPXXD, in Figure 7a.
Service disconnect is the device for
deactivation of an electrical circuit
when conducting checks and services of
the vehicle electrical propulsion system.
*
*
*
*
*
Vehicle charge inlet is the device on
the electric vehicle into which the
charge connector is inserted for the
purpose of transferring energy and
exchanging information from an
external electric power supply.
*
*
*
*
*
S5.3 Electrical safety. After each test
specified in S6 of this standard, each
high voltage source in a vehicle must
meet the electrical isolation
requirements of paragraph S5.3(a) of
this section, the voltage level
requirements of paragraph S5.3(b) of
this section, or the physical barrier
protection requirements of paragraph
S5.3(c) of this section.
(a) The electrical isolation of the high
voltage source, determined in
accordance with the procedure specified
in S7.6 of this section, must be greater
than or equal to one of the following:
(1) 500 ohms/volt for an AC high
voltage source; or
(2) 100 ohms/volt for an AC high
voltage source if it is conductively
connected to a DC high voltage source,
but only if the AC high voltage source
meets the physical barrier protection
requirements specified in paragraph
S5.3(c) of this section; or
(3) 100 ohms/volt for a DC high
voltage source.
(b) The voltages V1, V2, and Vb of the
high voltage source, measured according
to the procedure specified in S7.7 of this
section, must be less than or equal to 30
VAC for AC components or 60 VDC for
DC components.
(c) Protection against electric shock by
direct and indirect contact (physical
barrier protection) shall be
demonstrated by meeting the following
three conditions:
(1) The high voltage source (AC or
DC) meets the protection degree IPXXB
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when tested under the procedure
specified in S9.1 of this section using
the IPXXB test probe shown in Figures
7a and 7b to this section;
(2) The resistance between exposed
conductive parts of the electrical
protection barriers and the electrical
chassis is less than 0.1 ohms when
tested under the procedures specified in
S9.2 of this section. In addition, the
resistance between any two
simultaneously reachable exposed
conductive parts of the electrical
protection barriers that are less than 2.5
meters from each other is less than 0.2
ohms when tested under the procedures
specified in S9.2 of this section; and
(3) The voltages between the electrical
protection barrier enclosing the high
voltage source and other exposed
conductive parts are less than or equal
to 30 VAC or 60 VDC as measured in
accordance with S9.3 of this section.
S5.4 Electrical safety during normal
vehicle operation.
S5.4.1 Protection against direct
contact.
S5.4.1.1 Marking. The symbol
shown in Figure 6 to this section shall
be visible on or near electric energy
storage/conversion devices. The symbol
in Figure 6 to this section shall also be
visible on electrical protection barriers
which, when removed, expose live parts
of high voltage sources. The symbol
shall be yellow and the bordering and
the arrow shall be black.
S5.4.1.1.1 The marking is not
required for electrical protection
barriers that cannot be physically
accessed, opened, or removed without
the use of tools.
S5.4.1.2 High voltage cables. Cables
for high voltage sources which are not
located within enclosures shall be
identified by having an outer covering
with the color orange.
S5.4.1.3 Service disconnect. For a
service disconnect which can be
opened, disassembled, or removed
without tools, protection degree IPXXB
shall be provided when tested under
procedures specified in S9.1 of this
section using the IPXXB test probe
shown in Figures 7a and 7b to this
section.
S5.4.1.4 Protection degree of high
voltage sources and live parts.
(a) Protection degree IPXXD shall be
provided for live parts and high voltage
sources inside the passenger or luggage
compartment when tested under
procedures specified in S9.1 of this
section using the IPXXD test probe
shown in Figure 7a to this section.
(b) Protection degree IPXXB shall be
provided for live parts and high voltage
sources in areas other than the
passenger or luggage compartment when
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tested under procedures specified in
S9.1 of this section using the IPXXB test
probe shown in Figures 7a and 7b to
this section.
S5.4.2 Protection against indirect
contact.
S5.4.2.1 The resistance between all
exposed conductive parts and the
electrical chassis shall be less than 0.1
ohms when tested under the procedures
specified in S9.2 of this section.
S5.4.2.2 The resistance between any
two simultaneously reachable exposed
conductive parts of the electrical
protection barriers that are less than 2.5
meters from each other shall not exceed
0.2 ohms when tested under the
procedures specified in S9.2 of this
section.
S5.4.3 Electrical isolation.
S5.4.3.1 Electrical isolation of AC
and DC high voltage sources. The
electrical isolation of a high voltage
source, determined in accordance with
the procedure specified in S7.6 of this
section must be greater than or equal to
one of the following:
(a) 500 ohms/volt for an AC high
voltage source;
(b) 100 ohms/volt for an AC high
voltage source if it is conductively
connected to a DC high voltage source,
but only if the AC high voltage source
meets the requirements for protection
against direct contact in S5.4.1.4 of this
section and the protection from indirect
contact in S5.4.2 of this section; or
(c) 100 ohms/volt for a DC high
voltage source.
S5.4.3.2 Exclusion of high voltage
sources from electrical isolation
requirements. A high voltage source that
is conductively connected to an electric
energy storage device which is
conductively connected to the electrical
chassis and has a working voltage less
than or equal to 60 VDC, is not required
to meet the electrical isolation
requirements in S5.4.3.1 of this section
during normal vehicle operating
conditions if the voltage between the
high voltage source and the electrical
chassis is less than or equal to 30 VAC
or 60 VDC.
S5.4.3.3 Isolation resistance of high
voltage sources for charging the electric
energy storage device. For motor
vehicles with an electric energy storage
device that can be charged through a
conductive connection with the
grounded external electric power
supply, the isolation resistance between
the electrical chassis and the vehicle
charge inlet and each high voltage
source conductively connected to the
vehicle charge inlet during charging of
the electric energy storage device shall
be a minimum of one million ohms
when the charge connector is
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disconnected. The isolation resistance is
determined in accordance with the
procedure specified in S7.6 of this
section.
S5.4.4 Electrical isolation
monitoring. Each DC high voltage
sources of vehicles with a fuel cell
system shall be monitored by an
electrical isolation monitoring system
that displays a warning for loss of
isolation when tested according to S8 of
this section. The system must monitor
its own readiness and the warning
display must be visible to the driver
seated in the driver’s designated seating
position.
S5.4.5 Electric shock protection
during charging. For motor vehicles
with an electric energy storage device
that can be charged through a
conductive connection with a grounded
external electric power supply, a device
to enable conductive connection of the
electrical chassis to the earth ground
shall be provided. This device shall
enable connection to the earth ground
before exterior voltage is applied to the
vehicle and retain the connection until
after the exterior voltage is removed
from the vehicle.
S5.4.6 Mitigating driver error.
S5.4.6.1 Indicator of possible active
driving mode at start up. At least a
momentary indication shall be given to
the driver when the vehicle is in
possible active driving mode. This
requirement does not apply under
conditions where an internal
combustion engine provides directly or
indirectly the vehicle’s propulsion
power upon start up.
S5.4.6.2 Indicator of possible active
driving mode when leaving the vehicle.
When leaving the vehicle, the driver
shall be informed by an audible or
visual signal if the vehicle is still in the
possible active driving mode.
S5.4.6.3 Prevent drive-away during
charging. If the on-board electric energy
storage device can be externally
charged, vehicle movement by its own
propulsion system shall not be possible
as long as the charge connector of the
external electric power supply is
physically connected to the vehicle
charge inlet.
*
*
*
*
*
S9 Test methods for physical barrier
protection from electric shock due to
direct and indirect contact with high
voltage sources.
S9.1 Test method to evaluate
protection from direct contact with high
voltage sources.
(a) Any parts surrounding the high
voltage components are opened,
disassembled, or removed without the
use of tools.
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12673
(b) The selected access probe is
inserted into any gaps or openings of the
electrical protection barrier with a test
force of 10 N ± 1 N with the IPXXB
probe or 1 to 2 N with the IPXXD probe.
If partial or full penetration into the
physical barrier occurs, the probe shall
be placed as follows: Starting from the
straight position, both joints of the test
finger are rotated progressively through
an angle of up to 90 degrees with
respect to the axis of the adjoining
section of the test finger and are placed
in every possible position.
(c) A low voltage supply (of not less
than 40 V and not more than 50 V) in
series with a suitable lamp may be
connected between the access probe and
any high voltage live parts inside the
physical barrier to indicate whether live
parts were contacted.
(d) A mirror or fiberscope may be
used to inspect whether the access
probe touches high voltage parts inside
the physical barrier.
S9.2 Test method to evaluate
protection against indirect contact with
high voltage sources.
(a) Test method using a resistance
tester. The resistance tester is connected
to the measuring points (the electrical
chassis and any exposed conductive
part of the vehicle or any two exposed
conductive parts that are less than 2.5
meters from each other), and the
resistance is measured using a
resistance tester that can measure
current levels of at least 0.1 Amperes
with a resolution of 0.01 ohms or less.
(b) Test method using a DC power
supply, voltmeter and ammeter.
(1) Connect the DC power supply,
voltmeter and ammeter to the measuring
points (the electrical chassis and any
exposed conductive part or any two
exposed conductive parts that are less
than 2.5 meters from each other) as
shown in Figure 8 to this section.
(2) Adjust the voltage of the DC power
supply so that the current flow becomes
more than 0.2 Amperes.
(3) Measure the current I and the
voltage V shown in Figure 8 to this
section.
(4) Calculate the resistance R
according to the formula, R=V/I.
S9.3 Test method to determine
voltage between electrical protection
barrier and exposed conductive parts,
including electrical chassis, of the
vehicle.
(a) Connect the DC power supply and
voltmeter to the measuring points
(exposed conductive part of an electrical
protection barrier and the electrical
chassis or any other exposed conductive
part of the vehicle).
(b) Measure the voltage.
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Federal Register / Vol. 81, No. 47 / Thursday, March 10, 2016 / Proposed Rules
(c) After completing the voltage
measurements for all electrical
protection barriers, the voltage
differences between all exposed
conductive parts of the protective
barriers shall be calculated.
*
*
*
*
*
BILLING CODE 4910–59–P
Figure 6. Marking of High Voltage Equipment.
Access probe
in mm)
Jointed test finger
k---
Stop face
50x20)
-
IPXXB
N
demensions
Jointed test finger
(Metal)
Insulating material
~------80------~
Test wire 1.0 mm diameter, 100 mm long
(01+0.05)
IPXXD
Approx.100
~ =t::::::::::::=:::::::=:::::::::::::::=:
Handle
(Insulating material)
Stop face
(Insulating material)
from burrs
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Figure 7a. Access Probes for the Tests of Direct Contact Protection
Federal Register / Vol. 81, No. 47 / Thursday, March 10, 2016 / Proposed Rules
12675
Material: metal, except where otherwise specified
Linear dimensions in millimeters
Tolerances on dimensions without specific tolerance:
on angles, Oil 0 degrees
on linear dimensions:
up to 25 mm: 0/-0.05 mm
over 25 mm: ±0.2 mm
Both joints shall permit movement in the same plane and the same
direction through an angle of 90° with a 0° to + 10° tolerance.
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Figure 7b. Jointed Test Finger IPXXB
12676
Raymond R. Posten,
Associate Administrator for Rulemaking.
[FR Doc. 2016–05187 Filed 3–9–16; 8:45 am]
BILLING CODE 4910–59–C
DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric
Administration
50 CFR Part 660
[Docket No. 160126053–6053–01]
RIN 0648–BF74
Magnuson-Stevens Act Provisions;
Fisheries off West Coast States;
Pacific Coast Groundfish Fishery; 2016
Tribal Fishery for Pacific Whiting
National Marine Fisheries
Service (NMFS), National Oceanic and
Atmospheric Administration (NOAA),
Commerce.
ACTION: Proposed rule; request for
comments.
AGENCY:
NMFS issues this proposed
rule for the 2016 Pacific whiting fishery
under the authority of the Pacific Coast
Groundfish Fishery Management Plan
(FMP), the Magnuson Stevens Fishery
Conservation and Management Act
(Magnuson-Stevens Act), and the Pacific
Whiting Act of 2006. This proposed rule
would allocate 17.5% of the U.S. Total
Allowable Catch of Pacific whiting for
2016 to Pacific Coast Indian tribes that
have a Treaty right to harvest
groundfish.
mstockstill on DSK4VPTVN1PROD with PROPOSALS
SUMMARY:
Comments on this proposed rule
must be received no later than April 11,
2016.
ADDRESSES: You may submit comments
on this document, identified by NOAA–
NMFS–2016–0009, by any of the
following methods:
DATES:
VerDate Sep<11>2014
18:18 Mar 09, 2016
Jkt 238001
• Electronic Submission: Submit all
electronic public comments via the
Federal eRulemaking Portal. Go to
www.regulations.gov/
#!docketDetail;D=NOAA-NMFS-20160009, click the ‘‘Comment Now!’’ icon,
complete the required fields, and enter
or attach your comments.
• Mail: William W. Stelle, Jr.,
Regional Administrator, Northwest
Region, NMFS, 7600 Sand Point Way
NE., Seattle, WA 98115–0070, Attn:
Miako Ushio.
Instructions: Comments sent by any
other method, to any other address or
individual, or received after the end of
the comment period, may not be
considered by NMFS. All comments
received are part of the public record
and will generally be posted for public
viewing on www.regulations.gov
without change. All personal identifying
information (e.g., name, address, etc.),
confidential business information, or
otherwise sensitive information
submitted voluntarily by the sender will
be publicly accessible. NMFS will
accept anonymous comments (enter ‘‘N/
A’’ in the required fields if you wish to
remain anonymous).
FOR FURTHER INFORMATION CONTACT:
Miako Ushio (West Coast Region,
NMFS), phone: 206–526–4644, and
email: miako.ushio@noaa.gov.
SUPPLEMENTARY INFORMATION:
Electronic Access
This proposed rule is accessible via
the Internet at the Office of the Federal
Register Web site at https://
www.federalregister.gov. Background
information and documents are
available at the NMFS West Coast
Region Web site at https://
www.westcoast.fisheries.noaa.gov/
fisheries/management/whiting/pacific_
whiting.html and at the Pacific Fishery
Management Council’s Web site at
https://www.pcouncil.org/.
PO 00000
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Background
The regulations at 50 CFR 660.50(d)
establish the process by which the tribes
with treaty fishing rights in the area
covered by the Pacific Coast Groundfish
Fishery Management Plan (FMP) request
new allocations or regulations specific
to the tribes, in writing, during the
biennial harvest specifications and
management measures process. The
regulations state that the Secretary will
develop tribal allocations and
regulations in consultation with the
affected tribe(s) and, insofar as possible,
with tribal consensus. The procedures
NMFS employs in implementing tribal
treaty rights under the FMP were
designed to provide a framework
process by which NMFS can
accommodate tribal treaty rights by
setting aside appropriate amounts of
fish in conjunction with the Pacific
Fishery Management Council (Council)
process for determining harvest
specifications and management
measures.
Since the FMP has been in place,
NMFS has been allocating a portion of
the U.S. total allowable catch (TAC)
(called Optimum Yield (OY) or Annual
Catch Limit (ACL) prior to 2012) of
Pacific whiting to the tribal fishery,
following the process established in 50
CFR 660.50(d). The tribal allocation is
subtracted from the U.S. Pacific whiting
TAC before allocation to the non-tribal
sectors.
There are four tribes that can
participate in the tribal whiting fishery:
the Hoh Tribe, the Makah Tribe, the
Quileute Tribe, and the Quinault Indian
Nation (collectively, the ‘‘Treaty
Tribes’’). The Hoh Tribe has not
expressed an interest in participating to
date. The Quileute Tribe and Quinault
Indian Nation have expressed interest in
participating in the whiting fishery.
However, to date, only the Makah Tribe
has prosecuted a tribal fishery for
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Federal Register / Vol. 81, No. 47 / Thursday, March 10, 2016 / Proposed Rules
Agencies
[Federal Register Volume 81, Number 47 (Thursday, March 10, 2016)]
[Proposed Rules]
[Pages 12647-12676]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-05187]
-----------------------------------------------------------------------
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
49 CFR Part 571
[Docket No. NHTSA-2016-0029]
RIN 2127-AL68
Federal Motor Vehicle Safety Standards; Electric-Powered
Vehicles: Electrolyte Spillage and Electrical Shock Protection
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Notice of proposed rulemaking (NPRM).
-----------------------------------------------------------------------
SUMMARY: NHTSA is proposing to amend Federal Motor Vehicle Safety
Standard (FMVSS) No. 305, ``Electric-powered vehicles: Electrolyte
spillage and electrical shock protection,'' to adopt various electrical
safety requirements in Global Technical Regulation (GTR) No. 13,
``Hydrogen and fuel cell vehicles.'' To expand the standard's
performance requirements beyond post-crash conditions, NHTSA proposes
to adopt electrical safety requirements to protect against direct and
indirect contact of high voltage
[[Page 12648]]
sources during everyday operation of electric-powered vehicles. Also,
NHTSA proposes to adopt an optional method of meeting post-crash
electrical safety requirements consistent with that set forth in GTR
No. 13 involving use of physical barriers to prevent direct or indirect
contact (by occupants or emergency services personnel) with high
voltage sources. Today's proposal would facilitate the introduction of
new technologies including hydrogen fuel cell vehicles and 48 volt mild
hybrid technologies, and responds not only to GTR No. 13 but also to
petitions for rulemaking from Toyota Motor North America Inc. (Toyota)
and the Auto Alliance (Alliance).
DATES: Comments must be received on or before May 9, 2016.
Proposed compliance date: We believe there is widespread
conformance of vehicles to the proposed requirements. Accordingly, we
propose that the compliance date for the amendments in this rulemaking
action would be 180 days after the date of publication of the final
rule in the Federal Register. We propose to permit optional early
compliance with the amended requirements.
ADDRESSES: You may submit comments to the docket number identified in
the heading of this document by any of the following methods:
Federal eRulemaking Portal: Go to https://www.regulations.gov. Follow the online instructions for submitting
comments.
Mail: Docket Management Facility, M-30, U.S. Department of
Transportation, West Building, Ground Floor, Rm. W12-140, 1200 New
Jersey Avenue SE., Washington, DC 20590.
Hand Delivery or Courier: West Building Ground Floor, Room
W12-140, 1200 New Jersey Avenue SE., between 9 a.m. and 5 p.m. Eastern
Time, Monday through Friday, except Federal holidays.
Fax: (202) 493-2251.
Regardless of how you submit your comments, please mention the
docket number of this document.
You may also call the Docket at 202-366-9324.
Instructions: For detailed instructions on submitting comments and
additional information on the rulemaking process, see the Public
Participation heading of the Supplementary Information section of this
document. Note that all comments received will be posted without change
to https://www.regulations.gov, including any personal information
provided.
Privacy Act: Please see the Privacy Act heading under Rulemaking
Analyses and Notices.
FOR FURTHER INFORMATION CONTACT: For technical issues, you may call
William J. Sanchez, Office of Crashworthiness Standards (telephone:
202-493-0248) (fax: 202-493-2990). For legal issues, you may call
Deirdre Fujita, Office of Chief Counsel (telephone: 202-366-2992) (fax:
202-366-3820). Address: National Highway Traffic Safety Administration,
U.S. Department of Transportation, 1200 New Jersey Avenue SE., West
Building, Washington, DC 20590.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Executive Summary
II. FMVSS No. 305
III. The Global Technical Regulation
a. Overview of the Process
b. Overview of GTR No. 13
1. Electric Safety Requirements During Normal Vehicle Operation
2. Electric Safety Requirements Post-Crash Test
c. How does this proposal differ from GTR No. 13?
IV. Battelle Study and Developments
V. Toyota Petition for Rulemaking
VI. Alliance Petition for Rulemaking
VII. Overview of Proposed Rule
VIII. Proposal Addressing Safety During Normal Vehicle Operations
IX. Proposal Addressing Safety Post-Crash
X. Rulemaking Analyses and Notices
XI. Public Participation
I. Executive Summary
NHTSA is issuing this NPRM as part of the agency's ongoing effort
to harmonize vehicle safety standards under the Economic Commission for
Europe 1998 Global Agreement (``1998 Agreement''). The efforts of the
U.S. and other contracting parties to the 1998 Agreement culminated in
the establishment of GTR No. 13, ``Hydrogen and fuel cell vehicles.''
NHTSA voted in June 2013 in favor of establishing GTR No. 13. In this
NPRM, we are proposing requirements based on the electrical safety
requirements of GTR No. 13. NHTSA will initiate rulemaking in the
future on other aspects of GTR No. 13 directly pertaining to the fuel
system integrity of hydrogen fuel cell vehicles.
