no tool = no pass, unless tested to ul4200A

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As discussed in my other blog "Understanding the Standards" the standards fall in to 3 groups...

1. AV Electronic
2. UL Lithium
3. Luminaires

On this page I will explain how the requirement (or not) for a tool to open is

a) called up in the legislation

b) called up in the various standards

For the sake of a compelling argument, I will copy/paste from the legislation and standards.

Note: If your product that contains button batteries requires two simultaneous and independant hand movements (like a medicine bottle), then there is no need to meet the tool test.

Section 13 of the legislation calls for 2 hurdles that must both be met. Note the use of the conjunctive 'and' in section 13 (1) which requires that both hurdles must be met. That is: 13 (2) [Construction] and 13 (3) [Torture Testing] 

Section 13 (2) calls up Section 4.8.3 [Construction] in the Standard. 4.8.3 clealy states that a tool must be used. We shall assume that the alternative provision (2 simultaneous movements) does not apply as that is usually the case with the products we deal with here at BB Labs.

So if the product can be opened with your hand*, you don't need to bother with the torture testing. It has failed before you got started if you are assessing against the AV standards.

*that leads to the next big question that the legislation and standard do not address... how strong do you need to be? See "The Flip Key Conundrum"

Section 14 of the legislation calls up the Luminaires Standard as an option.

In my blog article "Understanding the Standards" I  discussed how the Luminaires Standard is not really relevant to car keys and garage remotes. Perhaps a lawyer could argue it does apply, but from a common sense and moral point of view it would be silly to adopt this standard. Nevertheless, if you did use it, your product will still fail the test if you can open it without the use of a tool.

The Legislation does not call up Section 5 of the the UL Lithium Standard (that's the section that requires tool openeing). However it does have more forceful torture testing. Basically, products containing button batteries that are hard to open by hand will pass. Easy to open products generally will get found out by the heavier finger probe test.