How the new standard deals with alterations and repairs to in-scope vehicles will have a large impact on the industry. See below the phrases from the standards below which relates to alteration and repair requirements:

OUR TAKE ON ALTERATIONS AND REPAIRS

When you are replacing a component within the system with a like for like replacement (eg replacing and AGM / Lead Acid battery with another AGM / Lead Acid Battery) then it is acceptable that the installation complies with the original standard that was applicable at the time of the install. As per Clause 1.5.2.1 the terminology of this is a ‘direct replacement’. However, if you are for example upgrading the system to a Lithium battery based system, you are essentially moving away from the notion of a ‘direct replacement’. Therefore all aspects of the electrical installation should be brought ‘up to spec’ to comply with 3001.2:2022.

As far as we are aware in most cases, adding new batteries ‘as an upgrade’ to an existing system would be considered an alteration. We have sought clarification from state regulators [Appendix 1] on this issue.

OUR TAKE ON SYSTEM ‘BMS’ PROTECTION

The above considerations should be standardised functions of any single lithium battery. Amptron uses advanced, safe and reliable battery management systems. We take great care in the setting of the BMS parameters in line with our manufacturing, and communicating these parameters to the user through our datasheets and user manuals. In addition, for the BluEdge series, it is possible to adjust the parameters through software if needed, which Amptron can make available to qualified and professional users.

See the phrase from the standard below which relates to battery system monitoring and communication

OUR TAKE ON ‘MONITORING AND COMMUNICATION’

Amptron raised several questions regarding the monitoring of the battery with Standards Australia, as well as state based regulatory bodies. We confirmed the following:

1. A smartphone application communicating with the battery is not considered adequate, as the phone may run out of battery, may not be present, or may not be able to be accessed in case of emergency.
2. Wireless communication between the monitor and the BMS is OK, however the wireless display/ visualisation device should be permanently mounted within the recreational vehicle. The wireless protocol should connect directly to the BMS.
3. Traditional shunt monitoring devices may not be considered compliant because they are not connected directly to the battery as per 5.4.12.3.4. Also, if the battery system has parallel or series connected batteries, the shunt cannot display individual critical battery information.In our opinion the best practice is a permanently connected monitor that communicates directly to the battery (or batteries if multiple in series/ parallel) BMS. In addition, this monitor should also report critical faults along with SOC and voltage. Amptron has updated its range to now include communication ports and Bluetooth modules, which connect directly to the battery management system. In addition, for most of the BluEdge series, if you are using multiple batteries connected in series or parallel, you able to communicate with one of the batteries allocated as the Master/Host, which will consolidate and communicate the information from all of the individual batteries. We have sought clarification from state regulators [Appendix 2] on this issue.

See the phrase from the standard below that relates to install locations:

OUR TAKE ON ‘LITHIUM BATTERIES INSTALLATION LOCATION’

If the space within the vehicle is used for sleeping and other living activities that make it a ‘habitable space’ then Lithium batteries cannot be installed in this space.

• Based on our research, any storage compartments for the batteries should be sealed from the ‘habitable space’ and not accessible from the ‘habitable space’ without using tools. EG: Under the bed of a caravan, in a cupboard in the same ‘habitable space’ where people may reside/ sleep, and where the battery bay is accessible from the habitable space and not fully sealed and vented to the outside. This should no longer be done.

OUR TAKE ON BEST PRACTICE

Treat the battery like an LPG tank. The battery compartment should be located external to the main habitable space of the recreational vehicle, e.g. in a sealed separated enclosure to the habitable area. If the battery compartment is within the space of the recreational vehicle (e.g. in a cavity below seating) then this cavity should be accessed via an external hatch, rather than from within the habitable area. In this case the access and venting is external, and any gas escaping should not enter the habitable area.

• NON-BEST PRACTICE, BUT ACCEPTABLE – Electrical Standards Victoria noted in August 2023 that the battery could be installed within the habitable space of a caravan, noting that the barrier to the space would need to prevent gases from entering the habitable area. For example, an existing under seat battery hatch, is retrofitted with a sealable lid, which can be compressed down meaning no gas to escape. The venting of this hatch must be external, with sealed glands used on every cable that runs between the hatch and the habitable space.
• While internally accessed battery hatches may be somewhat acceptable, (and definitely easier for builders and manufacturers), large access lids/ hatches have the potential to warp or bend over time meaning the seal will be compromised. The downside of this battery access method is that a compromised seal may lead to venting into the habitable space.

Full copies of the standard can buy purchased from the Standards Australia Website. If you are a member of the Caravan Industry Association Australia, access to the standard is available through Caravan Industry Association of Australia portal. If you would like clarification on any part of the standard, we would be happy to discuss with you via phone or email.

Response from NSW Department of Fair Trading

AMPTRON QUESTION:
In regards to section 1.5 it is not quite clear what the difference between ‘alterations’ and repairs is. Eg – If a caravan has a lead-acid battery that is no longer working, and it is replaced with a lithium battery as a drop-in-replacement (no other modification to the installation) is this classified as an ‘alteration’ or ‘repair?’

RESPONSE:
“In my view your example below would be called an alteration for the purposes of compliance with the standard. I would suggest that simply replacing a lead acid battery with the equivalent lithium ion battery would not satisfy the requirements of 1.5.1.1 (b) as I would assume (without looking at specific details) that the requirements are vastly different between section 5.4.11 and 5.4.12.”

Response from WA Department of Mines, Industry Regulation and Safety

AMPTRON QUESTION:
Same as above

RESPONSE:
“Clause 1.5.2.1 of AS/NZS 3001.2 provides the definition to what a repair is. To correctly understand the
requirements, it is easier to break down the parts of the clause and look at their separate requirements. There are a number of items to consider.

1. This clause is for repair only. It is for when an item of equipment or part of the installation has failed. It cannot be used as an easy requirement for an alteration because it allows the existing arrangements to go unaltered.
2. The wording “using methods, fixtures and fittings that were acceptable when that part of the electrical installation was originally installed”. This part is I ooking at a direct like for like replacement. For example, replacing a fight switch with a fight switch or an outlet for an outlet.
3. The wording for the next part is “originally installed or with methods, fixtures and fittings currently available as a direct replacement”. This is taken at replacing a failed item of equipment with a modern replacement. The major part to this is the words “direct replacement”. This means of the same type, rating, basic technology as the failed component. To go away from this is an alteration.