One purpose of FMVSS No. 305 is to reduce deaths and injuries from
electrical shock. The standard requires vehicles with high voltage
sources to meet certain performance criteria to protect vehicle
occupants, rescue workers and others who may come in contact with the
vehicle after a crash. Among other things, FMVSS No. 305 requires that
after a crash, high voltage sources in a vehicle are either (a)
electrically isolated from the vehicle's chassis or (b) their voltage
is below specified levels considered safe from electric shock hazards.
Since the physiological impacts of direct current (DC) are less than
those of alternating current (AC), the standard specifies lower minimum
electrical isolation requirements for certain DC components (100 ohms/
volt) than for AC components (500 ohms/volt).
GTR No. 13 also has requirements intended to reduce deaths and
injuries from electrical shock. Unlike FMVSS No. 305, GTR No. 13 has
requirements that reduce the risk of harmful electric shock during
normal vehicle operation. This NPRM proposes to adopt those
requirements to expand FMVSS No. 305's performance requirements beyond
post-crash conditions. In addition, while the various post-crash
compliance options in GTR No. 13 are similar to those in FMVSS No. 305,
GTR No. 13 includes a compliance option for electrical vehicle safety
that prevents direct and indirect contact of high voltage sources by
way of ``physical barriers.'' NHTSA is now proposing to amend FMVSS No.
305 to permit a physical barrier compliance option.\1\
---------------------------------------------------------------------------
\1\ Our proposed physical barrier option varies slightly from
GTR No. 13. GTR No. 13 provides contracting parties discretion in
whether to propose the option in their domestic regulatory process.
In our proposal today, we are not proposing to adopt GTR No. 13's
physical barrier option. However, as further discussed, below, we
are adopting a modified physical barrier option that we believe will
also afford the compliance flexibility that GTR No. 13 seeks to
provide, while at the same time providing a level of safety closer
to the other post-crash compliance options. A small number of minor
additional provisions are proposed as well. These additional
provisions would not significantly alter our incorporation of GTR
No. 13 and are consistent with the goal of incorporating a standard
that is harmonized with other international standards.
---------------------------------------------------------------------------
NHTSA tentatively believes that the by-product of adopting a
physical barrier option would be more than harmonizing vehicle
standards. Enhanced design innovation, reduced CO2 emissions
and increased fuel economy would likely result. This proposal would
facilitate the introduction of 48 volt mild hybrid technologies and
hydrogen fuel cell vehicles, and responds not only to GTR No. 13 but
also to petitions for rulemaking from Toyota and the Alliance.
Petitioner Toyota believes that an additional compliance option
that includes elements of the physical barrier option in GTR No. 13 is
needed to allow hydrogen fuel cell vehicles (HFCVs) to be offered for
sale in the U.S.\2\ HFCVs and other electric powered
[[Page 12649]]
vehicles operate with their DC high voltage sources (e.g. high voltage
battery) connected to the AC high voltage sources (e.g. electric
motor). In a moderate to severe crash (e.g., crash speeds at which an
air bag would deploy), electric powered vehicles are generally designed
with an automatic disconnect mechanism that activates and breaks the
conductive link between the electrical energy storage system and the
rest of the power train. Under these crash conditions in which an
automatic disconnect mechanism activates, Toyota states that its HFCVs
would be able to meet the electrical safety requirements of FMVSS No.
305. However, in low speed crashes where the automatic disconnect
mechanism is not designed to activate so that the vehicle can be driven
away after a minor crash (fender-bender), Toyota states that its HFCVs
would not be able to meet the electrical safety requirements in FMVSS
No. 305. The petitioner believes that the additional compliance option
requested in its petition would solve this problem and would not cause
any reduction in the level of electrical safety now required by FMVSS
No. 305.
---------------------------------------------------------------------------
\2\ Subsequent to its submission of the petition for rulemaking,
Toyota submitted and was granted a temporary exemption from FMVSS
No. 305 for an HFCV (see grant of petition, January 2, 2015 (80 FR
101)). Toyota incorporates electrical protection barriers
(conductively connected to the electric chassis with low resistance)
and maintains at least a 100 ohms/volt electrical isolation into
their design. NHTSA granted the petition for exemption on the basis
that the exemption would make the development or field evaluation of
a low emission (zero emission) vehicle easier and would not
unreasonably reduce the safety of the vehicle.
---------------------------------------------------------------------------
Petitioner Alliance requests a physical barrier compliance option
to facilitate the production of 48 volt mild hybrid technologies as
well as hydrogen fuel cell vehicles. The petitioner asks NHTSA to amend
FMVSS No. 305 to adopt a physical barrier option incorporated in the
Society of Automotive Engineers (SAE) J1766 Jan 2014,\3\ section 5.3.4,
for 48 volt mild hybrid systems. The Alliance believes that the
provisions for physical barriers in section 5.3.4 incorporate the
requirements of GTR No. 13 and provide for physical barriers that
ensure equal levels of safety as that afforded by the current FMVSS No.
305 electrical safety requirements.
---------------------------------------------------------------------------
\3\ SAE J1766, ``Recommended practice for electric, fuel cell,
and hybrid electric vehicle crash integrity testing,'' January 2014,
SAE International, https://www.sae.org.
---------------------------------------------------------------------------
The petitioner states that while vehicles with 48 volt mild hybrid
systems use mostly low-voltage components that do not present any
danger of harmful electric shock, AC voltage sources contained within
the system can exceed the 30 volt threshold in FMVSS No. 305 for
consideration as a high voltage source. Since these systems are
grounded to the vehicle chassis, they cannot meet FMVSS No. 305's
existing electrical isolation option. The petitioner states that while
it is feasible to design a 48 volt mild hybrid system that is isolated
from the chassis and meets FMVSS No. 305's electrical isolation
requirements, such designs involve more complexity, higher consumer
costs, and higher mass resulting in reduced fuel economy and increased
emissions. The petitioner believes that these penalties are
inappropriate when there would be no incremental safety benefit gained
beyond that associated with SAE J1766's physical barrier option.
NHTSA has undertaken this rulemaking after carefully and
extensively examining the safety issues. The agency previously decided
against consideration of a physical barrier option earlier in the
history of FMVSS No. 305, when our knowledge about the option was
limited.\4\ Commenters to an NPRM to upgrade electrical shock
protection requirements had asked NHTSA to adopt the option in the
final rule, for reasons similar to those provided by petitioners Toyota
and the Alliance. NHTSA declined, citing concerns about the lack of
notice for the provision, the absence of developed test procedures to
ensure protection from indirect contact, and uncertainty as to whether
the option would sufficiently account for indirect contact failure
modes. NHTSA then decided to undertake a research program (later known
as the Battelle study, discussed below in this preamble) to better
understand the issues related to a physical barrier option for
electrical safety.
---------------------------------------------------------------------------
\4\ See final rule, 75 FR 33515, June 14, 2010; response to
petitions for reconsideration, 76 FR 45436, July 29, 2011.
---------------------------------------------------------------------------
Since that decision in 2010, a number of developments led to
today's proposal. GTR No. 13 was established, a product of shared data
and knowledge from governing bodies and international experts around
the world. The Battelle study was completed and the physical barrier
countermeasure design was made more robust in response to its findings,
with SAE revising J1766 in January 2014 to set forth more protective
safety practices than it had before to address remote albeit lingering
concerns. Importantly, there have now been years of worldwide
recognition of the physical barrier option as an acceptable means of
providing electrical safety in electric powered vehicles, with years of
experience in design labs and in the field showing no evidence of
associated safety problems. HFCVs, 48 volt mild hybrid technologies,
and other vehicle designs have become a reality, and with them abundant
potential for the development of electrical technologies that a
physical barrier option in FMVSS No. 305 can facilitate, expedite and
safeguard.
We estimate that adopting this NPRM would come at essentially no
cost to consumers in the U.S. This proposal closely mirrors the
electrical safety provisions of GTR No. 13, which have been implemented
by manufacturers in this country.
NHTSA believes that this NPRM would improve the level of safety
afforded to the public. Adopting the provisions from GTR No. 13 that
reduce the risk of harmful electric shock during normal vehicle
operation would improve FMVSS No. 305 by expanding its performance
requirements beyond post-crash conditions. The proposed requirements
would provide post-crash compliance options for new power train
configurations that ensure that those configurations provide a
comparable level of post-crash safety compared to existing electric
vehicles.
Summary of Proposal
The proposed amendments are summarized as follows. In furtherance
of implementing GTR No. 13 and in response to the petitions for
rulemaking--
a. This NPRM proposes to add electrical safety requirements for
vehicle performance during everyday (``normal'') vehicle operations (as
opposed to during and after a crash), to mitigate electric shock due to
loss in electrical isolation and direct or indirect contact of high
voltage sources. The electrical safety requirements during normal
vehicle operations would include requirements for:
1. Direct contact protection from high voltage sources
i. IPXXD protection level \5\ for high voltage sources inside
passenger and luggage compartments. IPXXB protection level for high
voltage sources not in passenger and luggage compartments.
---------------------------------------------------------------------------
\5\ IPXXB and IPXXD ``protection levels'' refer to the ability
of the physical barriers to prevent entrance of a probe into the
enclosure, to ensure no direct contact with high voltage sources.
``IPXXB'' is a probe representing a small human finger. ``IPXXD'' is
a slender wire probe. Protection degrees IPXXD and IPXXB are
International Electrotechnical Commission specifications for
protection from direct contact of high voltage sources.
---------------------------------------------------------------------------
ii. IPXXB protection level for service disconnect that can be
opened or removed without tools.
iii. Markings on barriers of high voltage sources that can be
physically accessed, opened, or removed without the use of tools.
[[Page 12650]]
iv. Orange color outer covering for cables of high voltage
sources that are located outside electrical protection barriers.\6\
---------------------------------------------------------------------------
\6\ An electrical protection barrier is defined in GTR No. 13 as
the part providing protection from direct contact with high voltage
sources from any direction of access. These may be physical barriers
that enclose high voltage sources.
---------------------------------------------------------------------------
2. Indirect contact protection from high voltage sources
Exposed conductive parts of electrical protection barriers would
have to be conductively connected to the chassis with a resistance
less than 0.1 ohms, and the resistance between two simultaneously
reachable exposed conductive parts of electrical protection barriers
that are within 2.5 meters of each other would have to be less than
0.2 ohms.
3. Electrical isolation of high voltage sources
i. 500 ohms/volt or higher electrical isolation for AC high
voltage sources and 100 ohms/volt or higher for DC high voltage
sources.
ii. For conditions where AC and DC bus are connected, AC high
voltage sources would be permitted to have electrical isolation of
100 ohms/volt or higher, provided they also have the direct and
indirect contact protection described in 1 and 2, above.
iii. There would be an exclusion of 48 volt hybrid vehicles from
electrical isolation requirements during normal vehicle operation.
4. Electrical isolation monitoring system for DC high voltage
sources on fuel cell vehicles.
5. Electrical safety during charging involving connecting the
vehicle to an external electric power supply:
i. Minimum electrical isolation resistance of one million ohm of
the coupling system for charging the electrical energy storage
system; and
ii. Conductive connection of the electric chassis to earth
ground before and during exterior voltage is applied.
6. Mitigating driver error by--
i. Requiring an indication to the driver when the vehicle is in
active driving mode upon vehicle start up and when the driver is
leaving the vehicle; and,
ii. Preventing vehicle movement by its own propulsion system
when the vehicle charging system is connected to the external
electric power supply.
b. This NPRM also proposes to amend FMVSS No. 305's post-crash
electrical safety requirements. The proposed post-crash electrical
safety requirements include:
1. Adding an additional optional method of meeting post-crash
electrical safety requirements through physical barrier protection
from high voltage sources. The proposed specifications of this
optional method of electric safety include requirements ensuring
that:
i. High voltage sources would be enclosed in barriers that
prevent direct human contact with high voltage sources (IPXXB
protection level),
ii. Exposed conductive parts of electrical protection barriers
would be conductively connected to the chassis with a resistance
less than 0.1 ohms, and the resistance between any two
simultaneously reachable exposed conductive parts of electrical
protection barriers that are less than 2.5 meters from each other
would be less than 0.2 ohms, and
iii. Voltage between a barrier and other exposed conductive
parts of the vehicle would be at a low voltage level that would not
cause electric shock (less than 60 VDC \7\ or 30 VAC).
---------------------------------------------------------------------------
\7\ VDC is the voltage for direct current sources and VAC is
voltage for alternating current sources.
---------------------------------------------------------------------------
2. Permitting an AC high voltage source that is conductively
connected to a DC high voltage source to meet lower minimum
electrical isolation requirement of 100 ohms/volt, provided the AC
high voltage source also has physical barrier protection specified
in 1, above.
II. FMVSS No. 305
FMVSS No. 305 currently establishes requirements to reduce deaths
and injuries during and after a crash that occurs because of
electrolyte spillage from electric energy storage devices, intrusion of
electric energy storage/conversion device into the occupant
compartment, and electrical shock. Among other things, FMVSS No. 305
requires that during and after the crash tests specified in the
standard, high voltage sources in the vehicle must be either (a)
electrically isolated from the vehicle's chassis,\8\ or (b) their
voltage is below specified levels considered safe from electric shock
hazards.\9\
---------------------------------------------------------------------------
\8\ Under this electrical isolation option, since the
physiological impacts of DC are less than those of AC, the standard
permits DC high voltage sources with an electrical isolation
monitoring system to have lower minimum electrical isolation (100
ohms/volt) than the 500 ohms/volt required for AC high voltage
sources. This level of electrical isolation limits the current that
could pass through a human body (that is in contact with the
vehicle) to no more than 10 milliamperes (mA) DC or 2 mA AC. These
levels are considered to be safe levels of current and would not
cause any tissue damage, or fibrillation.
\9\ Under this low voltage option, electrical components are
considered to be low voltage and safe from electric shock hazard if
their voltage is less than or equal to 60 VDC or 30 VAC.
---------------------------------------------------------------------------
Many of these electrical shock protection requirements were
established by a June 14, 2010 final rule (75 FR 33515) that revised
the standard to align it more closely with the April 2005 version of
SAE J1766. Commenters to the NPRM preceding the June 14, 2010 final
rule (viz., the Alliance and Global Automakers) requested another
electrical safety compliance option, called the ``physical barrier
option,'' for providing greater flexibility to allow introduction of
advanced power train technologies. In the physical barrier option, high
voltage sources are enclosed in physical barriers (electrical
protection barriers) that do not permit entrance of a finger probe into
the enclosure after the crash test to ensure no direct contact with
high voltage sources. This option also requires the physical barriers
to be conductively connected to the electric chassis to ensure no
electric shock due to indirect contact in the event of loss in
isolation of a high voltage source.
In the June 14, 2010 final rule, NHTSA declined to adopt the
physical barrier option, citing concerns about the sufficiency of
notice provided for the provision, the absence of developed test
procedures to ensure protection from indirect contact, and uncertainty
as to whether the option would sufficiently account for indirect
contact failure modes. NHTSA stated that it would undertake a research
program (the Battelle study) to better understand the issues related to
a physical barrier option for electrical safety.
III. The Global Technical Regulation
a. Overview of the Process
The United States is a contracting party to the ``1998 Agreement''
(the Agreement concerning the Establishing of Global Technical
Regulations for Wheeled Vehicles, Equipment and Parts which can be
fitted and/or be used on Wheeled Vehicles). This agreement entered into
force in 2000 and is administered by the UN Economic Commission for
Europe's (UN ECE's) World Forum for the Harmonization of Vehicle
Regulations (WP.29). The purpose of this agreement is to establish
Global Technical Regulations (GTRs).
GTR No. 13, ``Hydrogen fuel cell vehicles,'' addresses hydrogen
fuel cell vehicle technology. NHTSA closely collaborated with experts
from contracting parties to the 1998 Agreement, particularly Germany
and Japan, to develop a GTR for hydrogen fueled vehicles that would
establish levels of safety that are equivalent to or exceeds those for
conventional gasoline fueled vehicles. The collaborative effort in this
process led to the establishment of GTR No. 13 in June 2013.
The U.S. voted on June 27, 2013 in favor of establishing GTR No.
13. In voting yes to establishing the GTR, NHTSA is obligated to
``submit the technical Regulation to the process'' used in the U.S. to
adopt the requirement into our law or regulation. By issuance of this
NPRM, NHTSA is initiating the process for considering adoption of GTR
No. 13.
[[Page 12651]]
Under the terms of the 1998 Agreement, NHTSA is not obligated to
adopt the GTR after initiating this process. In deciding whether to
adopt a GTR as an FMVSS, we follow the requirements for NHTSA
rulemaking, including the Administrative Procedure Act, the National
Highway and Motor Vehicle Safety Act (Vehicle Safety Act), Presidential
Executive Orders, and DOT and NHTSA policies, procedures and
regulations. Among other things, FMVSSs issued under the Vehicle Safety
Act ``shall be practicable, meet the need for motor vehicle safety, and
be stated in objective terms.'' 49 U.S.C. 30111.
This NPRM does not propose the entirety of GTR No. 13 at this time.
This document only addresses the electrical safety requirements in GTR
No. 13 (i.e., the electrical isolation requirements, physical barrier
requirements, etc.). GTR No. 13 also addresses hydrogen fuel system and
fuel container integrity requirements and the agency's plan is to issue
a separate proposal to seek comment on incorporating those portions of
GTR No. 13 into the relevant FMVSSs.
b. Overview of GTR No. 13
Hydrogen fueled fuel cell vehicles have an electric drive-train
powered by a fuel cell that generates electric power electrochemically
using hydrogen. The hydrogen is electrochemically combined with oxygen
(from air) within the fuel cell system to produce high-voltage electric
power. The electric power is supplied to the electric drive motors and/
or used to charge batteries and capacitors. HFCVs may also be equipped
with batteries to supplement the output of fuel cells and may also
recapture energy during stopping through regenerative braking, which
recharges batteries and thereby improves efficiency.
The fuel cell provides DC power while the drive motors typically
operate on AC. Therefore, the power train has: (a) Inverters to convert
DC power to AC to run the motors and (b) converters to convert AC power
generated in the drive motor during regenerative braking to DC to store
energy in the batteries. In many respects, the electric power train of
an HFCV is similar to that of electric and hybrid electric vehicles.
GTR No. 13, in part, specifies electrical safety requirements during
normal vehicle operation and after a crash test, to protect against
electric shock in the event of a failure in the high voltage propulsion
system.
In general, the portions of GTR No. 13 that are relevant to this
rulemaking are the electric safety requirements intended to protect
against the potential for electric shock during (a) normal vehicle
operation, and (b) after a crash. We discuss these requirements in GTR
No. 13 in the sections below.
1. Electric Safety Requirements During Normal Vehicle Operation
These performance requirements in GTR No. 13 are requirements
intended for protecting vehicle occupants (and others that may interact
with the vehicle) against electric shock during normal vehicle
operation.\10\ For the purposes of the GTR, normal vehicle operations
include those during driving and charging.
---------------------------------------------------------------------------
\10\ In other words, the focus of this ``in-use'' testing
(unlike ``post-crash'' testing, discussed later) deals with
performance criteria that would be assessed without first exposing
the vehicle to a crash test. This testing is aimed at evaluating
what the performance of the vehicle would be under normal operating
conditions.
---------------------------------------------------------------------------
The GTR requirements apply to all high voltage sources (electric
components contained or connected to the electric power train that have
a working voltage greater than 30 VAC or 60 VDC). It requires these
high voltage sources to have all four of the following measures to
protect against electric shock during normal vehicle operations: (1)
Prevent direct contact of high voltage sources (those operating with
voltage greater than 30 VAC or 60 VDC); (2) prevent indirect contact of
high voltage sources; (3) electrically isolate the high voltage sources
from the electric chassis (500 ohms/volt or higher for AC and 100 ohms/
volt or higher for DC sources); and (4) electrical isolation monitoring
system for HFCVs that warns the driver in the event of loss in
isolation.
The GTR also has the following measures to reduce driver errors
that may result in potential unsafe conditions: (1) Indication to the
driver when the vehicle is in possible active driving mode at startup
and when the driver is leaving the vehicle, and (2) prevent vehicle
movement by its own propulsion system when the vehicle charging system
is connected to the external electric power supply.
Protection Against Direct Contact With High Voltage Sources
For protection against direct contact with high voltage sources,
the GTR has different requirements based on the location of the high
voltage source (i.e., if it is in the passenger or luggage compartment
of the vehicle or not).
