Battery storage site commissioned without on site fire water provision, concern raised before any incident

In 2018 a grid connected battery energy storage site in the UK was built and commissioned to operating status. An engineering practitioner later raised a formal concern through a UK collaborative safety reporting scheme, stating that there was no fire hydrant within 90 metres of the site, the nearest being about 1.7 kilometres away, and that no emergency water supply had been provided on site. The reporter stated that the absence of accessible firefighting water had not been identified during consultation with the local fire and rescue service, nor at the design and approval stages. The scheme's expert panel reviewed the concern and published it with commentary in 2023. No fire occurred at the site, and the matter was recorded as a fire response vulnerability identified before any incident.

As stated by the reporter and the reviewing expert panel: (1) the general building fire safety guidance applied, Approved Document B, was considered not always sufficient for battery specific fire hazards, and the reporter's view was that such sites fall outside the common building situations the guidance addresses; (2) the fire and rescue service consultation carried out for the project did not identify the water supply gap, although consultation was the intended route for fire response considerations to be raised; (3) the reporter considered that suggestions to treat attenuation ponds as an emergency water supply were not an adequate substitute for dedicated fire water provision; (4) the reporter also noted that site safety signage was inadequate, with 'Danger of Death' signage not displayed on the required yellow background, which the reporter regarded as a separate departure from the Electricity Safety, Quality and Continuity Regulations 2002.

1. Engage the fire and rescue service early in design and confirm in writing what water supply, access and response arrangements are required, rather than relying on planning stage consultation alone.
2. Check whether the general building fire safety guidance applied to a site actually addresses battery specific hazards such as thermal runaway, deflagration and prolonged firefighting, and specify additional provision where it does not.
3. Produce an emergency response plan for first responders at design stage, with the fire water source, volume and duration agreed and documented.
4. Do not assume that attenuation ponds or other site water features constitute an emergency water supply without written confirmation from the fire and rescue service that water can be drawn in the volumes and timescales a battery fire would require.
5. Verify that site safety signage meets the Electricity Safety, Quality and Continuity Regulations 2002, including the specified background colours, at handover and at periodic inspection.
6. Include hydrant distance and fire water provision as explicit items on the commissioning and handover checklist, so that a site cannot reach operating status with the point unresolved.
7. Provide a route for staff and contractors to raise safety concerns through a confidential or collaborative reporting scheme, so that gaps can be addressed before rather than after an incident.

Approved Document B

cross-safety.org/uk/safety-information/cross-safety-report/battery-energy...