Written evidence from the British Occupational Hygiene Society (BEV0048)

Evidence by the British Occupational Hygiene Society to Business, Energy and Industrial Strategy Committee

Who are we?

  1. The British Occupational Hygiene Society is a leading scientific charity in the context of health protection in industry and beyond. We are the professional body for scientists designing, implementing and assuring controls of hazards to health in the workplace. Our membership comprise some of the worlds leading experts in the control of health risk in processes involved in the manufacture of batteries.

Why are we providing evidence?

  1. The evidence provided by BOHS is to inform the scientific understanding of the Committee:

a)      of the need for workforce expertise in the management of health risks involved in the production of EV batteries;

b)      the need for appropriate proportionate and effective guidance and regulation by the Health and Safety Executive of this high risk activity;

c)      to understand the challenges of effective management of health risk in high toxicity proprietary processes;

d)      to understand the cancer burden likely to be associated with battery manufacture in the absence of effective control;

e)      to understand the health and social care burden associated with battery manufacture in absence of effective control.

  1. There has been significant coverage of the challenges of producing safe batteries to scale, highlighted by the experience in Texas of Panasonic’s Gigafactory 1. The lack of a sufficiently trained and experienced workforce has been highlighted as a significant issue leading to the potential for unsafe batteries when reaching the market. This includes the expertise required to manage not only the safety of workers, but their health and the risks of further environmental damage and contamination.

What are the risks?

  1. Battery manufacture is neither inherently green, healthy or easy. The processes and components involved in the creation of high energy, high density modern batteries demand the use of volumes and types of substances which are extremely hazardous to human health (and consequently also to other forms of life and the environment. While they are an essential tool for the reduction in carbon footprints, they involve a supply chain which exposes workers to extreme hazards and high risk of long-term and serious health consequences from the point of extraction through to the point of recycling and disposal.
  2. The Committee will doubtless be aware of the risk of dangers including battery cell openings leading to toxic gasses (including hydrofluoric acid), consequent short circuits and unextinguishable, self-fuelling fires. However, in the manufacturing processes, these risks are escalated, while the substances used in manufacture are themselves highly toxic.

What do we know and what don’t we know?

  1. Making batteries safer indicates the need for skilled expertise. Automated welding is associated with battery thermal stress, as well as an increased failure rate “on the road.” However, manual welding requires careful management as welders are already in one of the highest risk categories for respiratory cancers and respiratory problems, as are those exposed to fumes. Escapes resulting in harmful exposures were a significant feature of the manufacture of batteries in South Korea in recent years. 
  2. Traditional battery manufacturing came with known hazards to health – most particularly lead. However, in the manufacture of EV batteries, there are more uncertainties, arising from proprietary commercially confidential processes. This places challenges on regulators to control hazards to health through generic substance controls, such as occupational exposure limits. Recent decisions by the HSE to leave occupational exposure limits for many substances utilised in ECV battery manufacture potentially risk the industry underestimating the cancer burden they will be bequeathing their workforce and the long-term impact on our NHS, where much of the economic burden of long latency occupational disease currently falls.

What are the things we need to guard against?

  1. Carcinogenic compounds include nickel, arsenic and cobalt compounds (all listed by ECHA for lower occupational exposure levels in the workplace, as a result of International Agency for Research on Cancer recommendations), as well as copper and propylene oxide. As well as being carcinogens, these substances used in EV battery manufacture, together with chemicals such as dimethoxyethane are also highly toxic.
  2. Ionic Lithium exposure is most likely to occur in the manufacture of cells (either from the electrolyte salt or the electrode manufacture) and has acute toxicity effects and long-term central nervous system effects. There is a further risk of exposure of workers if the cell fails after assembly. There are currently no substantive exposure limit values for exposure to ionic lithium in the UK.
  3. Negative electrode manufacturing processes may also contain boron or phosphorous, both of which present significant hazard to human health. Whether both or either are used is likely to be proprietary information.
  4. Manganese is likely to be used in manufacture and chronic exposure is associated with nervous system damage. Nickel is a critical metal in manufacture and as well as dermal, respiratory and other effects is a carcinogen whose occupational exposure limit has been recommended for reduction in Europe but has not had a corresponding reduction in the UK.
  5. In addition, a cocktail of reprotoxic, carcinogenic and toxic substances are used for electolytes, including hexoflouroasrenate, lithium hexafluoroborate and hexafluorophosphate. Long-term health effects range from those which are reprotoxic through to anorexia, anemia and respiratory failure. These substances can also be present in the recycling stage and should also be taken into consideration.

What is the need?

  1. It is vital that there is a proportionate, relevant and effective regulatory regime for the manufacture of EV batteries in the UK, lest we create pockets of chronic ill-health amongst the workforce and environmental hazards that mirror the legacy of coal mining in blighting communities and creating multi-generational burdens on health. The scale of potential exposure to materials not previously used at scale or at all in the UK raises a serious prospect that we will bequeath a legacy of rare cancers that will block beds needed for those who cannot avoid illness.
  2. There is no active consideration or guidance about the health risks to workers involved in the manufacture, servicing and recovery of batteries. It is vital that we scale up production and use of this technology to replace carbon technologies. It has taken decades to ensure that the UK’s hydrocarbon industries protect their workers from the inherent carcinogens and toxins in their manufacturing and supply chain. It is imperative that as new battery technology evolves in the UK, we stay ahead of new threats to human health.

What actions must we take?

  1. We therefore recommend:

f)        HSE produce published guidance, subject to objective scientific review around the health risks and management of substances and processes involved in the manufacture of batteries. This is essential to guide and inform the design, management and creation of new manufacturing plants so as to design out risks in accordance with the UK’s sovereign standards;

g)      HSE revisits EH40 with a prospective view to the likely potential future use of substances potentially being used for battery and other low carbon technology to align with IARC standards (at least) and to be informed by ACGIH findings from the US and ECHA findings from Europe to determine the best limit values to guide the design of proprietary processes;

h)      All workers in UK battery manufacture and recycling plants should be subject to a risk based health surveillance program where exposure risk is deemed high enough because of the novel combinations of hazardous materials;

i)        In accordance with regulation 7 of the Management of Health and Safety at Work Regulations, the minimum qualification of persons responsible for managing the control of exposures to substances harmful to health should be Chartered Occupational Hygienist, because of the potential complexity of exposure;

j)        No UK government or local government subsidy, investment or formal incentive should be provided to battery manufacturing companies without a formal and distinct occupational health preventative strategy being place (in line with good practice developed with EDF at Hinkley Point);

k)      Battery manufacturers should collaborate and contribute to research in the UK about the health effects of the rare materials that they work on;

l)        In line with the UK’s commitment to sustainable development, UK-supported battery manufacture should be able to evidence a supply chain for raw materials which ensure that those involved in the extraction, recycling and recovery, other processing and transport of substances harmful to health are protected against known threats to human health.

Why must we act?

  1. BOHS are committed to supporting a greener, low carbon future, but also one that is not blighted by thousands of lives cut short, the burgeoning of rare cancers and millions of pounds of additional cost in benefits and healthcare. Parliament must not ignore these risks and should ensure a pro-active approach to health risk management based on anticipating risk and the effective translation of appropriate expertise from other industries, such as the petrochemicals sector.