The GTR requires high voltage sources inside the passenger
compartment or luggage compartment to be enclosed in protection systems
such as solid insulators, electrical protection barriers, and
enclosures that cannot be opened, disassembled, or removed without the
use of tools and that provide protection degree IPXXD. Protection
degree IPXXD is an International Electrotechnical Commission (IEC)
specification for protection from direct contact of high voltage
sources. IPXXD protection is verified when a standard probe (rigid test
wire shown in Figure 1), 100 millimeters (mm) long and 1 millimeter
(mm) in diameter, does not contact high voltage components when probed
to enter an electrical protection barrier or enclosure.\11\
---------------------------------------------------------------------------
\11\ IEC60529 Second edition 1989-11 + Am. 1 1999-11, EN60529,
``Degrees of protection provided by enclosures.''
[GRAPHIC] [TIFF OMITTED] TP10MR16.000
For high voltage sources not in passenger or luggage
compartments,\12\ the GTR requires that they be enclosed in protection
systems such as solid insulators, electrical protection barriers, and
enclosures that cannot be opened, disassembled, or removed without the
use of tools, and that provide a protection degree of IPXXB (as opposed
to IPXXD, referenced above). Protection degree IPXXB is an IEC
specification for protection from direct contact of high
[[Page 12652]]
voltage sources. IPXXB protection is verified when a standard probe
(resembling a small human finger), 80 mm long and 12 mm in diameter,
does not contact high voltage components when probed to enter an
electrical protection barrier or enclosure.\13\ (See Figure 2 below.)
---------------------------------------------------------------------------
\12\ GTR No. 13 specifies direct contact protection requirements
for high voltage connectors (including vehicle inlet) separately.
\13\ IEC60529 Second edition 1989-11 + Am. 1 1999-11, EN60529,
``Degrees of protection provided by enclosures.'' This test probe
designed to simulate a small human finger (12 mm) conforms to ISO
20653 ``Road vehicles--Degrees of protection (IP-Code)--Protection
of electrical equipment against foreign objects, water, and access
(IPXXB).''
[GRAPHIC] [TIFF OMITTED] TP10MR16.001
In addition to barriers preventing direct physical contact with
high voltage sources, GTR No. 13 also requires protections for the
``service disconnect.'' \14\ These provisions protect emergency
personnel, persons performing service/maintenance on the vehicle, and
vehicle occupants. The GTR requires that a service disconnect (which
can be opened, disassembled or removed without tools) be enclosed by
protection systems with protection degree IPXXB when the service
disconnect is opened, disassembled, or removed.
---------------------------------------------------------------------------
\14\ A service disconnect is a device for deactivation of an
electrical circuit when conducting checks and services of the
electric battery, fuel cell stack, or other high voltage sources.
---------------------------------------------------------------------------
Further, the GTR requires that high voltage sources be labeled
using the symbol shown in Figure 3, below. The interior of the symbol
is yellow and the border and arrow symbol are black. This requirement
aims to provide a standardized warning regarding the presence of high
voltage sources within an enclosure that can be physically accessed,
opened or removed without the use of tools. The GTR specifies that the
labels need to be on or near electric energy storage/conversion devices
and on electrical protection barriers or enclosures of high voltage
sources that can be physically accessed, opened, or removed without the
use of tools and that are not located underneath the vehicle floor. For
connecters of high voltage sources, the GTR makes this requirement
optional.
[GRAPHIC] [TIFF OMITTED] TP10MR16.002
In the same vein, the GTR requires cables to have a standardized
warning that high voltage cables are present. The GTR requires that
cables for high voltage sources, which are not located within
enclosures, must have an orange outer covering for identification.
Protection Against Indirect Contact With High Voltage Sources
Indirect contact of high voltage sources \15\ may occur when a high
voltage source experiences a loss in electrical isolation and the
physical barrier or enclosure gets electrically energized. This type of
contact could also lead to electrical shock. To address this concern,
the GTR requires, first, that exposed conductive parts (parts which may
become electrically energized under electrical isolation failure and
which can be contacted by a human, such as electrical protection
barriers and enclosures) be conductively connected to the electrical
chassis such that the resistance between all exposed conductive parts
and the electrical chassis is less than 0.1 ohms when there is current
flow of at least 0.2 amperes (A).\16\ This would ensure that in the
event of loss in electrical isolation, no dangerous voltage potentials
are produced between exposed conductive parts and the electrical
chassis, and therefore very low levels of current would flow through a
human body contacting different parts of the vehicle.\17\
---------------------------------------------------------------------------
\15\ Contact of a conductive part which is energized due to loss
in electrical isolation of a high voltage source is an indirect
contact of the high voltage source.
\16\ GTR No. 13 considers this requirement to be met if visual
inspection indicates that a conductive connection has been
established by welding. NHTSA has concerns about this provision and
is requesting comments on it.
\17\ Since current flows through the path of least resistance,
most of the current flow would be through the chassis rather than
through the human body which has a significantly higher resistance.
---------------------------------------------------------------------------
Second, GTR No. 13 requires that vehicles whose rechargeable energy
storage systems are charged by conductively connecting to an external
grounded electric power supply have a device that conductively connects
the electrical chassis to the earth ground during charging. This
ensures that if there is a loss in electrical isolation of a high
voltage source during charging and the vehicle chassis is contacted by
a human, the magnitude of current
[[Page 12653]]
flowing through the person is very low and in the safe zone.\18\
---------------------------------------------------------------------------
\18\ Current will flow through the path of least resistance and
therefore most of the current resulting from a loss of electrical
isolation would flow through the ground connection rather than
through the human body.
---------------------------------------------------------------------------
Protection by Electrical Isolation
GTR No. 13 affords different electrical isolation requirements for
AC and DC high voltage sources based on whether they are conductively
isolated from each other or conductively linked together.
For AC and DC high voltage sources that are conductively isolated
from each other, GTR No. 13 requires isolation resistance between the
high voltage source and the electrical chassis to be a minimum value of
100 ohms/volt of the working voltage for DC high voltage sources, and a
minimum value of 500 ohms/volt of the working voltage for AC high
voltage sources. This requirement is similar to the post-crash
electrical isolation requirement currently in FMVSS No. 305. It ensures
that in the event high voltage sources are contacted, the current
flowing through the body is less than or equal to 10 mA DC or 2 mA AC--
which is considered to be safe.\19\
---------------------------------------------------------------------------
\19\ See IEC TS 60479-1 and TS 60479-2 Effects of Current on
Human Beings and Livestock--Part 1: General Aspects, 2005-07,
Reference Nos. CEI/IEC/TS 60479-1:2005.
---------------------------------------------------------------------------
For AC and DC high voltage sources that are conductively connected,
GTR No. 13 affords two options. The first option is the vehicle may
maintain an isolation resistance between the high voltage sources and
the electrical chassis at no less than 500 ohms/volt of the working
voltage. The second option is it may provide an isolation resistance
between the high voltage sources and the electrical chassis of no less
than 100 ohms/volt of the working voltage and provide physical barrier
protection for the AC high voltage sources to prevent both direct and
indirect contact, as discussed above. (Note that a ``physical barrier''
approach would be a new concept in FMVSS No. 305.)
In addition, GTR No. 13 specifies electrical isolation requirements
for charging electric vehicles whose rechargeable energy storage system
are charged by conductively connecting to an external power supply. GTR
No. 13 requires that the isolation resistance between the electrical
chassis and high voltage sources conductively connected to the vehicle
inlet which connects to the external power supply to be at least 1
million (M) ohms when the charge coupler is disconnected. This
requirement is in accordance with IEC61851-1-2010 \20\ and
International Standards Organization (ISO) 6469-2 \21\ which prescribe
electrical isolation for electric vehicles that connect to the power
grid for charging. A typical minimum allowable isolation requirement
for a grounded product connected to the power grid is 1000 ohms/volt,
which computes to 1M ohms.
---------------------------------------------------------------------------
\20\ IEC 61851-1:2010 Electric vehicle conductive charging
system--Part 1: General requirements, available at https://webstore.iec.ch/publication/6029.
\21\ ISO 6469-2:2009 Electrically propelled road vehicles--
Safety specifications--Part 2: Vehicle operational safety means and
protection against failures. Available at https://www.iso.org/iso/catalogue_detail?csnumber=45478.
---------------------------------------------------------------------------
Protection by Electrical Isolation Monitoring System
GTR No. 13 also contains provisions for monitoring the electrical
isolation under certain conditions. In fuel cell vehicles, GTR No. 13
requires DC high voltage sources (other than the coupling system for
charging) to have an on-board electrical isolation monitoring system,
together with a warning to the driver if the isolation resistance drops
below the minimum required value of 100 ohms/volt. FMVSS No. 305
specifies a similar requirement except that FMVSS No. 305 applies this
provision to vehicles that are certified to the 100 ohms/volt
electrical isolation option \22\ (rather than to fuel cell vehicles
specifically).
---------------------------------------------------------------------------
\22\ As discussed above, AC high voltage sources are required
under FMVSS No. 305 to have at least 500 ohms/volt of electrical
isolation. DC high voltage sources may have an electrical isolation
of 100 ohms/volt or greater provided that they meet conditions such
as having an electrical isolation monitoring system meeting the
requirements of the standard.
---------------------------------------------------------------------------
Protection by Mitigating Driver Error
GTR No. 13 also has provisions for mitigating the likelihood of
driver error in operating electric vehicles. First, GTR No. 13 requires
that at least a momentary indication be given to the driver when the
vehicle is in possible active driving mode.\23\ Second, when leaving
the vehicle, the driver shall be informed by an optical or audible
signal if the vehicle is still in possible active driving mode. The
third requirement is that for vehicles where the on-board rechargeable
energy storage/conversion device can be charged externally, vehicle
movement by its own propulsion system shall not be possible when the
external electric power supply is physically connected to the vehicle
inlet.
---------------------------------------------------------------------------
\23\ I.e., the vehicle mode when application of pressure to the
accelerator pedal or release of the brake system causes the electric
power train to move the vehicle.
---------------------------------------------------------------------------
The first requirement does not apply to vehicles with an internal
combustion engine that directly or indirectly provides the vehicle's
propulsion on startup. Since electric powered vehicles operate quietly,
an indication of the vehicle in possible active driving mode would
assist the driver in reducing operational errors that could have safety
implications. The third requirement prevents the charger from getting
ripped out of the vehicle inlet during charging that could cause
electrical arcing.
2. Electric Safety Requirements Post-Crash Test
The post-crash \24\ electrical safety requirements in GTR No. 13
apply to all high voltage sources (electric components contained or
connected to the electric power train that have a working voltage
greater than 30 VAC or 60 VDC). GTR No. 13 does not specify the type of
crash test and how it is conducted. This is left to each contracting
party to develop appropriate crash tests. After the crash test, to
provide adequate protection against electric shock, GTR No. 13 affords
three potential options that a vehicle manufacturer may use to protect
against potential human contact with high voltage sources. GTR No. 13
specifically gives contracting parties the choice not to provide the
physical barrier option in their final domestic regulation.
---------------------------------------------------------------------------
\24\ In terms of ``post-crash'' we are referring to assessing a
vehicle's electrical safety provisions (electrical isolation,
physical barrier, etc.) after the vehicle is exposed to specified
crash forces in a crash test. This is different from the
aforementioned ``in-use'' (or ``normal operating conditions'')
requirements where the vehicle is evaluated for conformance with a
performance requirement without first being exposed to crash
testing.
---------------------------------------------------------------------------
Reduce the Voltage Levels of the High Voltage Sources Such That They
Are No Longer High Voltage Sources
Reducing the high voltage sources' voltage to a level below what is
considered a ``high voltage source'' means there is no further need to
protect against electrical shock from those sources. Thus, in this
option, GTR No. 13 requires that the voltages of each high voltage
source be reduced to less than or equal to 30 VAC or 60 VDC within 60
seconds after the impact. A version of this option for electrical
safety is currently in FMVSS No. 305.
Use a Physical Barrier and Other Techniques To Prevent Direct/Indirect
Contact \25\ With High Voltage Sources
---------------------------------------------------------------------------
\25\ To reiterate, this option is one that contracting parties
may choose not to propose. In other words, a contracting party that
voted in favor of this GTR may submit this GTR to their domestic
rulemaking process affording only two options for protecting against
post-crash electrical shock (i.e., reducing the high voltage
sources' voltage so that they are no longer considered high voltage;
and maintaining the required levels of electrical isolation of the
high voltage sources).
---------------------------------------------------------------------------
The physical barrier option protects against electrical shock by
preventing
[[Page 12654]]
any human contact (direct or indirect) with the high voltage sources.
The physical barrier option for post-crash is similar to the physical
barrier option that GTR No. 13 affords for its normal vehicle operation
requirement. The requirements state that (post-crash) the vehicle needs
to prevent both direct and indirect human contact with high voltage
sources through the use of: (1) Physical barriers (i.e., prevent a
finger probe test device from contacting any high voltage source); and
(2) low resistance conductive connection of the physical barriers to
the electrical chassis (i.e., the resistance between all exposed
conductive parts and the electrical chassis has to be less than 0.1
ohms when there is a current flow of at least 0.2 A \26\). The only
major difference is that GTR No. 13 uses protection degree IPXXB (i.e.,
the IPXXB finger probe) for its post-crash requirements (rather than
IPXXD).\27\ As noted earlier, FMVSS No. 305 currently contains no
similar provision for electric shock protection through physical
barriers.
---------------------------------------------------------------------------
\26\ GTR No. 13 considers this requirement to be met if visual
inspection indicates that conductive connection has been established
by welding. The minimum resistance requirement is only evaluated in
case of doubt.
\27\ Here the post-crash requirements in the GTR use IPXXB
because it is assumed unlikely that, post-crash, someone would use a
wire to probe the enclosure.
---------------------------------------------------------------------------
Electrically Isolate the High Voltage Sources
This option protects against electric shock by ensuring that a
sufficient level of electrical isolation resistance is provided for the
high voltage source. GTR No. 13 provides two different sets of
requirements (based on whether the vehicle's AC and DC high voltage
sources are conductively connected) for vehicles electing to use this
option to protect against electric shock.
If the AC and DC high voltage sources are conductively isolated
from each other, then the minimum electrical isolation of a high
voltage source to the chassis is 500 ohms/volt for AC components and
100 ohms/volt for DC components of the working voltage.
If AC and DC high voltage sources are conductively connected, GTR
No. 13 requires that electrical isolation of AC and DC high voltage
sources be no less than 500 ohms/volt of the working voltage, or the
electric isolation of those sources be no less than 100 ohms/volt
provided that the AC high voltage sources (in addition to the minimum
100 ohms/volt electrical isolation) meet the reduced voltage level
requirements discussed above (first option), or meet the physical
protection requirements discussed above in the second option.
We note that while currently FMVSS No. 305 contains different
requirements for AC high voltage sources and DC high voltage sources,
it does not distinguish requirements based on whether the AC and DC
high voltage sources are conductively linked. Thus, while the
requirements in GTR No. 13 for AC and DC sources that are not
conductively connected are the same as those currently in FMVSS No.
305, the alternative requirements for conductively connected AC and DC
sources are not.
c. How does this proposal differ from GTR No. 13?
This NPRM proposes to add electrical safety requirements during
normal vehicle operation in GTR No. 13 into FMVSS No. 305. The proposal
also adds a modified version of physical barrier protection that is
specified in GTR No. 13 as a compliance option for meeting post-crash
electrical safety requirements. However, this NPRM does not propose to
adopt all the specifications in GTR No. 13. The differences in
electrical safety requirements and associated test procedures in the
proposal and that in GTR No. 13, along with an explanation for these
differences, are provided below. Comments are requested on NHTSA's
views.
Physical Barrier Protection During Normal Vehicle Operation
This NPRM proposes to adopt GTR No. 13's physical barrier
protection requirement during normal vehicle operation for direct
contact. However, for indirect contact protection, we propose to use
the proposed post-crash indirect contact protection requirements
described above (which include two additional requirements described
above in addition to that specified in GTR No. 13).
Verification of Physical Barrier Protection During Normal Vehicle
Operations
GTR No. 13 considers indirect contact protection requirements
during normal vehicle operations to be met if a galvanic connection
\28\ has been established by welding between exposed conductive parts
and the electrical chassis.
---------------------------------------------------------------------------
\28\ A galvanic connection is a conductive connection.
---------------------------------------------------------------------------
For conditions where the DC and AC high voltage sources are
connected during normal vehicle operations, GTR No. 13 permits the AC
high voltage sources to have a minimum electrical isolation of 100
ohms/volt provided the AC high voltage sources have either: (a) Double
or more layers of solid insulators or electrical protection barriers
that meet the requirements for indirect contact protection; or (b)
Mechanically robust protections that have sufficient durability over
vehicle service life such as motor housings, electronic converter cases
or connectors.
These methods of verification consist of mere visual inspection and
do not provide sufficient objectivity for use in an FMVSS. Therefore,
the agency's proposal does not consider indirect contact protection
requirements to be met if galvanic connection has been established
between exposed conductive parts and the electric chassis. The agency
is also not proposing visual inspection methods to permit AC high
voltage sources that are connected to a DC high voltage source to have
minimum electrical isolation of 100 ohms/volt during normal vehicle
operation.
High Voltage Markings
GTR No. 13 requires marking (yellow high voltage symbol) for
enclosures and barriers of high voltage sources (electrical protection
barriers) that can be physically accessed, opened, or removed without
the use of tools. These markings are not required for electrical
protection barriers located underneath the vehicle floor.
NHTSA tentatively concludes that the exclusion is without merit.
GTR No. 13 does not provide a justification for exempting electrical
protection barriers located underneath the vehicle floor from the high
voltage marking requirement. There is also no definition of ``vehicle
floor'' in GTR No. 13. NHTSA does not believe electrical protection
barriers located under the vehicle floor should be excluded because it
is possible that the high voltage sources enclosed by these barriers
may be accessed in a rollover crash or during vehicle maintenance.
Direct Contact Protection of Connectors
GTR No. 13 specifies direct contact protection requirements for
high voltage connectors separately. Per GTR No. 13, connectors do not
need to meet IPXXB protection if they are located underneath the
vehicle floor and are provided with a locking mechanism, or require the
use of tools to separate the
[[Page 12655]]
connector, or the voltage reduces to below 30 VAC or 60 VDC within one
second after the connector is separated. NHTSA does not believe
connectors of high voltage sources should be excluded. If connectors
are high voltage sources and if they can be accessed, opened, or
removed without the use of tools, regardless of whether they are
located under the floor, they should be required to meet the same
requirements for voltage markings and direct contact protection as
electric protection barriers. Additionally, the agency notes that
``vehicle floor'' and ``connector'' are not defined in GTR No. 13.
Therefore, NHTSA would not exclude connectors of high voltage sources.
Post-Crash Physical Barrier Protection Option
GTR No. 13 specifies that individual contracting parties of the
1998 agreement may elect to propose the physical barrier protection
from direct and indirect contact of high voltage sources and live
parts. According to GTR No. 13, for protection against direct contact,
high voltage sources and live parts are required to have protection
degree IPXXB. For protection against indirect contact, GTR No. 13
requires that the resistance between all exposed conductive parts and
electrical chassis be lower than 0.1 ohm when there is current flow of
at least 0.2 A.
The physical barrier protection option in this NPRM includes the
same provisions for direct and indirect contact protection as that in
GTR No. 13 but adds two additional requirements for indirect contact
protection (from SAE J1766 January 2014).
This first additional requirement is that the resistance between
any two simultaneously reachable exposed conductive parts of the
electrical protection barriers that are less than 2.5 meters from each
other is less than 0.2 ohms. This additional requirement protects
against indirect contact of high voltage sources when two electrical
protection barriers are contacted simultaneously. The second additional
requirement is that the voltages between an electrical protection
barrier enclosing a high voltage source and other exposed conductive
parts are less than or equal to 30 VAC or 60 VDC. This additional
requirement is included in SAE J1766 January 2014 to provide additional
protection from indirect contact of high voltage sources, addressing
the issues raised in the Battelle research of the physical barrier
protection option.
Verification of Post-Crash Indirect Contact Protection
GTR No. 13 states that a high voltage source is considered to have
post-crash indirect contact protection if the electrical protection
barrier enclosing the high voltage source has a galvanic connection to
the chassis by welding. This method of verification is a mere visual
inspection and lacks the objectivity needed for an FMVSS. This NPRM
does not include this method of verification and instead proposes to
use the test procedure in GTR No. 13 whereby a current of 0.2 A is
passed through the connection to determine its resistance.
