Guideline for the safe storage of lithium-containing energy carriers
PGS 37-2 has been definitively established and clarifies when the guideline for the storage of lithium-containing energy carriers applies. Discover what this means for your organization and the expected inclusion in the Bal as of July 1, 2027.
PGS 37-2:2023 Guideline for the safe storage of lithium-containing energy carriers
In December 2023, the final version of PGS 37-2 was adopted by the Administrative Environmental Council. The content of this guideline is therefore established. PGS 37-2 contains regulations for the safe storage of lithium-containing energy carriers, such as lithium-ion batteries, accumulators, and vehicles with integrated battery systems.
The guideline currently does not have direct legal status through the Environmental Activities Decree. The government is working on the inclusion of PGS 37-2 in the Decree. Due to the complexity of the subject matter, the guideline is being further developed in conjunction with the regulations, with expected legal anchoring as of July 1, 2027. This schedule may still change.
Until the inclusion in the Decree is formally realized, PGS 37-2 can certainly play a role in permitting and supervision. Competent authorities can apply the guideline via the duty of care, customized regulations, or as justification for permit conditions. Organizations are therefore wise to already assess to what extent they comply with the requirements of PGS 37-2.
PGS 37-2 applicable or not
In practice, there was frequent discussion about when an energy carrier does or does not fall under PGS 37-2. Therefore, in the final version, a decision tree has been included in paragraph 1.2.1 to help determine the applicability of the guideline.
When this decision tree is used in combination with the established lower limits, it becomes clear whether or not storage is involved within the meaning of PGS 37-2. This limits the room for interpretation and enables organizations to better substantiate whether the guideline applies to their situation.
For the designation of the so-called typicals, a clear flowchart has been included in Annex H. With the help of this flowchart, it can be determined which type of energy carrier is applicable. This is important for determining the correct safety measures and provisions.
With these additions, PGS 37-2 has been significantly clarified compared to previous draft versions.
Scope of application and lower limits
PGS 37-2 applies to the storage of various categories of lithium-containing energy carriers. Distinctions are made based on, among other things, the type of energy carrier, weight, and condition of the battery, such as new, used, or defective.
The lower limits play an important role in determining applicability. In the final version, the lower limits for defective or damaged energy carriers have been particularly tightened. This has consequences for organizations dealing with return flows, temporary storage, or storage after incidents.
Because damaged batteries pose an increased risk, including the danger of fire or thermal runaway, the guideline sets additional requirements for storage facilities and control measures in these cases.
Relationship with PGS 37-1
PGS 37-2 concerns the storage of lithium-containing energy carriers. For energy storage systems such as large-scale battery installations, PGS 37-1 applies. In situations where both storage and use of battery systems take place, it is important to carefully assess which guideline is applicable.
What does this mean for organizations
Although the legal incorporation into the Bal is not expected to take place until July 1, 2027, the content of PGS 37-2 is final and is already being applied in practice. Organizations that store lithium-containing energy carriers are advised to assess their situation using the decision tree, the lower limits, and the relevant provisions from the guideline.
A timely assessment prevents discussion during permit issuance and supervision and reduces the risk of additional measures at a later stage.
