What is PGS 37-2?
PGS 37-2 is the guideline from the Dutch Publication Series on Dangerous Substances (Publicatiereeks Gevaarlijke Stoffen) for the safe storage of lithium-containing energy carriers. The current version is PGS 37-2:2023, version 1.1. It describes risks and measures around storage, damaged or defective batteries, charging, detection, incident response, registration and competence.
It is not a certificate. Which measures apply legally depends on the activity, the type of battery, its condition, the quantity per fire compartment, permit conditions and local rules. Storage of lithium batteries has not yet been designated nationally as a separate environmentally harmful activity in the Dutch Environmental Activities Decree (Besluit activiteiten leefomgeving, Bal). An amendment is in preparation; IPLO, the Dutch government's information point for the living environment, expects it to enter into force in 2028. Until then PGS 37-2 takes effect through permit conditions, the duty of care, tailored requirements or rules in the municipal environmental plan.
For us the guideline is above all a yardstick. Used, defective and sometimes damaged batteries come in every working day. For each battery we want to know what state it is in, whether it is safe to handle, where it is in the process and what the next step is.
Does PGS 37-2 only apply above 300 kg?
No. You often hear the 300 kg figure, but the guideline works with different groups of energy carriers, each with its own threshold per fire compartment. For the groups that matter most in a battery workshop:
| Group of energy carriers | Threshold per fire compartment |
|---|---|
| A specific group of low-capacity cells and batteries | 1,000 kg |
| Various other groups | 333 kg |
| Damaged or defective energy carriers | 30 kg |
The difference between 333 and 30 kg says it all. An intact e-bike battery above 100 Wh falls in a 333 kg group; the same battery with a dent or a leak falls in the 30 kg group. The 1,000 kg group covers only small cells and batteries of up to 100 Wh. That is why we look beyond kilos, above all at the condition of the battery and where it is in the process. Which threshold applies to your situation depends on the actual category and quantity.
What happens to a battery when it comes in?
1. Registration and incoming inspection
The battery is linked to an order or case. We record the details and do a first safety check for dents, cracks, deformation, exposed wiring, water or fire damage and leakage. Safety starts here, before the diagnosis.
2. Technical assessment
Then we measure. Depending on the battery type we test capacity, cell balance, BMS function, communication and error codes. That way we do not replace the cells in a battery that a targeted repair would fix, and we know which step is technically sound.
3. Status and location in the portal
Our portal shows the status of each battery and where it is stored. That helps with planning and customer contact, and with safety too. An ordinary battery in process, a battery still to be assessed and a battery for disposal do not belong together.
4. Charging and testing in a fixed place
Charging and final testing take place in facilities designated for that purpose, away from temporary storage. Heat build-up, electrical faults and a possible thermal runaway are easier to control when you know exactly where those risks are.
5. Suspect or damaged batteries kept apart
If we see a deviation at intake or later in the process that points to an increased risk, it is no longer an ordinary battery in process. We assess it under our internal procedure and, where necessary, physically isolate it in a facility intended for that purpose. Employees report deviations immediately and do not leave such a battery unattended in the workflow.
6. Repair or controlled disposal
If a battery can be repaired safely and sensibly, we do that. If not, or if it is handed in as waste, it goes to controlled collection and disposal. We record the transport and disposal data.
How is safety organised within the company?
A steel storage unit does little if nobody knows what to look for, record and do. That is why we combine facilities with fixed ways of working, instructions and checks:
- a safety check on arrival;
- registration of the battery and its process status;
- separate handling of different risk categories;
- designated charging and test facilities;
- safety instructions and designated competent employees;
- an internal emergency plan for smoke, fire and suspected thermal runaway;
- detection and alarm according to the facilities installed at the site;
- periodic checks and improvement within the ISO 9001 management system.
The emergency plan is clear about who does what. In case of smoke, flames or doubt we call the emergency services on 112. Employees only take initial action within safe limits. In a fire or thermal runaway the fire service is in charge.
Practising with the fire service
An emergency plan on paper says little until you have practised it. In Beugen we ran through a scenario with the fire service, with a simulated battery incident, smoke and the rescue of people.
Among other things, we looked at the approach and access for the crews, rolling out fire hoses, the available fire-fighting water supply, the handover of information and controlling the battery involved. We use the exercise to learn and improve. It is not a certificate and not a formal approval by the fire service.
Traceability and ISO 9001
KWS Seuren is ISO 9001:2015 certified. For battery service that means quality does not depend only on what happens at the workbench. Checks, records, deviations and improvement actions have to be repeatable and demonstrable.
With battery safety it comes down to the same thing. You want to know which battery came in, what happened to it, where it is now and which next step was chosen.
What happens to discarded batteries?
Not every battery can be saved. We keep discarded batteries separate from the repair work. They go to controlled collection and disposal. The ADR rules apply to the packaging and transport of lithium batteries, and we match transport and packaging to them.
The order stays the same: first we check whether safe repair or reuse is technically sound. Only when that is not possible does end-of-life follow.
Frequently asked questions
No. PGS 37-2 is a safety guideline and not a certification scheme. KWS Seuren uses the guideline as an important safety and assessment framework and therefore prefers to describe the concrete measures and processes instead of claiming a certificate that does not exist.
That depends on the situation. In the Netherlands PGS 37-2 can become relevant or mandatory through permit conditions, the duty of care, tailored requirements or local rules. National regulation is also still developing. Whether the guideline applies is assessed on the basis of the actual activity, the quantity and the category of batteries.
No. There is no universal limit of 300 kg. PGS 37-2 has different thresholds per category and fire compartment, including 1,000 kg, 333 kg and 30 kg. Damaged or defective batteries fall into a much stricter category (30 kg) than certain other energy carriers.
KWS Seuren first checks every incoming battery for visible safety deviations. If there are signs of an increased risk, the battery does not stay in the normal process. It is assessed under the internal procedure and set apart where necessary.
At KWS Seuren, charging and final testing are a separate process step in a facility designated for that purpose, away from temporary storage. The exact way of working depends on the battery type, the purpose of the test and the technical condition of the battery.
If repair or responsible reuse is not possible, the battery goes to KWS Seuren's controlled collection and disposal. The rules for storage, packaging and transport of lithium batteries apply.
No. Contact KWS Seuren before you transport or ship a swollen, leaking, burnt, badly overheated or otherwise visibly damaged battery. Specific transport rules apply to damaged or defective lithium batteries, and a standard parcel shipment is then not always permitted.
For business customers
For bike shops, insurers, care organisations, lease and fleet operators and manufacturers, battery safety is part of the chain. It is then about more than the repair: intake, traceability, temporary storage, return logistics and what happens to batteries that can no longer be used.
Does your quality, purchasing or safety department set requirements for a battery service provider? Then we explain our process and quality information and agree arrangements for intake, reporting, logistics and returns. See how we work with bike shops and organisations, read more about quality and safety in every battery order or get in touch with our business team.
Want to have one battery examined, or register a damaged battery?
For a single battery you can request an examination directly. Do you have a battery that is swollen, leaking or burnt? Contact us first, so we can decide together how it reaches us safely.