Physical Barrier Protection of AC High Voltage Sources That Are
Connected to DC High Voltage Sources
This NPRM proposes to adopt the physical barrier protection
requirement for direct contact specified in GTR No. 13 for both post-
crash and during normal vehicle operation. However, for indirect
contact protection, the proposal uses the proposed post-crash indirect
contact protection requirements described above (which include two
additional requirements described above in addition to that specified
in GTR No. 13).
Optional Procedures for Evaluating Electrical Isolation Post-Crash
FMVSS No. 305's test procedure for measuring electrical isolation
of high voltage sources is similar to that in GTR No. 13. However, GTR
No. 13 permits the crash tests to be conducted without energizing the
electric power train while FMVSS No. 305 does not. In conditions where
the high voltage sources are not energized during the crash test, GTR
No. 13 permits measuring electrical isolation resistance of high
voltage sources by other means, including using a megohmmeter.\29\ Yet,
GTR No. 13 does not specify a test procedure to measure isolation
resistance using a megohmmeter.
---------------------------------------------------------------------------
\29\ A megohmmeter is a specialized ohmmeter that is primarily
used to determine electrical isolation resistance. This device
operates by applying a voltage or current to the item being tested.
Because externally applied voltages or currents can disrupt its
measurement (and/or cause damage to the instrument) the megohmmer is
used to test items that are under an inactive and fully de-energized
state.
---------------------------------------------------------------------------
NHTSA is not proposing to conduct the crash test without energizing
the electric power train and so is not permitting the use of the
megohmmeter. NHTSA stated its position on this matter in final rules
published on June 14, 2010 (75 FR 33515), July 29, 2011 (76 FR 45436),
and January 16, 2015 (80 FR 2320). In the January 16, 2015 final rule,
NHTSA noted that the agency's research on the feasibility of using a
megohmmeter for measuring electrical isolation presented certain
technical questions that need to be resolved (i.e., the research showed
that megohmmeters could accurately measure electrical isolation
resistance of DC high voltage sources in an inactive state but did not
consistently do so for AC high voltage sources).
Additionally, electrical isolation resistance measurement with a
megohmmeter is only possible when the electrical power train is not
energized, such as when an inert gas is used in hydrogen containers of
a fuel cell vehicle. NHTSA will address the issue of the use of inert
gas in hydrogen containers of fuel cells vehicles when conducting crash
tests in a future proposal to incorporate into FMVSSs the fuel system
and fuel container integrity requirements of hydrogen fuel cell
vehicles in GTR No. 13. The agency will address in that rulemaking the
use of alternative methods of measuring isolation resistance in
conditions where the electric power train is not energized in crash
tests.
Procedures for Measuring Voltage Post-Crash
FMVSS No. 305 specifies that all post-crash voltage measurements
for determining voltage and electrical isolation of high voltage
sources with respect to the electric chassis be made after a minimum of
5 seconds after the vehicle comes to rest following impact. GTR No. 13
specifies that for determining post-crash electrical isolation of high
voltage sources, the voltage measurements be made after a minimum of 5
seconds after ``impact.'' GTR No. 13 also specifies that for
determining post-crash voltage (for assessing compliance with the low
voltage option), the voltage measurements be made after a minimum of 5
seconds and no later than 60 seconds after impact.
The agency is not proposing to change the timing of voltage
measurement post-crash in FMVSS No. 305 to harmonize with GTR No. 13.
The ``after impact'' interval specified in GTR No. 13 appears less
objective than FMVSS No. 305's measure and adopting the GTR No. 13
specified time for post-crash voltage measurement may reduce the
objectivity of the test. Further, all-in-all we believe this difference
in the timing of voltage measurement in FMVSS No. 305 and GTR No. 13 is
minor.
[[Page 12656]]
Miscellaneous Differences Between the Proposed Regulatory Text and GTR
No. 13
There is some unnecessary or redundant text in some sections of GTR
No. 13 that we have not included in this proposal, to make the
regulatory text more concise. An example of this is in the electrical
isolation option for post-crash electrical safety, under conditions
when the AC and DC high voltage sources are connected. GTR No. 13
specifies that the vehicle meet one of the following requirements: (1)
Electrical isolation of the DC and AC high voltage sources from the
chassis be no less than 500 ohm/volt; (2) electrical isolation of the
DC and AC high voltage sources from the chassis be no less than 100
ohm/volt and the AC high voltage sources also have physical barrier
protection; or (3) electrical isolation of the AC and DC high voltage
sources from the chassis be no less than 100 ohm/volt and the AC high
voltage source is considered as a low voltage source. We believe that
the option (3) requirement above is unnecessary, because if the AC high
voltage source is considered as a low voltage source, it already meets
the low voltage electrical isolation option. Thus, we determined it is
not necessary to provide option (3).
IV. Battelle Study and Developments
NHTSA initiated a research program in 2010, using Battelle as a
contractor, to better understand the safety implications of using a
physical barrier to protect against electric shock. The objectives of
the research were to: (a) Determine failure modes associated with
electrical protection barriers that could potentially result in
electric shock to occupants in the vehicle or to rescue workers due to
direct or indirect contact, (b) evaluate the practicability and
feasibility of test procedures in what was then a draft version \30\ of
GTR No. 13 for direct and indirect contact protection.
---------------------------------------------------------------------------
\30\ The electrical safety requirements in the 2010 draft
version of GTR No. 13 are the same as those in the GTR No. 13 that
was established on June 27, 2013. Henceforth, we refer to the draft
version as the adopted GTR.
---------------------------------------------------------------------------
As discussed below (and in our supporting technical document) \31\
the Battelle research indicates that the physical barrier protection
specified in GTR No. 13 would protect against electric shock when there
is a single point failure in the electrical safety systems. However, if
there were multiple failures in the electrical safety systems specified
in GTR No. 13 for normal vehicle operating conditions,\32\ the Battelle
research indicates that a person could receive an electric shock when
they contact the high voltage sources in certain specific ways.
---------------------------------------------------------------------------
\31\ Along with this document, we have placed in the docket a
supporting technical document providing further information on our
analysis of the Battelle research and GTR No. 13.
\32\ Under GTR No. 13, during normal vehicle operation, all high
voltage sources contained or connected to the power train are
required to be electrically isolated from the chassis (with minimum
electrical isolation of 500 ohms/VAC or 100 ohms/VDC) and enclosed
by physical barriers that prevent direct human contact. The physical
barriers enclosing these high voltage sources are required to be
conductively connected to the chassis (with resistance less than 0.1
ohms) to provide indirect contact shock protection.
---------------------------------------------------------------------------
The Battelle study \33\ identified various scenarios of electrical
safety system failures, including direct contact of high voltage
source, indirect contact of live parts of high voltage sources, loss in
conductive connection between electrical protection barrier and
chassis, and a combination of these failures. Direct contact of a high
voltage source could occur in the event of a crash that results in
mechanical failure of protection barriers or penetration of electrical
insulation that would allow fingers or conductive tools to enter
protection barriers and contact the high voltage sources within the
barrier. Indirect contact of high voltage sources could occur in the
event of a crash in which an electrical protection barrier is energized
due to loss in electrical isolation of the high voltage source within
the barrier.
---------------------------------------------------------------------------
\33\ Hydrogen Fuel Cell Vehicle--Electrical Protective Barrier
Option, Final Report, DOT HS 812134, May 2015. Available at https://www.nhtsa.gov/Research/Crashworthiness/Alternative%20Energy%20Vehicle%20Systems%20Safety%20Research and in
the docket for this NPRM.
---------------------------------------------------------------------------
To illustrate failure modes associated with electric protection
barriers, Battelle used the schematic shown in Figure 4 below in which
a high voltage source (shown on the left side of the figure) is
isolated from the vehicle chassis by resistances RiH and
RiL on the positive and negative side, respectively, and
enclosed in an electrical protection barrier (EPB1). The
high voltage source may be either DC or AC and may represent a variety
of components such as a fuel cell, battery, motor, or capacitor.
Also shown in Figure 4 are electrical wirings from the positive
side of the high voltage source to its negative side to complete the
circuit. The schematic shows two electric protection barriers
(EPB2 and EPB3) enclosing the wirings on the
positive and negative side, respectively, and a body with resistance
Rb contacting these two protection barriers. All three
electrical protection barriers in the figure are conductively connected
to the electrical chassis with resistances RCh,
RChH, and RChL.
For normal vehicle operation, GTR No. 13 requires RiH
and RiL resistances to provide electrical isolation of at
least 500 ohms/VAC or 100 ohms/VDC. It also requires the electrical
wiring to be insulated. Further, it requires the three electrical
protection barriers (EPB1, EPB2, and
EPB3) to have protection degree IPXXD or IPXXB and be
conductively connected to the chassis such that the resistances
RCh, RChH, and RChL are less than 0.1
ohms. The lowest possible value of body resistance Rb is 500
ohms.\34\
---------------------------------------------------------------------------
\34\ IEC TC-60479-I, ``Effects of current on human beings and
livestock--Part I--General Aspects,'' 2005.
---------------------------------------------------------------------------
[[Page 12657]]
[GRAPHIC] [TIFF OMITTED] TP10MR16.003
Battelle's analysis of the schematic in Figure 4 identified
scenarios of direct contact and indirect contact of high voltage
sources. Direct contact occurs when the electrical protection barriers
EPB2 and/or EPB3 are breached or penetrated and
the body contacts the wiring enclosed within. Indirect contact occurs
when EPB2 and/or EPB3 are energized due to loss
of electrical isolation of the high voltage source within the barrier
and the body contacts the electrical protection barriers as shown in
Figure 4. Examples of direct and indirect contact scenarios are
presented below:
Case 1--Direct contact of high voltage source without
electric shock hazard. Protection barrier EPB2 is
compromised and the body directly contacts the electrical wiring from
the positive side, and also contacts the electrical protection barrier
EPB3 enclosing the wiring on the negative side of the high
voltage source (Figure 5). In this case, as long as the resistance
RiL or RiH is greater than or equal to 500 ohms/
VAC or 100 ohms/VDC, the current through the body (shown by dashed
lines) will be within safe limits.
[GRAPHIC] [TIFF OMITTED] TP10MR16.004
Case 2--Direct contact of a high voltage source with
electric shock hazard. Electrical protection barriers EPB2
and EPB3 of the wiring on the positive and negative side of
the high voltage source are compromised and the body contacts the
positive and negative wiring (Figure 6). For the worst Case 2
condition, a body resistance Rb equal to 500 ohms (lowest
possible) is used. For a DC high voltage source of 350V, the minimum
resistance value for RiL and RiH is 35,000 ohms.
Since the body resistance Rb is significantly lower than the
electrical isolation RiL and RiH,
[[Page 12658]]
current through the body (shown by dashed lines) is not limited and the
body would experience electric shock.
[GRAPHIC] [TIFF OMITTED] TP10MR16.005
Case 3--Indirect contact of high voltage source without
electric shock hazard. The wiring on the positive side of the high
voltage source loses electrical isolation to the electrical protection
barrier, EPB2, and the body contacts the electrical
protection barriers EPB2 and EPB3 of the positive
and negative wiring (Figure 7). Similar to Case 1, as long as the
isolation resistance RiL or RiH is greater than
or equal to 500 ohms/VAC or 100 ohms/VDC, the current through the body
(shown by dashed lines) will be within safe limits.
[GRAPHIC] [TIFF OMITTED] TP10MR16.006
Case 4--Indirect contact of high voltage source with
possibility of electric shock. The electric wiring of the positive and
negative sides of the high voltage source lose electrical isolation to
the protective barriers EPB2 and EPB3,
respectively, and the body contacts the two protective barriers
EPB2 and EPB3 (Figure 8). Since RCh,
RChH and RChL are all very low values (less than
0.1 ohms according to GTR No.13), this condition would result in a
short circuit of the high voltage source that could activate and open a
short circuit fuse that is generally equipped in electric
[[Page 12659]]
propulsion vehicles. If a fuse activates, then no current will flow and
so no electrical shock would occur. However, if the fuse does not
activate, and if the electrical isolation RiL and
RiH are reduced to low levels and the chassis resistance is
not significantly low compared to the body resistance, then the current
through the body contacting the protective barriers (shown by dashed
line) may not be within safe limits and the body could experience
electric shock. This scenario is further discussed in the Alliance
petition for rulemaking (infra) and in the supporting technical
document of this NPRM.
[GRAPHIC] [TIFF OMITTED] TP10MR16.007
Battelle identified additional scenarios, including those regarding
loss in electrical isolation RiL and/or RiH and
loss of electrical bonding of the protective barriers with the
chassis.\35\ These scenarios showed that, for vehicles that meet the
electrical isolation and physical barrier protection requirement in GTR
No. 13 during normal vehicle operation, electric shock is not possible
when there is only a single point of failure in the electrical safety
systems. However, electric shock is possible when at least two or three
failures of electrical safety systems occur and a human body comes into
contact with two compromised protective barriers on opposite sides of
the high voltage source to complete the circuit. For example, in Case
2, electric shock could occur if two electrical protection barriers on
the positive and negative side of the high voltage source are
compromised and a body contacts the positive and negative side of a
high voltage source by entering the two compromised protection
barriers. In Case 4, electric shock could occur only if at least four
electric safety features (loss in electrical isolation of electrical
protection barriers EPB2 and EPB3 which are on the positive and
negative side of the high voltage source and loss in electrical
isolation RiH and RiL of the high voltage source) are compromised and
the body contacts both compromised barriers, EPB2 and EPB3.
---------------------------------------------------------------------------
\35\ Details of these scenarios are presented in the Battelle
final report, DOT HS 812 134, May 2015, which is available in the
docket of this NPRM.
---------------------------------------------------------------------------
To address the concern of electric shock from indirect contact, GTR
No. 13 specifies that the physical barriers enclosing high voltage
sources should be conductively connected with low resistance (less than
0.1 ohms) to the electrical chassis, so that if one segment of the high
voltage source should lose electrical isolation, all contactable
surfaces of the vehicle chassis and protective barriers will be at the
same voltage and thereby prevent electric shock to a person touching
two different protective barriers or parts of the electrical chassis.
Battelle also evaluated the maximum resistance (0.1 ohms) of the
electric bonds between electrical protection barriers and the
electrical chassis that is specified in GTR No. 13. Battelle found that
in the event of multiple electrical safety system failures (loss in
electrical isolation of both segments of the high voltage source to
their electrical protection barriers) and a person touching both the
barriers to complete the circuit, the resistance of 0.1 ohms between
the protective barrier and electrical chassis would not be sufficient
to prevent electric shock to the person contacting the protective
barriers.\36\
---------------------------------------------------------------------------
\36\ This issue is further explained in the supporting technical
document in the docket of this NPRM.
---------------------------------------------------------------------------
V. Toyota Petition for Rulemaking
On December 23, 2013, Toyota submitted a petition for rulemaking to
amend FMVSS No. 305 by adding an additional compliance option for
electrical safety to allow HFCVs to be offered for sale in the US.
Toyota notes that the requested compliance option includes elements of
the electrical protection barrier that is currently in GTR No. 13.
Toyota notes that many countries, including the European Union, Japan,
and South Korea, already include electrical protection barrier as a
compliance option for electrical safety in their standards.
Toyota explains its reasons for petitioning as follows.\37\ FMVSS
No. 305
[[Page 12660]]
requires compliance with electrical safety requirements following
impacts ``at any speed up to and including'' the specified test speeds.
Toyota notes that for electric powered vehicles, including fuel cell
vehicles, the DC high voltage sources (e.g. high voltage battery) will
be connected to the AC high voltage sources (e.g. electric motor)
during normal vehicle operation and in low speed crashes where the
automatic disconnect does not operate.\38\ In such conditions, when the
AC and DC high voltage sources are connected, the isolation resistance
at the AC high voltage source is in parallel with the isolation
resistance of the DC high voltage source. Therefore, even if the
electrical isolation provided for the AC high voltage source is
significantly greater than the required 500 ohms/volt, the effective
isolation resistance measured at the AC high voltage source can be, at
most, as high as that provided for the DC high voltage source.
---------------------------------------------------------------------------
\37\ Honda Motor Co. Ltd. and American Honda Motor Co. Inc.
(Honda) echoed these concerns in its comments on NHTSA's notice of
receipt of Toyota's exemption petition, supra. See Docket No. NHTSA-
2014-0068.
\38\ Toyota noted that the automatic disconnect mechanism is not
activated in low speed crashes, such as minor fender benders that
may occur in a parking lot and in conditions where the inverters in
the fuel cell auxiliary system may continue to operate.
---------------------------------------------------------------------------
Toyota explains that in current battery electric vehicles,
manufacturers are able to provide electrical isolation for the high
voltage battery in excess of 500 ohms/volt, even though FMVSS No. 305
permits DC high voltage sources to have 100 ohms/volt with an
electrical isolation monitoring system. On the other hand, it is
difficult to maintain electrical isolation greater than 500 ohms/volt
for the fuel cell stack in an HFCV due to the presence of fuel cell
coolant.\39\ Therefore, when the DC and AC high voltage sources are
connected in an HFCV, it may not be possible to achieve the required
500 ohms/volt electrical isolation for AC high voltage sources.
---------------------------------------------------------------------------
\39\ The fuel cell coolant may get ionized during repeated
operation and may reduce the electrical isolation provided.
---------------------------------------------------------------------------
Toyota states that NHTSA said in the June 14, 2010 final rule (75
FR 33515) that the agency was issuing the final rule to facilitate the
development and introduction of fuel cell vehicles. One provision
provided by the final rule was to specify lower minimum electrical
isolation requirements for DC than AC high voltage sources (500 ohms/
volt for AC and 100 ohms/volt for DC sources). Toyota further asserts
that this flexibility offered for HFCVs is not useful unless a
provision is made for the condition when the AC and DC high voltage
sources are connected, such as after a low speed crash.\40\ Since such
a provision is currently not available, HFCVs are essentially required
to provide electrical isolation levels at or in excess of 500 ohms/volt
at the fuel cell stacks.
---------------------------------------------------------------------------
\40\ FMVSS No. 305 requires that the electrical safety
requirements in FMVSS No. 305 be met after front, rear, and side
crash tests that include low speeds. In such conditions (which
includes ``fender benders''), the automatic disconnect is designed
to remain closed so that the vehicle remains operational and so the
driver can continue driving the vehicle.
---------------------------------------------------------------------------
Toyota asks that NHTSA adopt an alternative provision for
electrical safety through isolation of high voltage sources that
involves electrical protection barriers to address post-crash
conditions where the AC and DC high voltage sources are connected. The
petitioner suggests adopting GTR No. 13's specification that the
electrical isolation of the high voltage source may be greater or equal
to 100 ohms/volt for an AC high voltage source if that AC source is
conductively connected to a DC high voltage source, provided that the
AC high voltage source meets the specified post-crash physical barrier
protection requirements in GTR No. 13.\41\ The petitioner suggests
specific regulatory text for the requirements and test procedures that
are based on the specifications in GTR No. 13 for modifying FMVSS No.
305 to include the petitioner's requested compliance option.
---------------------------------------------------------------------------
\41\ The requirements for post-crash physical barrier protection
option for electrical safety in GTR No. 13 are that after a crash
test, high voltage sources have protection level IPXXB and that the
resistance between all exposed conductive parts and the electrical
chassis be lower than 0.1 ohm when there is a current flow of at
least 0.2 amperes.
---------------------------------------------------------------------------
Toyota also requests that NHTSA amend S6.4 of FMVSS No 305 which
requires vehicles to satisfy all of the post-crash performance
requirements ``after being rotated on its longitudinal axis to each
successive increment of 90 degrees . . . . .'' to indicate that
compliance with electrical isolation and physical barrier protection
requirements would be evaluated after the vehicle is rotated a full 360
degrees. Toyota notes that the vehicle conditions related to the
electrical isolation and physical barrier protection requirements do
not change at various increments of a rollover and that it would be
unreasonably dangerous for laboratory personnel to conduct the
specified tests with the vehicle at 90 degree increments.
VI. Alliance Petition for Rulemaking
On November 10, 2014, the Alliance submitted a petition for
rulemaking to update and upgrade FMVSS No. 305 to incorporate a
physical barrier compliance option to provide protection against
electric shock. The Alliance states that the implementation of a
physical barrier compliance option is especially critical to facilitate
both the introduction of complying HFCVs as well as 48 volt mild hybrid
technologies.\42\ The petitioner also believes the amendments would
enable safe design innovation for all electrified vehicles, as well as
reduce CO2 emissions and increase fuel economy.
---------------------------------------------------------------------------
\42\ 48 volt mild hybrid systems are generally internal
combustion engines and a 48 volt battery equipped with an electric
machine (one motor/generator in a parallel configuration) allowing
the engine to be turned off whenever the car is coasting, braking,
or stopped, yet restart quickly. These mild hybrids may employ
regenerative braking and some level of power assist to the internal
combustion engine, but do not have an exclusive electric-only mode
of propulsion.
---------------------------------------------------------------------------
The Alliance states that the physical barrier compliance option is
essential for FMVSS No. 305 certification of HFCVs in low speed crashes
where the automatic disconnect is not designed to operate. The Alliance
also states that in such crashes, the DC high voltage source can
impinge on the AC high voltage sources through the inverter, making it
impractical to achieve 500 ohms/volt electrical isolation for the AC
high voltage source.
The Alliance explains that while it would seem that 48 volt mild
hybrid systems would not be within the intended scope of FMVSS No.
305,\43\ these systems typically convert DC voltage into three-phase AC
voltage that can exceed the 30 VAC voltage threshold for consideration
as a high voltage source in FMVSS No. 305.\44\ The
[[Page 12661]]
Alliance states that these 48 volt mild hybrid systems are grounded to
the vehicle chassis and so cannot viably meet the existing isolation
resistance option as well as the pretest measurement for isolation
resistance. The Alliance notes that while it is feasible to design a 48
volt mild hybrid system that meets FMVSS No. 305 electrical isolation
requirements, isolated systems inherently involve more complexity,
higher consumer costs, and higher mass resulting in reduced fuel
economy and increased emissions. The Alliance suggests that these
results are particularly inappropriate since there is no incremental
safety benefit provided by an isolated system compared to physical
barriers. The Alliance states that as a result, it is requesting
modifications to FMVSS No. 305 to permit the introduction 48 volt mild
hybrid systems and HFCVs into the U.S.
---------------------------------------------------------------------------
\43\ FMVSS No. 305 considers electrical sources operating at
voltages greater than or equal to 30 VAC or 60 VDC as high voltage
sources that are subject to FMVSS No. 305 electrical safety
requirements.
\44\ We have also considered information provided by Mercedes-
Benz in a briefing to the agency on June 2, 2015. As explained by
Mercedes-Benz, the AC-DC inverter converts the DC current from the
48 V battery into AC for the 3-phase AC motor. Mercedes-Benz showed
that the voltage between the electrical chassis and each of the
phases of the AC electric motor is switched DC voltage (voltage
between 0 and 48 volts). Since that voltage is less than 60 volts,
it is considered low DC voltage under FMVSS No. 305. However,
Mercedes-Benz noted that the voltage between two phases of the AC
motor is AC, and may be slightly greater than 30 VAC under certain
circumstances, which can be considered a high voltage AC source
under the standard. Mercedez-Benz explained its view that physical
barrier protection around the AC motor, and around cables from the
inverter to the motor, would mitigate human contact with these AC
high voltage sources, and thereby mitigate the likelihood of
electric shock. Additionally, the presenter showed that electrical
protection barriers enclosing the AC high voltage sources could be
conductively connected to the chassis with resistance less than 0.1
ohms, and thereby provide electric shock protection from indirect
contact of the high voltage sources. See the memorandum in the
docket for this NPRM on Mercedes-Benz, Daimler AG, input on 48 V
mild hybrid systems.
---------------------------------------------------------------------------
The Alliance notes that in NHTSA's July 29, 2011, response to
petitions for reconsideration of the 2010 final rule,\45\ NHTSA
deferred consideration of the physical barrier protection option
pending additional research. The Alliance states that the agency's
research on the physical barrier option \46\ showed that electric shock
from indirect contact in a crash could only be possible, if the
following conditions were met (see Case 4 described above and
illustrated in Figure 8):
---------------------------------------------------------------------------
\45\ 76 FR 45436.
\46\ ``Hydrogen Fuel Cell Vehicle--Electrical Protective Barrier
Option,'' DOT HS 812134, May 2015, is available at https://www.nhtsa.gov/Research/Crashworthiness/Alternative%20Energy%20Vehicle%20Systems%20Safety%20Research and in
the docket for this NPRM.
---------------------------------------------------------------------------
(1) A loss of electrical isolation within the enclosure of a high
voltage source,
(2) a loss of electrical isolation within a second (different) high
voltage source enclosure,
(3) these two distinct losses in isolation (specified in (1) and
(2)) occur on opposite rails (positive and negative) of the high
voltage source,
(4) the overcurrent devices do not automatically open the circuit
as a result of the simultaneous loss of isolation on the positive and
negative rails to ground (the Alliance states that the normal design
practice is for the overcurrent devices to automatically open under the
circumstances outlined in (3)),
(5) a person has access to these two enclosures in the crashed
vehicle, and
(6) a person touches these two enclosures simultaneously.
The Alliance believes that the likelihood of each of the above 6
events occurring is remote and that the simultaneous occurrence of
these events in real world situations is even more remote and
exceedingly small. The Alliance believes that the other scenarios
identified in the Battelle final report as having potential safety
concerns similarly require multiple failures in the system to occur,
followed by what the petitioner believes to be unlikely human contacts
and a lack of fuses or other electrical safety protection.
Nevertheless, the Alliance states that, despite the extremely low
likelihood of a safety issue from any of the scenarios in the final
Battelle report, the updated version of SAE J1766 (January 2014) \47\
includes performance requirements that safeguard against all safety
critical scenarios identified in the Battelle report.
---------------------------------------------------------------------------
\47\ SAE J1766, ``Recommended practice for electric, fuel cell,
and hybrid electric vehicle crash integrity testing,'' January 2014,
SAE International, https://www.sae.org.
---------------------------------------------------------------------------
The Alliance expresses its support of the December 23, 2013
petition for rulemaking from Toyota to modify FMVSS No. 305 to
facilitate the sale of HFCVs in the U.S. (petition discussed infra) and
notes that the January 2014 version of SAE J1766 also includes
provisions for a modified isolation requirement for AC systems with
physical barriers, as Toyota requests in its petition for rulemaking.
The Alliance states that SAE J1766 January 2014 also has provisions for
a ``stand-alone'' physical barrier protection compliance option that is
needed for facilitating the development of 48 volt mild hybrid systems,
since electrical components of these systems are conductively connected
to the chassis and so cannot viably satisfy electrical isolation
requirements. The Alliance believes that this ``stand-alone'' physical
barrier compliance option provides sufficient protection to address
potential (although unlikely, states the petitioner) safety critical
scenarios identified in the Battelle report.
The Alliance asserts that while FMVSS No. 305 only evaluates
electrical safety in post-crash condition, auto manufacturers also
design for high voltage safety under normal operating conditions. The
petitioner states that providing physical barriers is the most common
method of protection against high voltage contact in the automotive
industry, as well as other industries that use high voltage electric
circuits. The Alliance believes it is reasonable that this method of
protection against electric shock hazard can also be used for post-
crash shock protection provided these physical barriers remain intact
post-crash, and that either the voltage between exposed conductive
parts is below 30 VAC or 60 VDC, or resistance between exposed
conductive parts of the barriers and electrical chassis is below
specified resistance levels.
The Alliance states it is urgent to update FMVSS No. 305 to
facilitate the introduction of HFCVs and 48 volt mild hybrid technology
vehicles that are necessary to accommodate compliance with Corporate
Average Fuel Economy (CAFE) standards. Consequentially, the petitioner
states that it is not additionally requesting adoption of the low
energy compliance option that is also included in SAE J1766 January
2014. Instead the petitioner requests that the low energy compliance
option be considered for the electric vehicle safety (EVS) GTR that is
currently in process.
SAE J1766 January 2014 also changes the time criterion for
initiating verification of post-crash electrical safety from 5 seconds
after the vehicle comes to rest (similar to the specification currently
in FMVSS No. 305) to 10 seconds after initial impact. The Alliance
states that given the urgency necessary to facilitate the introduction
of HFCVs and 48 volt mild hybrid technology, it is limiting its
petition for rulemaking to only include the post-crash physical barrier
protection compliance option in SAE J1766 January 2014 into FMVSS No.
305.
Specifically, the Alliance requests including section 5.3.4 of SAE
J1766 January 2014 into FMVSS No. 305. This section provides two
options for post-crash electrical safety by means of physical barriers.
The first option (Option 1 for physical barrier protection) is
similar to the post-crash physical barrier protection option for
electrical safety in GTR No. 13,\48\ but includes an additional
requirement that the resistance between the high voltage source
enclosed by the physical barrier and the exposed conductive parts of
the electrical protection barrier be greater than 0.01 ohms/volt for DC
high voltage sources and 0.05 ohms/volt for AC high voltage sources.
---------------------------------------------------------------------------
\48\ Protection against direct contact with high voltage sources
is provided by protection degree IPXXB and protection against
indirect contact of high voltage sources is provided by requiring
the resistance between exposed conductive parts and the electrical
chassis to be lower than 0.1 ohm when there is a current flow of at
least 0.2 amperes.
---------------------------------------------------------------------------
The second option for electrical safety through electrical
protection barriers (Option 2 for physical barrier protection) in SAE
J1776 January 2014
[[Page 12662]]
is through protection from direct contact by protection degree IPXXB,
and that the voltage between the electrical protection barrier and
other exposed conductive parts and the electrical chassis is less than
or equal to 30 VAC for AC high voltage sources and 60 VDC for DC high
voltage sources. The Alliance states that Option 2 is similar to the
low voltage option already in FMVSS No. 305.
The Alliance supplemented its petition by a submission dated
October 20, 2015, which provided an analysis of its proposal for
electrical safety through physical barriers.\49\ Figure 9, below,
presents the circuit diagram the petitioner provided for the
representation of a high voltage source (e.g., battery) with voltage of
1,000 VAC or 1,500 VDC, enclosed in physical barriers that are
conductively connected to the electrical chassis with resistance less
than or equal to 0.1 ohms. The circuit diagram also has a
representation of a human body with a minimum resistance of 500 ohms
\50\ contacting protective barriers enclosing opposite rails of the
high voltage source. The resistances R1 and R2 in
Figure 9 represent the resistance between the high voltage source and
the protective physical barriers that enclose it. This circuit diagram
is a representation of the indirect contact Battelle scenario, Case 4,
in the event that electrical isolation of the high voltage source to
the chassis is lost and RiH and RiL are equal to
zero.
---------------------------------------------------------------------------
\49\ The Alliance analysis of the physical barrier protection
option proposed for electrical safety (October 2014) is in the
docket of this NPRM.
\50\ According to IEC TC-60479-I, ``Effects of current on human
beings and livestock--Part I--General Aspects,'' 2005, the lowest
possible electrical resistance of a human body is 500 ohms.
[GRAPHIC] [TIFF OMITTED] TP10MR16.008
According to Option 1 of the electrical protection barrier in the
Alliance submission, the combined resistance \51\ of R1 and R2 is
required to be less than or equal to 0.05 ohms/VAC or 0.01 ohms/VDC.
Under Option 2, the voltage difference between barrier #1 and barrier
#2 is required to be less than or equal to 30 VAC or 60 VDC. The
Alliance observes that its analysis using the model in Figure 9
demonstrates that the proposed physical barrier protection option
provides equivalent levels of safety as the electrical isolation option
\52\ currently in FMVSS No. 305 in all the safety critical scenarios
identified in the Battelle study, including the scenario Case 4 for
indirect contact.
---------------------------------------------------------------------------
\51\ R1 and R2 resistances are in a parallel configuration.
\52\ The current through the body Ib (shown in Figure 9) is less
than or equal to 10 mA of direct current or 2 mA of alternating
current.
---------------------------------------------------------------------------
The Alliance also states that the Option 1 electrical protection
barrier is the same as that of Option 2 since the conditions that meet
the Option 1 requirements also meet the Option 2 requirements. The
Alliance acknowledges that it is difficult to measure the resistance
between a high voltage source and the exposed conductive parts of the
electrical protection barrier that encloses the high voltage source, as
is needed to evaluate the Option 1 electrical protection barrier.\53\
The Alliance recommends that NHTSA incorporate Option 2 (direct contact
protection degree IPXXB and voltage between electrical protection
barrier and exposed conductive parts less than or equal to 30 VAC or 60
VDC) into FMVSS No. 305 since its analysis indicates that compliance
with Option 1 would also entail compliance with Option 2.
---------------------------------------------------------------------------
\53\ The resistance level is too low to measure accurately and
in order to access a high voltage source enclosed in the physical
barrier, some disassembly of the barrier may be required in some
cases.
---------------------------------------------------------------------------
The Alliance specifies the following test procedures from Appendix
C in SAE J1766 January 2014: (1) Section C.1 for verifying IPXXB
protection degree of physical barriers, which is similar to the
procedure in GTR No. 13, (2) Section C.2.1 for verifying that the
resistance between electrical protection barriers and electrical
chassis is less than 0.1
[[Page 12663]]
ohms, and (3) Section C.2.3 to verify that the voltage difference
between any two exposed conductive parts of the electric chassis
(including physical barriers) is less than or equal to 30 VAC or 60
VDC. The Alliance also specifies Section C.2.2 in SAE J1766 January
2014 for verifying that the resistance between a high voltage source
and the electrical chassis \54\ is greater than or equal to 0.05 ohms/
VAC or 0.01 ohms/VDC. We note, however, that section C.2.2 does not
provide a specific method of measurement and instead states, ``The
measurement may be performed by any means that provides sufficient
accuracy for the post-crash situation.''
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\54\ Since the resistance between a protective physical barrier
and the electrical chassis is required to be less than or equal to
0.1 ohm (a very low value), the resistance between a high voltage
source and the physical barrier would be the same as or only
slightly lower than the resistance between the high voltage source
and the electrical chassis.
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These test procedures are further discussed in a later section
analyzing the petitions for rulemaking to modify FMVSS No. 305.
VII. Overview of Proposed Rule
NHTSA is initiating rulemaking to consider adopting GTR No. 13 into
FMVSS No. 305, as appropriate under the Vehicle Safety Act, and to
address the issues raised by the Alliance and Toyota in their
respective petitions. We request comment on the decisions put forth in
this NPRM, including those regarding minor additional provisions that
the agency is considering to address the concerns of the petitioners.
NHTSA believes that this NPRM would improve the level of safety
afforded to the public. Adopting the provisions from GTR No. 13 that
reduce the risk of harmful electric shock during normal vehicle
operation would improve FMVSS No. 305 by expanding its performance
requirements beyond post-crash conditions. The proposed requirements
would provide post-crash compliance options for new power train
configurations that ensure that those configurations provide a
comparable level of post-crash safety compared to existing electric
vehicles.
The proposed amendments are summarized as follows. In furtherance
of implementing GTR No. 13 and in response to the petitions for
rulemaking--
a. This NPRM proposes to add electrical safety requirements for
vehicle performance during normal vehicle operations (as opposed to
during and after a crash), to mitigate electric shock due to loss in
electrical isolation and direct or indirect contact of high voltage
sources. The electrical safety requirements during normal vehicle
operations would include requirements for:
1. Direct Contact Protection From High Voltage Sources
i. IPXXD protection level for high voltage sources inside
passenger and luggage compartments. IPXXB protection level for high
voltage sources not in passenger and luggage compartments.
ii. IPXXB protection level for service disconnect that can be
opened or removed without tools.
iii. Markings on barriers of high voltage sources that can be
physically accessed, opened, or removed without the use of tools.
iv. Orange color outer covering for cables of high voltage
sources that are located outside electrical protection barriers.
2. Indirect Contact Protection From High Voltage Sources
Exposed conductive parts of electrical protection barriers would
have to be conductively connected to the chassis with a resistance
less than 0.1 ohms, and the resistance between two simultaneously
reachable exposed conductive parts of electrical protection barriers
that are within 2.5 meters of each other would have to be less than
0.2 ohms.
3. Electrical Isolation of High Voltage Sources
i. 500 ohms/volt or higher electrical isolation for AC high
voltage sources and 100 ohms/volt or higher for DC high voltage
sources
ii. For conditions where AC and DC bus are connected, AC high
voltage sources would be permitted to have electrical isolation of
100 ohms/volt or higher, provided they also have the direct and
indirect contact protection described in 1 and 2, above.
iii. There would be an exclusion of 48 volt hybrid vehicles from
electrical isolation requirements during normal vehicle operation.
4. Electrical Isolation Monitoring System for DC High Voltage Sources
on Fuel Cell Vehicles
5. Electrical Safety During Charging Involving Connecting the Vehicle
to an External Electric Power Supply
i. Minimum electrical isolation resistance of one million ohms
of the coupling system for charging the electrical energy storage
system; and
ii. Conductive connection of the electric chassis to earth
ground before and during exterior voltage is applied.
6. Mitigating Driver Error by--
i. Requiring an indication to the driver when the vehicle is in
active driving mode upon vehicle start up and when the driver is
leaving the vehicle; and,
ii. Preventing vehicle movement by its own propulsion system
when the vehicle charging system is connected to the external
electric power supply.
b. This NPRM proposes to amend FMVSS No. 305's post-crash
electrical safety requirements. The post-crash electrical safety
requirements would include:
1. Adding an additional optional method of meeting post-crash
electrical safety requirements through physical barrier protection
from high voltage sources. The proposed specifications of this
optional method of electric safety include requirements ensuring
that:
i. High voltage sources would be enclosed in barriers that
prevent direct human contact with high voltage sources (IPXXB
protection level),
ii. Exposed conductive parts of electrical protection barriers
would be conductively connected to the chassis with a resistance
less than 0.1 ohms, and the resistance between two simultaneously
reachable exposed conductive parts of electrical protection barriers
that are less than 2.5 meters from each other would be less than 0.2
ohms, and
iii. Voltage between a barrier and other exposed conductive
parts of the vehicle would be at a low voltage level that would not
cause electric shock (less than 60 VDC or 30 VAC).
2. Permitting an AC high voltage source that is conductively
connected to a DC high voltage source to meet lower minimum
electrical isolation requirement of 100 ohms/volt provided the AC
high voltage source also has physical barrier protection specified
in 1, above.
VIII. Proposal Addressing Safety During Normal Vehicle Operations
We first discuss the proposed requirements for vehicle performance
during normal vehicle operations, followed by those for performance
post-crash.
a. Direct Contact Protection From High Voltage Sources
GTR No. 13 specifies safety measures to ensure that high voltage
sources cannot be contacted. This safety measure is to enclose high
voltage sources in physical barriers (electrical protection barriers)
to prevent direct human contact. NHTSA is proposing to include in FMVSS
No. 305 the direct contact protection requirements specified in GTR No.
13 for the passenger and luggage compartments and other areas.\55\
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\55\ GTR No. 13 assesses the potential for direct contact with
high voltage components using test probes specified in ISO 20653.
---------------------------------------------------------------------------
NHTSA is proposing to assess protection against direct contact with
high voltage sources contained inside the passenger and luggage
compartments using a 1.0 mm diameter and 100 mm long test wire probe
(IPXXD). This test probe ensures that any gaps in the protective
barriers are
[[Page 12664]]
no larger than 1 mm and that any live components contained within are
no closer to the gap than 100 mm. This ensures that body parts,
miscellaneous tools or other slender conductive items typically present
in a passenger or luggage compartment cannot penetrate any gaps/seams
in the protective enclosures and contact high voltage components
contained within.
For assessing protection against direct contact with high voltage
sources in areas other than the passenger and luggage compartments
under normal operating conditions, NHTSA is proposing to use the test
probe IPXXB, representing a test finger. In areas other than the
passenger and luggage compartments, the barrier would not likely
contact tools and other slender conductive items. Therefore, protection
using the test wire probe IPXXD would not be necessary and the test
finger probe IPXXB would be appropriate to prevent inadvertent contact
with high voltage components contained in the protective enclosures, by
persons such as mechanics.
GTR No 13 also requires that a service disconnect that can be
opened, disassembled, or removed without tools requires IPXXB
protection when it is opened, disassembled, or removed. NHTSA is
proposing to include this requirement into FMVSS No. 305, as well as a
definition for a service disconnect.
NHTSA is proposing marking (yellow high voltage symbol) for
enclosures and barriers of high voltage sources that can be physically
accessed, opened, or removed without the use of tools, similar to GTR
No. 13. As explained earlier in this preamble, we are not excluding
some barriers as GTR No. 13 does.
NHTSA is proposing that cables for high voltage sources which are
not located within electrical protection barriers to be identified by
an orange color outer covering, similar to GTR No. 13. However, as
explained earlier in this preamble, we are not excluding some
connectors as GTR No. 13 does.
As noted earlier in this preamble, GTR No. 13 specifies direct
contact protection requirements for high voltage connectors separately,
and has exclusions with which we do not agree. Per GTR No. 13,
connectors do not need to meet IPXXB protection if they are located
underneath the vehicle floor and are provided with a locking mechanism,
or require the use of tools to separate the connector, or the voltage
reduces to below 30 VAC or 60 VDC within one second after the connector
is separated. For the reasons given earlier, NHTSA does not believe
that the exclusions are warranted and does not anticipate adopting them
in a final rule.
b. Indirect Contact Protection From High Voltage Sources
Under GTR No. 13, exposed conductive parts (parts that can be
contacted with the test probes, IPXXD or IPXXB, and become electrically
energized under electrical isolation failure conditions) have to be
protected against indirect contact during normal vehicle operation. GTR
No. 13 requires electrical protection barriers or enclosures of high
voltage sources to be conductively connected to the electrical chassis
with resistance of no more than 0.1 ohms during normal vehicle
operations. This requirement would provide protection from electric
shock by shunting \56\ any harmful electrical currents to the vehicle
chassis should any electrically charged components lose isolation
within the protective barrier.
---------------------------------------------------------------------------
\56\ Shunting is when a low-resistance connection between two
points in an electric circuit forms an alternative path for a
portion of the current. If a human body contacts an electrical
protection barrier that is energized due to loss in electrical
isolation of a high voltage source enclosed in the barrier, most of
the current would flow through the chassis rather than through the
human body because the current path through the chassis has
significantly lower resistance (less than 0.1 ohm) than the
resistance of the human body (greater or equal to 500 ohm).
---------------------------------------------------------------------------
For indirect contact protection, we propose to apply the same
indirect contact protection requirements and test procedures as would
apply under post-crash conditions (see discussion in next section,
below). The proposed indirect contact protection requirements would be
for exposed conductive parts of electrical protection barriers to be
conductively connected to the chassis with a resistance less than 0.1
ohms and that the resistance between two simultaneously reachable
exposed conductive parts of electrical protection barriers that are
within 2.5 meters of each other be less than 0.2 ohms. These
resistances would be measured by passing a current of at least 0.2 A
between exposed conductive parts and the electrical chassis. For the
reasons previously discussed, NHTSA is not including GTR No. 13's
provision that permits visual inspection of welds as a method of
assessing compliance of indirect contact protection.
c. Electrical Isolation of High Voltage Sources
This NPRM would require that under normal operating conditions, all
high voltage sources of the power train and those connected to the
power train have sufficient electrical isolation resistance measured
against the electrical chassis to ensure that current flowing through a
human body in contact with the vehicle is not dangerous.
For conditions where DC and AC high voltage sources are isolated
from each other, DC high voltage sources would be required to have a
minimum electrical isolation of 100 ohms/volt and AC high voltage
sources would be required to have a minimum of 500 ohms/volt.
For conditions where DC and AC high voltage sources are connected,
AC and DC high voltage sources would be permitted to have a minimum
electrical isolation of 100 ohms/volt, provided the AC high voltage
source has direct and indirect contact protection in a. and b. above.
We proposed to exclude 48 volt hybrid vehicles from these
electrical isolation requirements during normal vehicle operation.
Since electric components in 48 volt mild hybrid systems are
conductively connected to the electric chassis, these systems would not
be able to comply with electrical isolation requirements both during
normal vehicle operations and after a crash. Therefore, we believe that
the ``normal use'' requirements in GTR No. 13 need to be modified to
permit the introduction of 48 volt mild hybrid systems.
The United Nations Economic Commission for Europe Regulation 100
(ECE R.100) \57\ normal operation requirements were modified on June
10, 2014 to facilitate the development and sale of 48 volt mild hybrid
systems. Under these changes, 48 volt mild hybrid systems that are
conductively connected to the electrical chassis are exempt from the
in-use electrical isolation requirements. However, electrical
protection barriers are still required during normal vehicle operations
for high voltage components of these 48 volt mild hybrid systems so as
to provide direct and indirect contact protection. As discussed in a
later section for post-crash electrical safety requirements, we believe
that these 48 volt mild hybrid systems with electrical protection
barriers for all high voltage components in the system would not pose
concerns regarding electric shock. Therefore, NHTSA proposes to include
a similar exclusion from in-use electrical isolation requirements for
48 volt mild hybrid systems that are conductively connected to the
electrical chassis.
---------------------------------------------------------------------------
\57\ Uniform Provisions Concerning the Approval of Vehicles with
Regard to Specific Requirements for the Electric Power Train, ECE
R.100-02, June 24, 2014.
---------------------------------------------------------------------------
[[Page 12665]]
d. Electrical Isolation Monitoring System for DC High Voltage Sources
on Fuel Cell Vehicles
GTR No. 13 requires that DC high voltage sources (other than the
coupling system for charging) in HFCVs have an on-board electrical
isolation monitoring system, together with a warning to the driver if
the isolation resistance drops below the minimum required value of 100
ohms/volt. Similarly, FMVSS No. 305 currently specifies that DC high
voltage sources that comply with electrical safety requirements by the
electrical isolation of 100 ohms/volt must have an electrical isolation
monitoring system to warn the driver. SiCnce most HFCVs would comply
with the electrical isolation requirements in FMVSS No. 305 using the
100 ohms/volt option,\58\ these HFCVs, which must have an electrical
isolation monitoring system under GTR No. 13, would also be required by
FMVSS No. 305 to have the monitoring system.
---------------------------------------------------------------------------
\58\ In fuel cell vehicles, the presence of fuel cell coolant
may not permit electrical isolation levels of 500 ohms/volt of the
DC source.
---------------------------------------------------------------------------
Nonetheless, to ensure that the intent of GTR No. 13 and FMVSS No.
305 are met, the agency is proposing to amend FMVSS No. 305 to indicate
expressly that each DC high voltage source in fuel cell vehicles would
need to be equipped with an electrical isolation monitoring system.
e. Protection From Electric Shock During Charging
GTR No. 13 requires electric vehicles whose rechargeable energy
storage system are charged by conductively connecting to an external
power supply to have a device to enable conductive connection of the
electrical chassis to the earth ground during charging. Additionally,
GTR No. 13 requires the isolation resistance between the high voltage
source and the electrical chassis to be at least 1 million ohms when
the charge coupler is disconnected. The first requirement ensures that
in the event of electrical isolation loss during charging, a person
contacting the vehicle does not form a ground loop with the chassis and
sustain significant electric shock. The second requirement ensures that
the magnitude of current through a human body when a person contacts a
vehicle undergoing charging is low and in the safe zone. NHTSA believes
these two normal use charging safety requirements are warranted and
proposes to include them in FMVSS No. 305.
f. Mitigating Driver Error
Consistent with GTR No. 13, we propose amending FMVSS No. 305 to
add requirements that mitigate the likelihood of driver error in
operating electric vehicles. First, we propose requiring vehicles to
provide an indication to the driver when the vehicle is in an active
driving mode upon vehicle start up and when the driver is leaving the
vehicle.\59\ Second, we propose requiring vehicles to prevent vehicle
movement by its own propulsion system when the vehicle charging system
is connected to the external electric power supply.
---------------------------------------------------------------------------
\59\ We note that an NPRM issued on FMVSS No. 114, ``Theft
protection and rollaway prevention'' (76 FR 77183) proposes to
require vehicles with keyless ignition controls to provide an
audible warning to the driver exiting the vehicle while the
propulsion system is operating. We request comment on whether the
FMVSS No. 114 requirement, if adopted, would satisfy this provision
in the GTR.
---------------------------------------------------------------------------
IX. Proposal Addressing Safety Post-Crash
FMVSS No. 305 requires that after a crash, each high voltage source
in the vehicle are either electrically isolated from the vehicle's
chassis, or their voltage is reduced to levels considered safe from
electric shock hazards (i.e., less than 30 VAC or less than 60 VDC).
As noted in earlier sections, GTR No. 13 specifies that vehicles
may meet regulatory requirements by having no high voltage levels (see
(a) below), meet physical barrier protection requirements (see (b))
below, or meet electrical isolation requirements (see (c) below):
a. Voltage levels: The voltages of the high voltage source must
be less than or equal to 30 VAC or 60 VDC within 60 seconds after
the impact. (This option for electrical safety is currently in FMVSS
No. 305.)
b. Electrical protection barrier: The physical protection
requirement is an option each contracting party of the 1998
agreement may elect to adopt. The provision is similar to the
electrical safety requirements during normal operations except that
the protection degree IPXXB applies rather than IPXXD. (The
provision for electrical protection through physical barriers is
currently not in FMVSS No. 305.)
i. Protection from direct contact: Protection from direct
contact of high voltage sources with protection degree IPXXB
required.
ii. Protection from indirect contact: The resistance between all
exposed conductive parts and electrical chassis is required to be
less than 0.1 ohms when there is a current flow of at least 0.2
A.\60\
---------------------------------------------------------------------------
\60\ GTR No. 13 considers this requirement to be met if visual
inspection indicates that conductive connection has been established
by welding. The minimum resistance requirement is only evaluated in
case of doubt.
---------------------------------------------------------------------------
c. Electrical isolation:
i. If the AC and DC high voltage sources are conductively
isolated from each other, then the minimum electrical isolation of a
high voltage source to the chassis is 500 ohms/volt for AC
components and 100 ohms/volt for DC components of the working
voltage.
ii. If AC and DC high voltage sources are conductively
connected, the minimum electrical isolation of AC and DC high
voltage sources must be--
500 ohms/volt of the working voltage, or
100 ohms/volt of the working voltage with the AC high
voltage sources meeting the physical protection requirements in (b)
or have no high voltage as specified in (a).
(FMVSS No. 305 does not distinguish AC and DC high voltage sources
that are conductively connected from those that are isolated. Thus, the
method above for complying with electrical isolation requirements when
AC and DC high voltage sources are connected post-crash (see c. ii.
above) is not now available in FMVSS No. 305.)
Proposal
This NPRM proposes to amend the isolation resistance compliance
option in FMVSS No. 305 to harmonize with GTR No. 13. We are proposing
to add an optional method of meeting post-crash electrical isolation
requirements for an AC high voltage source that is connected to a DC
high voltage source. In such condition, the required minimum electrical
isolation for the AC high voltage source is 100 ohms/volt provided the
AC high voltage source meets the post-crash physical barrier protection
requirements.
We are also proposing to add a physical barrier protection option
for post-crash electrical safety that includes requirements specifying
that:
i. High voltage sources must be enclosed in barriers that
prevent direct human contact with high voltage sources (IPXXB
protection level),
ii. Electrical protection barriers must be conductively
connected to the chassis with a resistance less than 0.1 ohms, and
the resistance between two simultaneously reachable exposed
conductive parts of electrical protection barriers that are less
than 2.5 meters of each other must be less than 0.2 ohms, and
iii. Voltage between a barrier and other exposed conductive
parts of the vehicle must be at a low voltage level that would not
cause electric shock (less than 60 VDC or 30 VAC).
Electrical Isolation Resistance Option
Currently, FMVSS No. 305's electrical isolation option requires
that vehicles with high voltage sources meet different isolation
requirements based on whether the vehicle is an AC or a DC high voltage
source. Electric powered vehicles are required to electrically isolate
AC and DC high voltage sources from the chassis with electrical
isolation no less than 500 ohms/volt, but the DC high voltage source
can have electrical isolation no less than 100 ohms/volt if
[[Page 12666]]
the DC high voltage source has an electrical isolation monitoring
system.
GTR No. 13 differs from FMVSS No. 305 by distinguishing between
situations where AC and DC high voltage are conductively isolated from
each other or are conductively connected. GTR No. 13 states that when
AC and DC high voltage sources are isolated from each other, the AC
high voltage sources need to maintain electrical isolation no less than
500 ohms/volt and DC sources need to maintain electrical isolation no
less than 100 ohms/volt. This is similar to FMVSS No. 305.\61\
---------------------------------------------------------------------------
\61\ We note that GTR No. 13 permits DC high voltage sources to
have 100 ohms/volt minimum electrical isolation without specifying
that the DC high voltage sources must be equipped with an electrical
isolation monitoring system. While this appears to differ from FMVSS
No. 305, we do not believe there is a practical difference. The only
vehicles needing to use FMVSS No. 305's 100 ohms/volt electrical
isolation compliance option for DC high voltage sources are fuel
cell vehicles. In this NPRM, the agency is proposing to require all
DC high voltage sources of fuel cell vehicles to be equipped with an
electrical isolation monitoring system. Therefore, while we propose
to adopt the post-crash electrical isolation requirements for DC
high voltage sources in GTR No. 13 into FMVSS No. 305 to further
harmonization efforts, we do not believe there would be an effect on
vehicle design or safety.
---------------------------------------------------------------------------
When the AC and DC sources are conductively connected, GTR No. 13
affords three different methods for these high voltage sources to
achieve compliance:
(1) All AC and DC sources maintain minimum electrical isolation of
500 ohms/volt (this is basically the approach of FMVSS No. 305);
(2) AC high voltage sources that are linked to a DC high voltage
source may have a minimum of 100 ohms/volt instead of 500 ohms/volt if
the AC high voltage source also has physical barrier protection from
direct and indirect contact of high voltage sources; \62\ or
---------------------------------------------------------------------------
\62\ FMVSS No. 305 does not distinguish when the AC and DC
sources are connected from when AC and DC sources are separated. The
standard specifies that all AC high voltage sources must have a
minimum electrical isolation of 500 ohms/volt. The condition
involving connected AC and DC high voltage sources is germane to the
Toyota petition.
---------------------------------------------------------------------------
(3) all AC and DC sources maintain a minimum isolation resistance
of 100 ohms/volt and all AC sources meet low-voltage requirements in
GTR No. 13.
Need for Amendment
After reviewing the Toyota petition and other information, NHTSA
understands petitioners' concern about FMVSS No. 305's electrical
isolation requirements for AC high voltage sources under the conditions
when the AC and DC bus are conductively connected. We tentatively
believe that an amendment is warranted to facilitate the manufacture of
fuel cell and other vehicles.
If FMVSS No. 305 were not amended, the electrical isolation for
fuel cell stacks would need to be 500 ohms/volt or greater to comply
with FMVSS No. 305, which may not be technically feasible.
Proposal for Electrical Isolation Option
In consideration of the above, NHTSA is proposing to add an option
that would permit an AC high voltage source that is connected to a DC
high voltage source post-crash to have electrical isolation no less
than 100 ohms/volt provided the high voltage source also meets physical
barrier protection requirements. Specifically, the electrical isolation
option for electrical safety in the proposal requires that the
electrical isolation of a high voltage source be greater than or equal
to one of the following:
(1) 500 ohms/volt for an AC high voltage source; or
(2) 100 ohms/volt for an AC high voltage source if it is
conductively connected to a DC high voltage source, but only if the AC
high voltage source meets the physical barrier protection requirements;
or
(3) 100 ohms/volt for a DC high voltage source.
NHTSA tentatively believes that adding this option into the
existing FMVSS No. 305 requirements essentially harmonizes with the
electrical isolation option in GTR No. 13. When an AC and DC high
voltage source are conductively connected, the electrical isolation
measured will be the same for both high voltage sources and
approximately equal to the lower electrical isolation measurement of
the two. Accordingly, the combined electrical isolation of conductively
connected AC and DC high voltage sources can be greater than or equal
to 500 ohm/volt only if the electrical isolation of each AC and DC high
voltage sources are greater than or equal to 500 ohms/volt. Therefore
the first option for electrical isolation in GTR No. 13 when an AC and
DC high voltage source are conductively connected is redundant to what
is already in FMVSS No. 305 since it is equivalent to the electrical
isolation requirement when the AC and DC high voltage sources are
conductively isolated from each other. The third option for electrical
isolation in GTR No. 13 is unnecessary because if an AC high voltage
source meets low voltage requirements, there is no need to meet the
electrical isolation requirements.
We note, however, that the physical barrier protection requirement
in the proposed regulatory language to accommodate a lower electrical
isolation level for a AC high voltage source that is conductively
connected to a DC high voltage source is not the same as that specified
in GTR No. 13. The physical barrier protection requirement is an option
each contracting party of the 1998 agreement may elect to adopt. As
explained in the following section, although our proposal in this
document chooses not to adopt the physical barrier option in GTR No. 13
per se, we are proposing to adopt a modified physical barrier option.
Based on the information from the Battelle research, the Alliance
petition, the Toyota petition and other sources, we tentatively believe
that our proposed physical barrier option will afford the compliance
flexibility that the manufacturers desire while providing a level of
safety that is more comparable to the other post-crash electric shock
compliance options.
Physical Barrier Protection
Need for Amendment
The Alliance petition for rulemaking requested updates to FMVSS No.
305 for facilitating the development and sale of not only HFCVs but
also 48 volt mild hybrid vehicles. Because 48 volt batteries are
considered low voltage, the 48 volt mild hybrid systems are designed
with conductive connection to the electric chassis and so are unable to
provide electrical isolation. While most parts of the 48 volt mild
hybrid system would be considered low voltage per the measurement to
the chassis, the voltage between different phases of the 3-phase AC
motor can be slightly greater than 30 VAC and so would be considered a
high voltage source.
The Alliance Petition
The agency has considered the information provided by the Alliance
and by Mercedes-Benz \63\ and tentatively concludes that without an
electrical protection barrier option, 48 volt mild hybrids will not be
a practical consideration for improving fuel economy. In the absence of
such an option, these systems will need to be electrically isolated
from the chassis and thereby result in higher mass, reduced fuel
economy, increased emissions, and higher consumer costs.
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\63\ We discussed the Mercedes-Benz information earlier in this
preamble, in the section describing the Alliance's petition for
rulemaking, supra. 48 V Systems--Powerful Innovative Technologies
for 2020 FC Targets, Mercedes-Benz, Daimler AG, June 2, 2015.
Available in the docket for this NPRM.
---------------------------------------------------------------------------
Regarding the Battelle study, we first begin by noting that we
agree with the Alliance's analysis that for electric
[[Page 12667]]
powered vehicles that meet the electrical isolation and physical
barrier protection requirement in GTR No. 13 during normal vehicle
operation, there is a very low likelihood that the various safety
critical scenarios identified in the Battelle report with electric
shock potential would occur. The scenarios would only be possible if
multiple failures of safety systems occurred, along with human contact
to very specific locations. Be that as it may, the Alliance petition
also suggested modifications to the electrical protection barrier
provisions in GTR No. 13, which it states provide the same level of
protection as the electrical isolation option for electrical safety in
FMVSS No. 305 along with protection from the safety critical scenarios
identified in the Battelle report.
The physical barrier protection option in the Alliance petition
specifies two optional methods of providing physical barrier protection
from direct and indirect contact of high voltage sources. The first
method (Option 1) requires an AC or DC high voltage source to have:
1. Direct contact protection degree IPXXB,
2. All exposed conductive parts of electrical protection barriers
are conductively connected to electrical chassis with resistance less
than 0.1 ohms, and
3. The electrical isolation between the high voltage source and the
electrical protection barrier enclosing it is greater than or equal to
0.05 ohms/VAC or 0.01 ohms/VDC.
The second method (Option 2) requires an AC or DC high voltage
source to have:
1. Direct contact protection degree IPXXB.
2. The voltage between the electrical protection barrier and other
exposed conductive parts is low voltage (30 VAC or 60 VDC).
Technical Analysis
The physical barrier protection provides electrical safety via
electrical protection barriers that are placed around high voltage
components to insure that there is no direct or indirect human contact
with live high voltage sources during normal vehicle operation or after
a vehicle crash. For protection against contact with live parts in
post-crash conditions, a test probe designed to simulate a small human
finger (12 mm) conforming to ISO 20653 ``Road vehicles--Degrees of
protection (IP-Code)--Protection of electrical equipment against
foreign objects, water, and access (IPXXB)'' is specified in GTR No.
13.\64\ The agency notes that protection against direct contact of high
voltage sources is currently not specified in FMVSS No. 305 and so
adding such a provision into FMVSS No. 305 would further enhance
protection from electric shock. The IPXXB finger probe is utilized in
other standards \65\ for protecting electrical maintenance personnel
from inadvertently contacting high voltage during servicing of
electrical equipment. Therefore, NHTSA tentatively believes protection
level using the simulated human finger probe (IPXXB) to prohibit
inadvertent contact by passengers and first responders with high
voltage components contained within protective enclosures is
appropriate.\66\
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\64\ IEC60529 Second edition 1989-11 + Am. 1 1999-11, EN60529,
``Degrees of protection provided by enclosures.''
\65\ For example, IEC 60479, ``Low voltage switchgear and
control gear assemblies,'' uses IPXXB level protection for
preventing contact with high voltage sources by maintenance
personnel. The voltage levels considered in IEC 60479 are similar to
those in automotive application.
\66\ The use of the IPXXB finger probe as opposed to the IPXXD
wire probe for evaluating direct contact protection after a crash
test is appropriate. The IPXXD is intended to evaluate contact with
high voltage sources inside the passenger or luggage compartment
during normal vehicle operation to ensure that body parts,
miscellaneous tools or other slender conductive items typically
encountered in a passenger or luggage compartment cannot penetrate
any gaps/seams in the protective enclosures and contact high voltage
components contained within.
---------------------------------------------------------------------------
NHTSA reviewed \67\ the Alliance's proposal for a post-crash
electrical protection barrier option for FMVSS No. 305 and confirmed
that the electric current Ib through the body (with minimum resistance
of 500 ohms) in Figure 9, supra, is less than or equal to 10 mA DC or
less than or equal to 2 mA AC under various scenarios, as long as the
three requirements for the Alliance-suggested Option 1 for post-crash
physical barrier protection are met. These are: 1. Direct contact
protection degree IPXXB, 2. all exposed conductive parts are
conductively connected to electrical chassis with resistance less than
0.1 ohms, and 3. the combined resistance of R1 and
R2 and the resistance of the conductive connection of the
electrical protection barrier to the chassis is greater than or equal
to 0.05 ohms/VAC or 0.01 ohms/VDC. When all three conditions in the
Option 1 physical barrier protection suggested by Alliance are met, the
agency's analysis showed that in the event of loss in electrical
isolation, the body current is limited to safe levels under the various
safety critical scenarios identified in the Battelle study. The
agency's analysis also confirmed that when the above conditions are
met, the voltage between barrier #1 and barrier #2 in Figure 9 is less
than or equal to 30 VAC or 60 VDC, as the Alliance noted.\68\
---------------------------------------------------------------------------
\67\ Supporting technical document in the docket of this NPRM.
\68\ For example, an analysis of the circuit in Figure 9 was
conducted using the following values for the components in the
circuit: Vb = 1000 VDC, bonding resistance bond #1 and bond #2 equal
to 0.1 ohm, R1 and R2 resistances equal to 20 ohms, and body
resistance equal to 500 ohms. This resulted in a combined resistance
of R1 and R2 and bonding resistance to chassis
of 10.05 ohms (or 0.01005 ohms/volt electrical isolation from the
chassis) and current through the body of 9.95 mA (<10 mA considered
as safe level of current). The analysis also showed that in this
example, the voltage between barrier #1 and barrier #2 is equal to
4.97 volt (<60 volt is considered to be low voltage). This is
further explained in the supporting technical document in the docket
of this NPRM.
---------------------------------------------------------------------------
The specification that the conductive connection between a
protection barrier and the chassis be less than 0.1 ohm provides
protection from electric shock by shunting any harmful electrical
currents through the vehicle chassis (rather than through a human
contacting the protection barrier) should any electrically charged
components lose isolation within the protective barrier. The 0.1 ohms
resistance level for electrical bonding (or conductive connection) is
well established in international standards both in and out of the
automotive industry (e.g. MIL_B_5087, NASA Technical Standard NSA-STD-
P023 ``Electrical Bonding for NASA Launch Vehicles, Payloads, and
Flight Equipment,'' ISO6469, ECE-R100, and IEC 60335-1 ``Household and
Similar Electrical Appliances'' Part 1: General Requirements). For
these reasons, NHTSA accepts that the resistance of the conductive
connection between the protective barrier and the electrical chassis be
less than 0.1 ohms.
However, the agency sought clarification on the indirect contact
protection requirement of Option 1 suggested by the Alliance, which
states that, ``The resistance between exposed conductive parts of the
electrical protection barrier(s) and the electrically conductive
chassis is less than 0.1 ohms where there is a current flow of at least
0.2 A.'' NHTSA noted that the maximum allowable resistance for the
electrical chassis was not specified and asked the Alliance how its
suggested Option 1 would afford adequate indirect contact protection
when exposed conductive parts of two electrical protection barriers
were contacted simultaneously instead of simultaneous contact of an
electrical protection barrier and the chassis.
[[Page 12668]]
In response,\69\ the Alliance acknowledged that the effective
resistance between two exposed conductive parts of the electrical
protection barriers was not well defined in its proposal. The
petitioner stated that in order to address the fact that there are no
resistance specifications for the electrically conductive chassis, it
recommends the addition of a performance requirement that limits the
maximum resistance between any two exposed conductive parts of the
electrical protection barriers to less than 0.2 ohms (which corresponds
to the requirement that maximum resistance between the protective
physical barrier and the electrical chassis is less than 0.1 ohms). The
Alliance also stated that the resistance measurements between any two
exposed conductive parts of the electrical protection barriers should
be limited to those that can be simultaneously contacted by a human.
The petitioner stated its belief that limiting the resistance
measurement to a distance of 2.5 meter \70\ would ensure that any
surfaces that can be simultaneously contacted by a human be subjected
to the proposed performance requirements. The petitioner noted that
such a distance limitation would significantly reduce the test burden
(number of test points) while maintaining the same level of safety.
Accordingly, the Alliance offered the following modification to the
text in SAE J1766 regarding indirect contact protection requirements
and requested that NHTSA seek comment on it in an NPRM.
---------------------------------------------------------------------------
\69\ Alliance's response to NHTSA's questions is in the docket
of this NPRM.
\70\ This distance specification was obtained from IEC 60364-4-
41. ``Low-voltage electrical installations--Part 4-4--Protection
against electric shock.'': Annex B (Obstacles and Placing out of
Reach), and ISO6469-3,:2011, ``Electrically propelled road
vehicles--Safety specifications--Part 3: Protection of persons
against electric shock.''
[Petitioner's suggested requirement] S5.3.4(2)--The bonding
resistance between any exposed conductive parts of the electrical
protection barriers and the vehicle's electrical chassis shall not
exceed 0.1 ohms. This requirement is deemed satisfied if the
galvanic connection has been made by welding and the weld is intact
after each of the specified crash tests. In addition, the bonding
resistance between any two simultaneously reachable exposed
conductive parts of the electrical protection barriers in a distance
of 2.5 meters shall not exceed 0.2 ohms. See C.2.1 for the
---------------------------------------------------------------------------
applicable test procedure.
The agency tentatively concludes that this modification responds to
NHTSA's concern about the lack of resistance specification for the
electrical chassis and the lack of low resistance specification between
two electrical protection barriers that can be contacted
simultaneously.\71\ However, we note that the requirement in the
suggested S5.3.4(2) above is for the resistance to be less than or
equal to 0.1 ohms and 0.2 ohms, while SAE J1766 January 2014 and GTR
No. 13 specify that the resistance be less than 0.1 ohms. For purposes
of harmonization with GTR No. 13, the agency proposes to use ``less
than 0.1 ohms'' and ``less than 0.2 ohms.''
---------------------------------------------------------------------------
\71\ NHTSA's analysis using 0.2 ohm resistance (instead of 0.1
ohm) between two protective barriers along with IPXXB protection and
isolation between high voltage source and the protective barrier of
0.01 ohm/VDC or 0.05 ohm/VAC results in safe current levels through
the body (10 mA DC or 2 mA AC). See details of NHTSA's analysis in
the supporting technical document in the docket of this NPRM.
---------------------------------------------------------------------------
The proposed modification suggested by the Alliance also states,
``This requirement is deemed satisfied if the galvanic connection has
been made by welding and the weld is intact after each of the specified
crash tests.'' We believe that such a method of assessing compliance of
indirect contact protection by visually inspecting the welding lacks
objectivity that is needed for FMVSS. Therefore, NHTSA proposes not
including this method for evaluating compliance. Instead, the agency
proposes to include the test procedure in GTR No. 13 and SAE J1766
January 2014 that determines the resistance between an electrical
protection barrier and the chassis and between two electrical
protection barriers by passing through a current of at least 0.2 A.
NHTSA seeks comment on its proposal not to include assessing compliance
of a conductive connection by means of visual inspection.
The agency's review had also indicated that the Alliance's proposed
Option 2 for physical barrier protection (direct contact protection
degree IPXXB and the voltage between barrier #1 and barrier #2 is less
than or equal to 30 VAC or 60 VDC) does not guarantee that the current
through the body is less than 10 mA DC and 2 mA AC for all
scenarios.\72\ NHTSA requested that the Alliance provide clarification
on this matter. The Alliance responded \73\ that FMVSS No. 305 already
recognizes these low voltage thresholds, both with respect to the
applicability of the standard and with respect to the electrical safety
provisions of the standard. The Alliance also noted that GTR No. 13 and
numerous other government regulations and industry standards recognize
these low voltage threshold levels for automotive applications.\74\ The
Alliance observed that for voltage below or equal to 30 VAC and 60 VDC,
the potential body current is below the let-go limit \75\ and below the
limit for electric shock with non-reversible harm. The Alliance stated
that it is for these reasons that voltage levels below 30 VAC and 60
VDC are designated worldwide as low voltage without safety concern.\76\
---------------------------------------------------------------------------
\72\ For example, an analysis of the circuit in Figure 9 was
conducted using the following values for the components in the
circuit: Vb = 1000 VDC, bonding resistance bond #1 and bond #2 equal
to 0.1 ohm, R1 and R2 resistances equal to 1.6 ohms, and body
resistance equal to 500 ohms. This resulted in a combined resistance
of R1 and R2 and bonding resistance to chassis
of 0.85 ohms (or 0.00085 ohms/volt electrical isolation from
chassis) and current through the body of 117 mA (>10 mA is
considered an unsafe level of current). The analysis also showed
that in this example, the voltage between barrier #1 and barrier #2
is equal to 58.52 volt (<60 volt is considered to be low voltage).
This is further explained in the supporting technical document in
the docket of this NPRM.
\73\ Alliance's response to NHTSA's questions is in the docket
of this NPRM.
\74\ Electrical safety requirements in Europe, Japan, and Korea
and SAE J1766 recognize voltage levels less than or equal to 30 VAC
or 60 VDC as low voltage.
\75\ Maximum value of touch current at which a person holding
electrodes can let go of the electrodes.
\76\ The Alliance also noted its belief that the indirect
contact scenarios identified in the Battelle study are extremely
rare and that in setting appropriate safety measures, the
probability of faults, probability of contact with live parts, and
the ratio of touch voltage and fault voltage needs to be considered.
---------------------------------------------------------------------------
NHTSA tentatively agrees with the clarification provided by the
Alliance that voltage levels at or lower than 30 VAC and 60 VDC are
already specified as low voltage in FMVSS No. 305 and at these voltage
levels, the potential body current is below the limit for electric
shock. Currently, the European Union, Japan, and Korea, permit
compliance for electrical safety using the electrical protection
barrier option in GTR No. 13 and NHTSA is not aware of any incidence of
electrical shock during normal operation and after a crash.
The Alliance suggested adopting Option 2 for physical barrier
protection rather than Option 1 because it is difficult to measure
electrical isolation between the high voltage source and exposed
conductive parts of its electrical protection barrier, which is needed
to assess compliance with Option 1.\77\ Additionally, the agency's
analysis confirms that of the Alliance's, that if the three conditions
of Option 1 are met, the two conditions of Option 2 would also be met
and in the event of loss of electrical isolation, the current through a
body contacting electrical protection barriers is within safe levels
[[Page 12669]]
(same level of safety as that afforded by post-crash electrical
isolation requirements).
---------------------------------------------------------------------------
\77\ The Alliance did not specify a test procedure to determine
electrical isolation between the high voltage source and its
electrical protection barrier.
---------------------------------------------------------------------------
NHTSA's Proposal for Physical Barrier Protection
In consideration of the above technical analysis, the agency is
proposing to combine Alliance's suggested Option 1 and Option 2
requirements for electrical protection barriers. Specifically, the
agency proposes the following requirements for an electrical protection
barrier of a high voltage source:
(1) Direct contact protection degree IPXXB,
(2) indirect contact protection (electrical protection barriers are
conductively connected to the chassis with resistance less than 0.1
ohms and resistance between two electrical protection barriers that are
accessible within 2.5 meters is less than 0.2 ohms), and
(3) low voltage of 30 VAC or 60VDC between the electrical
protection barrier and other exposed conductive parts.
The first two conditions are specified in GTR No. 13 and (1) and
(3) together is the same as Option 2 suggested by the Alliance. We
concur that there is merit to the third condition since FMVSS No. 305
already recognizes voltages less than or equal to 30 VAC and 60 VDC as
low voltage. Our technical analysis confirms that the proposed post-
crash physical barrier protection option (with the first two
requirements in GTR No. 13 and an additional third requirement that
electrical protection barriers be low voltage) affords the same level
of safety as the post-crash electrical isolation option currently in
FMVSS No. 305.
NHTSA seeks comment on the proposed inclusion of the physical
barrier protection option into FMVSS No. 305. NHTSA also seeks comment
on its proposed physical barrier protection requirements which combine
the requirements in GTR No. 13 and Option 2 in the Alliance petition.
The agency also seeks comment on the proposed test procedures for
assessing physical barrier protection.
Toyota's Request for Amending Post-Crash Test Procedure
In its December 23, 2013 petition for rulemaking, Toyota requests
that NHTSA amend S6.4 of FMVSS No. 305, which requires a vehicle to
satisfy all of the post-crash performance requirements ``after being
rotated on its longitudinal axis to each successive increment of 90
degrees. . . .'' Toyota recommends that the tests to evaluate
electrical isolation and physical barrier protection requirements be
performed after the vehicle is rotated a full 360 degrees. Toyota
states that the vehicle conditions related to these requirements do not
change at various increments of a rollover, and it would be
increasingly dangerous for laboratory personnel to conduct the
specified tests with the vehicle at other 90 degree increments.
NHTSA has evaluated Toyota's request and is denying it. NHTSA does
not agree with Toyota's assessment that the vehicle conditions related
to electrical safety requirements do not change at various increments
of rollover. Post-crash direct contact protection is assessed by first
opening, disassembling, or removing electrical protection barriers,
solid insulator, and connectors without the use of tools, and then the
IPXXB probe is used to determine if high voltage sources can be
contacted. This evaluation may yield different results for the
different attitudes of the vehicle. For example, high voltage sources
may be more accessible when the vehicle is rotated 90 degrees than when
upright. NHTSA is not aware of unreasonably dangerous conditions to
laboratory personnel in conducting the specified tests with the vehicle
at 90 degree increments. Toyota did not provide any supporting data to
substantiate its case. NHTSA seeks comment on this issue.
X. Rulemaking Analyses and Notices
Executive Order 12866 and DOT Regulatory Policies and Procedures
This rulemaking document was not reviewed by the Office of
Management and Budget under E.O. 12866. It is not considered to be
significant under E.O. 12866 or the Department's Regulatory Policies
and Procedures. The amendments proposed by this NPRM would have no
significant effect on the national economy, as the requirements are
already in voluntary industry standards and international standards
that current electric powered vehicles presently meet.
This NPRM proposes to update FMVSS No. 305 to incorporate the
electrical safety requirements in GTR No. 13. This proposal also
responds to petitions for rulemaking from Toyota and the Alliance to
facilitate the introduction of fuel cell vehicles and 48 volt mild
hybrid technologies into the vehicle fleet. The proposal adds
electrical safety requirements in GTR No. 13 that involves electrical
isolation and direct and indirect contact protection of high voltage
sources to prevent electric shock during normal operation of electric
powered vehicles. Today's proposal also provides an additional optional
method of meeting post-crash electrical safety requirements in FMVSS
No. 305 that involves physical barriers of high voltage sources to
prevent electric shock due to direct and indirect contact with live
parts. Since there is widespread conformance with the requirements that
would apply to existing vehicles, we anticipate no costs or benefits
associated with this rulemaking.
Regulatory Flexibility Act
NHTSA has considered the effects of this NPRM under the Regulatory
Flexibility Act (5 U.S.C. 601 et seq., as amended by the Small Business
Regulatory Enforcement Fairness Act (SBREFA) of 1996). I certify that
this NPRM would not have a significant economic impact on a substantial
number of small entities. Any small manufacturers that might be
affected by this NPRM are already subject to the requirements of FMVSS
No. 305. Further, the agency believes the testing associated with the
requirements added by this NPRM are not substantial and to some extent
are already being voluntarily borne by the manufacturers pursuant to
SAE J1766. Therefore, there will be only a minor economic impact.
National Environmental Policy Act
NHTSA has analyzed this rulemaking action for the purposes of the
National Environmental Policy Act. The agency has determined that
implementation of this action will not have any significant impact on
the quality of the human environment.
Executive Order 13132 (Federalism)
NHTSA has examined today's NPRM pursuant to Executive Order 13132
(64 FR 43255; Aug. 10, 1999) and concluded that no additional
consultation with States, local governments, or their representatives
is mandated beyond the rulemaking process. The agency has concluded
that the proposal does not have sufficient federalism implications to
warrant consultation with State and local officials or the preparation
of a federalism summary impact statement. The proposal does not have
``substantial direct effects on the States, on the relationship between
the national government and the States, or on the distribution of power
and responsibilities among the various levels of government.''
NHTSA rules can have preemptive effect in two ways. First, the
National Traffic and Motor Vehicle Safety Act contains an express
preemption provision:
When a motor vehicle safety standard is in effect under this
chapter, a State or a political subdivision of a State may
[[Page 12670]]
prescribe or continue in effect a standard applicable to the same
aspect of performance of a motor vehicle or motor vehicle equipment
only if the standard is identical to the standard prescribed under this
chapter. 49 U.S.C. 30103(b)(1).
It is this statutory command that preempts any non-identical State
legislative and administrative law \78\ addressing the same aspect of
performance, not today's rulemaking, so consultation would be
inappropriate.
---------------------------------------------------------------------------
\78\ The issue of potential preemption of state tort law is
addressed in the immediately following paragraph discussing implied
preemption.
---------------------------------------------------------------------------
Second, the Supreme Court has recognized the possibility, in some
instances, of implied preemption of State requirements imposed on motor
vehicle manufacturers, including sanctions imposed by State tort law.
That possibility is dependent upon there being an actual conflict
between a FMVSS and the State requirement. If and when such a conflict
exists, the Supremacy Clause of the Constitution makes the State
requirements unenforceable. See Geier v. American Honda Motor Co., 529
U.S. 861 (2000), finding implied preemption of state tort law on the
basis of a conflict discerned by the court,\79\ not on the basis of an
intent to preempt asserted by the agency itself.
---------------------------------------------------------------------------
\79\ The conflict was discerned based upon the nature (e.g., the
language and structure of the regulatory text) and the safety-
related objectives of FMVSS requirements in question and the impact
of the State requirements on those objectives.
---------------------------------------------------------------------------
NHTSA has considered the nature (e.g., the language and structure
of the regulatory text) and objectives of today's NPRM and does not
discern any existing State requirements that conflict with the rule or
the potential for any future State requirements that might conflict
with it. Without any conflict, there could not be any implied
preemption of state law, including state tort law.
Executive Order 12988 (Civil Justice Reform)
With respect to the review of the promulgation of a new regulation,
section 3(b) of Executive Order 12988, ``Civil Justice Reform'' (61 FR
4729; Feb. 7, 1996), requires that Executive agencies make every
reasonable effort to ensure that the regulation: (1) Clearly specifies
the preemptive effect; (2) clearly specifies the effect on existing
Federal law or regulation; (3) provides a clear legal standard for
affected conduct, while promoting simplification and burden reduction;
(4) clearly specifies the retroactive effect, if any; (5) specifies
whether administrative proceedings are to be required before parties
file suit in court; (6) adequately defines key terms; and (7) addresses
other important issues affecting clarity and general draftsmanship
under any guidelines issued by the Attorney General. This document is
consistent with that requirement.
Pursuant to this Order, NHTSA notes as follows. The issue of
preemption is discussed above. NHTSA notes further that there is no
requirement that individuals submit a petition for reconsideration or
pursue other administrative proceedings before they may file suit in
court.
Privacy Act
Please note that anyone is able to search the electronic form of
all comments received into any of our dockets by the name of the
individual submitting the comment (or signing the comment, if submitted
on behalf of an association, business, labor union, etc.). You may
review DOT's complete Privacy Act Statement in the Federal Register
published on April 11, 2000 (65 FR 19477-78), or online at https://www.dot.gov/privacy.html.
Paperwork Reduction Act
Under the Paperwork Reduction Act of 1995 (PRA), a person is not
required to respond to a collection of information by a Federal agency
unless the collection displays a valid OMB control number. There are no
information collection requirements associated with this NPRM.
National Technology Transfer and Advancement Act
Section 12(d) of the National Technology Transfer and Advancement
Act of 1995 (NTTAA), Public Law 104-113, as amended by Public Law 107-
107 (15 U.S.C. 272), directs the agency to evaluate and use voluntary
consensus standards in its regulatory activities unless doing so would
be inconsistent with applicable law or is otherwise impractical.
Voluntary consensus standards are technical standards (e.g., materials
specifications, test methods, sampling procedures, and business
practices) that are developed or adopted by voluntary consensus
standards bodies, such as the Society of Automotive Engineers (SAE).
The NTTAA directs us to provide Congress (through OMB) with
explanations when the agency decides not to use available and
applicable voluntary consensus standards. The NTTAA does not apply to
symbols.
FMVSS No. 305 has historically drawn largely from SAE J1766, and
does so again for this current rulemaking, which proposes revisions to
FMVSS No. 305 to facilitate the development of fuel cell and 48 volt
mild hybrid technologies. It is based on GTR No. 13 and the latest
version of SAE J1766 January 2014.
Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandates Reform Act of 1995 (UMRA),
Public Law 104-4, requires Federal agencies to prepare a written
assessment of the costs, benefits, and other effects of proposed or
final rules that include a Federal mandate likely to result in the
expenditure by State, local, or tribal governments, in the aggregate,
or by the private sector, of more than $100 million annually (adjusted
for inflation with base year of 1995). Adjusting this amount by the
implicit gross domestic product price deflator for the year 2013
results in $142 million (106.733/75.324 = 1.42). This NPRM would not
result in a cost of $142 million or more to either State, local, or
tribal governments, in the aggregate, or the private sector. Thus, this
NPRM is not subject to the requirements of sections 202 of the UMRA.
Executive Order 13609 (Promoting Regulatory Cooperation)
The policy statement in section 1 of Executive Order 13609
provides, in part: The regulatory approaches taken by foreign
governments may differ from those taken by U.S. regulatory agencies to
address similar issues. In some cases, the differences between the
regulatory approaches of U.S. agencies and those of their foreign
counterparts might not be necessary and might impair the ability of
American businesses to export and compete internationally. In meeting
shared challenges involving health, safety, labor, security,
environmental, and other issues, international regulatory cooperation
can identify approaches that are at least as protective as those that
are or would be adopted in the absence of such cooperation.
International regulatory cooperation can also reduce, eliminate, or
prevent unnecessary differences in regulatory requirements.
The agency participated in the development of GTR No. 13 to
harmonize the standards of fuel cell vehicles. As a signatory member,
NHTSA is proposing to incorporate electrical safety requirements and
options specified in GTR No. 13 into FMVSS No. 305.
Regulation Identifier Number
The Department of Transportation assigns a regulation identifier
number (RIN) to each regulatory action listed in the Unified Agenda of
Federal
[[Page 12671]]
Regulations. The Regulatory Information Service Center publishes the
Unified Agenda in April and October of each year. You may use the RIN
contained in the heading at the beginning of this document to find this
action in the Unified Agenda.
Plain Language
Executive Order 12866 requires each agency to write all rules in
plain language. Application of the principles of plain language
includes consideration of the following questions:
Have we organized the material to suit the public's needs?
Are the requirements in the rule clearly stated?
Does the rule contain technical language or jargon that
isn't clear?
Would a different format (grouping and order of sections,
use of headings, paragraphing) make the rule easier to understand?
Would more (but shorter) sections be better?
Could we improve clarity by adding tables, lists, or
diagrams?
What else could we do to make the rule easier to
understand?
If you have any responses to these questions, please write to us
with your views.
XI. Public Participation
How do I prepare and submit comments?
Your comments must be written and in English. To ensure that your
comments are correctly filed in the Docket, please include the docket
number of this document in your comments.
Your comments must not be more than 15 pages long. (49 CFR 553.21).
We established this limit to encourage you to write your primary
comments in a concise fashion. However, you may attach necessary
additional documents to your comments. There is no limit on the length
of the attachments.
Comments may also be submitted to the docket electronically by
logging onto the Docket Management System Web site at https://www.regulations.gov. Follow the online instructions for submitting
comments.
Please note that pursuant to the Data Quality Act, in order for
substantive data to be relied upon and used by the agency, it must meet
the information quality standards set forth in the OMB and DOT Data
Quality Act guidelines. Accordingly, we encourage you to consult the
guidelines in preparing your comments. OMB's guidelines may be accessed
at https://www.whitehouse.gov/omb/fedreg/reproducible.html.
How can I be sure that my comments were received?
If you wish Docket Management to notify you upon its receipt of
your comments, enclose a self-addressed, stamped postcard in the
envelope containing your comments. Upon receiving your comments, Docket
Management will return the postcard by mail.
How do I submit confidential business information?
If you wish to submit any information under a claim of
confidentiality, you should submit three copies of your complete
submission, including the information you claim to be confidential
business information, to the Chief Counsel, NHTSA, at the address given
above under FOR FURTHER INFORMATION CONTACT. In addition, you should
submit a copy, from which you have deleted the claimed confidential
business information, to the docket at the address given above under
ADDRESSES. When you send a comment containing information claimed to be
confidential business information, you should include a cover letter
setting forth the information specified in our confidential business
information regulation. (49 CFR part 512)
Will the agency consider late comments?
We will consider all comments received before the close of business
on the comment closing date indicated above under DATES. To the extent
possible, we will also consider comments that the docket receives after
that date. If the docket receives a comment too late for us to consider
in developing a final rule (assuming that one is issued), we will
consider that comment as an informal suggestion for future rulemaking
action.
How can I read the comments submitted by other people?
You may read the comments received by the docket at the address
given above under ADDRESSES. The hours of the docket are indicated
above in the same location. You may also see the comments on the
Internet. To read the comments on the Internet, go to https://www.regulations.gov. Follow the online instructions for accessing the
dockets.
Please note that even after the comment closing date, we will
continue to file relevant information in the docket as it becomes
available. Further, some people may submit late comments. Accordingly,
we recommend that you periodically check the Docket for new material.
You can arrange with the docket to be notified when others file
comments in the docket. See www.regulations.gov for more information.
List of Subjects in 49 CFR Part 571
Imports, Motor vehicles, Motor vehicle safety.
In consideration of the foregoing, NHTSA proposes to amend 49 CFR
part 571 as follows:
PART 571--FEDERAL MOTOR VEHICLE SAFETY STANDARDS
0
1. The authority citation for part 571 continues to read as follows:
Authority: 49 U.S.C. 322, 30111, 30115, 30117, and 30166;
delegation of authority at 49 CFR 1.95.
0
2. In Sec. 571.305:
0
a. Revise S1 and S2;
0
b. Under S4:
0
i. Add in alphabetical order definitions for ``Charge connector'',
``Direct contact'', ``Electrical protection barrier'', ``Exposed
conductive part'', ``External electric power supply'', ``Fuel cell
system'', ``Indirect contact'', ``Live part'', ``Luggage compartment'',
``Passenger compartment'', and ``Possible active driving mode'';
0
ii. Revise the definition of ``Propulsion system''; and
0
iii. Add in alphabetical order definitions for ``Protection degree
IPXXB'', ``Protection degree IPXXD'', ``Service disconnect'', and
``Vehicle charge inlet'';
0
c. Revise S5.3 and S5.4; and
0
d. Add S5.4.1, S5.4.1.1, S5.4.1.1.1, S5.4.1.2, S5.4.1.3, S5.4.1.4,
S5.4.2, S5.4.2.1, S5.4.2.2, S5.4.3, S5.4.3.1, S5.4.3.2, S5.4.3.3,
S5.4.4, S5.4.5, S5.4.6, S5.4.6.1, S5.4.6.2, S5.4.6.3, S9, S9.1, S9.2,
S9.3, and figures 6, 7a, 7b, and 8.
The revisions and additions read as follows:
Sec. 571.305 Standard No. 305; Electric-powered vehicles: electrolyte
spillage and electrical shock protection.
S1. Scope. This standard specifies requirements for limitation of
electrolyte spillage and retention of electric energy storage/
conversion devices during and after a crash, and protection from
harmful electric shock during and after a crash and during normal
vehicle operation.
S2. Purpose. The purpose of this standard is to reduce deaths and
injuries during and after a crash that occur because of electrolyte
spillage from electric energy storage devices, intrusion of electric
energy storage/conversion devices into the occupant compartment, and
electrical shock, and to reduce deaths and injuries during
[[Page 12672]]
normal vehicle operation that occur because of electric shock.
* * * * *
S4. Definitions.
* * * * *
Charge connector is a conductive device that, by insertion into a
vehicle charge inlet, establishes an electrical connection of the
vehicle to the external electric power supply for the purpose of
transferring energy and exchanging information.
Direct contact is the contact of persons with high voltage live
parts.
* * * * *
Electrical protection barrier is the part providing protection
against direct contact with live parts from any direction of access.
Exposed conductive part is the conductive part that can be touched
under the provisions of the IPXXB protection degree and becomes
electrically energized under isolation failure conditions. This
includes parts under a cover that can be removed without using tools.
External electric power supply is a power supply external to the
vehicle that provides electric power to charge the propulsion battery
in the vehicle.
Fuel cell system is a system containing the fuel cell stack(s), air
processing system, fuel flow control system, exhaust system, thermal
management system, and water management system.
* * * * *
Indirect contact is the contact of persons with exposed conductive
parts.
Live part is a conductive part of the vehicle that is electrically
energized under normal vehicle operation.
Luggage compartment is the space in the vehicle for luggage
accommodation, separated from the passenger compartment by the front or
rear bulkhead and bounded by a roof, hood, floor, and side walls, as
well as by the electrical barrier and enclosure provided for protecting
the power train from direct contact with live parts.
Passenger compartment is the space for occupant accommodation that
is bounded by the roof, floor, side walls, doors, outside glazing,
front bulkhead and rear bulkhead or rear gate, as well as electrical
barriers and enclosures provided for protecting the occupants from
direct contact with live parts.
Possible active driving mode is the vehicle mode when application
of pressure to the accelerator pedal (or activation of an equivalent
control) or release of the brake system causes the electric power train
to move the vehicle.
Propulsion system means an assembly of electric or electro-
mechanical components or circuits that propel the vehicle using the
energy that is supplied by a high voltage source. This includes, but is
not limited to, electric motors, inverters/converters, and electronic
controllers.
Protection degree IPXXB is protection from contact with high
voltage live parts. It is tested by probing electrical protection
barriers or enclosures with the jointed test finger probe, IPXXB, in
Figure 7b.
Protection degree IPXXD is protection from contact with high
voltage live parts. It is tested by probing electrical protection
barriers or enclosures with the test wire probe, IPXXD, in Figure 7a.
Service disconnect is the device for deactivation of an electrical
circuit when conducting checks and services of the vehicle electrical
propulsion system.
* * * * *
Vehicle charge inlet is the device on the electric vehicle into
which the charge connector is inserted for the purpose of transferring
energy and exchanging information from an external electric power
supply.
* * * * *
S5.3 Electrical safety. After each test specified in S6 of this
standard, each high voltage source in a vehicle must meet the
electrical isolation requirements of paragraph S5.3(a) of this section,
the voltage level requirements of paragraph S5.3(b) of this section, or
the physical barrier protection requirements of paragraph S5.3(c) of
this section.
(a) The electrical isolation of the high voltage source, determined
in accordance with the procedure specified in S7.6 of this section,
must be greater than or equal to one of the following:
(1) 500 ohms/volt for an AC high voltage source; or
(2) 100 ohms/volt for an AC high voltage source if it is
conductively connected to a DC high voltage source, but only if the AC
high voltage source meets the physical barrier protection requirements
specified in paragraph S5.3(c) of this section; or
(3) 100 ohms/volt for a DC high voltage source.
(b) The voltages V1, V2, and Vb of the high voltage source,
measured according to the procedure specified in S7.7 of this section,
must be less than or equal to 30 VAC for AC components or 60 VDC for DC
components.
(c) Protection against electric shock by direct and indirect
contact (physical barrier protection) shall be demonstrated by meeting
the following three conditions:
(1) The high voltage source (AC or DC) meets the protection degree
IPXXB when tested under the procedure specified in S9.1 of this section
using the IPXXB test probe shown in Figures 7a and 7b to this section;
(2) The resistance between exposed conductive parts of the
electrical protection barriers and the electrical chassis is less than
0.1 ohms when tested under the procedures specified in S9.2 of this
section. In addition, the resistance between any two simultaneously
reachable exposed conductive parts of the electrical protection
barriers that are less than 2.5 meters from each other is less than 0.2
ohms when tested under the procedures specified in S9.2 of this
section; and
(3) The voltages between the electrical protection barrier
enclosing the high voltage source and other exposed conductive parts
are less than or equal to 30 VAC or 60 VDC as measured in accordance
with S9.3 of this section.
S5.4 Electrical safety during normal vehicle operation.
S5.4.1 Protection against direct contact.
S5.4.1.1 Marking. The symbol shown in Figure 6 to this section
shall be visible on or near electric energy storage/conversion devices.
The symbol in Figure 6 to this section shall also be visible on
electrical protection barriers which, when removed, expose live parts
of high voltage sources. The symbol shall be yellow and the bordering
and the arrow shall be black.
S5.4.1.1.1 The marking is not required for electrical protection
barriers that cannot be physically accessed, opened, or removed without
the use of tools.
S5.4.1.2 High voltage cables. Cables for high voltage sources which
are not located within enclosures shall be identified by having an
outer covering with the color orange.
S5.4.1.3 Service disconnect. For a service disconnect which can be
opened, disassembled, or removed without tools, protection degree IPXXB
shall be provided when tested under procedures specified in S9.1 of
this section using the IPXXB test probe shown in Figures 7a and 7b to
this section.
S5.4.1.4 Protection degree of high voltage sources and live parts.
(a) Protection degree IPXXD shall be provided for live parts and
high voltage sources inside the passenger or luggage compartment when
tested under procedures specified in S9.1 of this section using the
IPXXD test probe shown in Figure 7a to this section.
(b) Protection degree IPXXB shall be provided for live parts and
high voltage sources in areas other than the passenger or luggage
compartment when
[[Page 12673]]
tested under procedures specified in S9.1 of this section using the
IPXXB test probe shown in Figures 7a and 7b to this section.
S5.4.2 Protection against indirect contact.
S5.4.2.1 The resistance between all exposed conductive parts and
the electrical chassis shall be less than 0.1 ohms when tested under
the procedures specified in S9.2 of this section.
S5.4.2.2 The resistance between any two simultaneously reachable
exposed conductive parts of the electrical protection barriers that are
less than 2.5 meters from each other shall not exceed 0.2 ohms when
tested under the procedures specified in S9.2 of this section.
S5.4.3 Electrical isolation.
S5.4.3.1 Electrical isolation of AC and DC high voltage sources.
The electrical isolation of a high voltage source, determined in
accordance with the procedure specified in S7.6 of this section must be
greater than or equal to one of the following:
(a) 500 ohms/volt for an AC high voltage source;
(b) 100 ohms/volt for an AC high voltage source if it is
conductively connected to a DC high voltage source, but only if the AC
high voltage source meets the requirements for protection against
direct contact in S5.4.1.4 of this section and the protection from
indirect contact in S5.4.2 of this section; or
(c) 100 ohms/volt for a DC high voltage source.
S5.4.3.2 Exclusion of high voltage sources from electrical
isolation requirements. A high voltage source that is conductively
connected to an electric energy storage device which is conductively
connected to the electrical chassis and has a working voltage less than
or equal to 60 VDC, is not required to meet the electrical isolation
requirements in S5.4.3.1 of this section during normal vehicle
operating conditions if the voltage between the high voltage source and
the electrical chassis is less than or equal to 30 VAC or 60 VDC.
S5.4.3.3 Isolation resistance of high voltage sources for charging
the electric energy storage device. For motor vehicles with an electric
energy storage device that can be charged through a conductive
connection with the grounded external electric power supply, the
isolation resistance between the electrical chassis and the vehicle
charge inlet and each high voltage source conductively connected to the
vehicle charge inlet during charging of the electric energy storage
device shall be a minimum of one million ohms when the charge connector
is disconnected. The isolation resistance is determined in accordance
with the procedure specified in S7.6 of this section.
S5.4.4 Electrical isolation monitoring. Each DC high voltage
sources of vehicles with a fuel cell system shall be monitored by an
electrical isolation monitoring system that displays a warning for loss
of isolation when tested according to S8 of this section. The system
must monitor its own readiness and the warning display must be visible
to the driver seated in the driver's designated seating position.
S5.4.5 Electric shock protection during charging. For motor
vehicles with an electric energy storage device that can be charged
through a conductive connection with a grounded external electric power
supply, a device to enable conductive connection of the electrical
chassis to the earth ground shall be provided. This device shall enable
connection to the earth ground before exterior voltage is applied to
the vehicle and retain the connection until after the exterior voltage
is removed from the vehicle.
S5.4.6 Mitigating driver error.
S5.4.6.1 Indicator of possible active driving mode at start up. At
least a momentary indication shall be given to the driver when the
vehicle is in possible active driving mode. This requirement does not
apply under conditions where an internal combustion engine provides
directly or indirectly the vehicle's propulsion power upon start up.
S5.4.6.2 Indicator of possible active driving mode when leaving the
vehicle. When leaving the vehicle, the driver shall be informed by an
audible or visual signal if the vehicle is still in the possible active
driving mode.
S5.4.6.3 Prevent drive-away during charging. If the on-board
electric energy storage device can be externally charged, vehicle
movement by its own propulsion system shall not be possible as long as
the charge connector of the external electric power supply is
physically connected to the vehicle charge inlet.
* * * * *
S9 Test methods for physical barrier protection from electric shock
due to direct and indirect contact with high voltage sources.
S9.1 Test method to evaluate protection from direct contact with
high voltage sources.
(a) Any parts surrounding the high voltage components are opened,
disassembled, or removed without the use of tools.
(b) The selected access probe is inserted into any gaps or openings
of the electrical protection barrier with a test force of 10 N 1 N with the IPXXB probe or 1 to 2 N with the IPXXD probe. If
partial or full penetration into the physical barrier occurs, the probe
shall be placed as follows: Starting from the straight position, both
joints of the test finger are rotated progressively through an angle of
up to 90 degrees with respect to the axis of the adjoining section of
the test finger and are placed in every possible position.
(c) A low voltage supply (of not less than 40 V and not more than
50 V) in series with a suitable lamp may be connected between the
access probe and any high voltage live parts inside the physical
barrier to indicate whether live parts were contacted.
(d) A mirror or fiberscope may be used to inspect whether the
access probe touches high voltage parts inside the physical barrier.
S9.2 Test method to evaluate protection against indirect contact
with high voltage sources.
(a) Test method using a resistance tester. The resistance tester is
connected to the measuring points (the electrical chassis and any
exposed conductive part of the vehicle or any two exposed conductive
parts that are less than 2.5 meters from each other), and the
resistance is measured using a resistance tester that can measure
current levels of at least 0.1 Amperes with a resolution of 0.01 ohms
or less.
(b) Test method using a DC power supply, voltmeter and ammeter.
(1) Connect the DC power supply, voltmeter and ammeter to the
measuring points (the electrical chassis and any exposed conductive
part or any two exposed conductive parts that are less than 2.5 meters
from each other) as shown in Figure 8 to this section.
(2) Adjust the voltage of the DC power supply so that the current
flow becomes more than 0.2 Amperes.
(3) Measure the current I and the voltage V shown in Figure 8 to
this section.
(4) Calculate the resistance R according to the formula, R=V/I.
S9.3 Test method to determine voltage between electrical protection
barrier and exposed conductive parts, including electrical chassis, of
the vehicle.
(a) Connect the DC power supply and voltmeter to the measuring
points (exposed conductive part of an electrical protection barrier and
the electrical chassis or any other exposed conductive part of the
vehicle).
(b) Measure the voltage.
[[Page 12674]]
(c) After completing the voltage measurements for all electrical
protection barriers, the voltage differences between all exposed
conductive parts of the protective barriers shall be calculated.
* * * * *
BILLING CODE 4910-59-P
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Raymond R. Posten,
Associate Administrator for Rulemaking.
[FR Doc. 2016-05187 Filed 3-9-16; 8:45 am]
BILLING CODE 4910-59-C