Resource Centre / Evidence & Documentation / Stakeholder Documentation
Resource Guide 12

Documentation for Insurers, EHS Teams & Fire Authorities

A strong battery-safety review needs more than a product data sheet. Battery inventory, site conditions, operating procedures, fire protection, emergency planning and product evidence may all be relevant depending on who is reviewing the risk.

The documentation principle

Make the battery operation understandable to someone who does not run it every day.

A reviewer needs to understand what batteries are present, what happens to them, where that activity occurs, what can go wrong and what controls are already in place.

The product is only one part of that picture. A cabinet, container or charging system cannot explain the battery inventory, site layout, emergency process or organisational controls around it.

Battery Safe Systems — practical interpretation Build a site evidence pack — not a folder of unrelated product brochures.

Organise information around the battery activity, identified hazards, controls, equipment and documented limitations so another person can follow the reasoning behind the safety strategy.

Important There is no single universal document pack required by every insurer, EHS team or fire authority.

Requirements vary with jurisdiction, occupancy, battery quantity, activity, insurer, organisational policy and the nature of the proposed installation. This guide provides a structure for organising information — not a substitute for stakeholder-specific requirements.

01
Different reviewers

The same battery operation can be viewed through different risk lenses.

Insurer Property & business-loss exposure

An insurer may focus on fire severity, storage arrangement, separation, suppression, detection, property exposure and the potential for a local event to become a larger loss.

Primary question: how could this affect the property?
EHS Workplace hazards & controls

An EHS review may focus on employee exposure, operating practices, abnormal battery handling, training, emergency procedures and whether controls are being maintained.

Primary question: how is the hazard managed operationally?
Fire authority / AHJ Code compliance & emergency response

The fire code official or other AHJ may consider the adopted code, permits, battery quantities, fire protection, technical reports, emergency planning and the proposed installation.

Primary question: does the arrangement satisfy applicable requirements?
Facilities / management Site operation & maintainability

Internal facilities teams may need to understand electrical load, physical location, maintenance, alarm interfaces, access, inspection and future capacity.

Primary question: can we operate this safely over time?
Same battery operation Different stakeholder Different questions Relevant evidence
Practical interpretation Do not send every reviewer the same unexplained bundle of documents.

Maintain one strong underlying evidence pack, then make the relevant information easy to find for the particular review.

02
Battery & site record

Start with a clear description of what is actually happening at the site.

Before discussing a cabinet, room or charging system, establish the battery inventory and the operating context. This provides the basis for both risk assessment and stakeholder discussion.

Battery inventory What batteries are present?

Battery type, chemistry where known, manufacturer, model, quantity and Wh / kWh information.

Condition What states can batteries be in?

New, in-service, returned, end-of-life, damaged, suspect or recalled batteries should not be treated as one uniform inventory.

Activity What happens to them?

Storage, charging, repair, testing, handling, quarantine, collection or transportation.

Charging How much charging occurs?

Chargers, simultaneous charging quantity, electrical demand, charging periods and supervision arrangements.

Location Where does the activity occur?

Building, floor, room, occupancy, proximity to exits, combustible materials and important property.

Existing protection What controls already exist?

Fire alarm, detection, suppression, ventilation, separation, security and emergency arrangements.

People Who interacts with the batteries?

Employees, contractors, students, fleet operators, maintenance teams or members of the public.

Battery flow Where do batteries go next?

Returned batteries, damaged batteries, recycling, disposal and transport routes should be understood.

Use the Battery Inventory & Site Risk Assessment guide
03
Insurer review

Property insurers may look beyond whether the battery equipment itself can burn.

Property-loss prevention considers the potential scale of an event and how effectively it can be limited. Battery quantity, storage arrangement, fire protection, separation and surrounding property can therefore be as important as the equipment itself.

Inventory Quantity, energy & battery condition

Provide enough information to understand the scale of the exposure.

Storage Layout & arrangement

Show storage height, separation, configuration and surrounding combustible load where relevant.

Location Property exposure

Identify the battery area relative to buildings, important equipment, escape routes and other operations.

Suppression Automatic fire protection

Document existing suppression systems and relevant design information where available.

Detection Alarm & monitoring

Explain how abnormal conditions or fire are detected and communicated.

Procedures Damaged battery handling

Show how abnormal batteries are identified, isolated and prevented from re-entering normal stock.

Emergency Pre-incident planning

Record what staff do, who is contacted and what information responders can access.

Evidence Protection-system documentation

Provide the technical evidence supporting any containment or fire-performance claims relied upon.

Insurer example FM Data Sheet 7-112

FM publishes dedicated loss-prevention guidance for lithium-ion battery manufacturing and storage. This illustrates the broader property-risk factors an insurer may consider, but it should not be treated as a universal requirement imposed by all insurers.

FM Data Sheet 7-112 ↗
Important Ask the actual insurer what they want reviewed before treating an insurer guideline as a mandatory rule.

Insurance requirements, engineering recommendations and statutory requirements are different things and should be labelled accordingly.

04
EHS review

Show how the battery hazard is controlled during everyday operation.

An EHS review is likely to focus heavily on what employees actually do: how batteries are inspected, charged, handled, removed from service, isolated and ultimately transferred or disposed of.

01
Hazard assessment

Identify relevant electrical, thermal, chemical, fire and physical hazards.

02
Charging procedure

Define approved chargers, charging location, inspection, supervision and abnormal-condition response.

03
Battery inspection criteria

Explain signs of damage, swelling, leakage, overheating, physical impact or other abnormal condition.

04
Damaged-battery procedure

Define who removes a battery from normal use, where it goes and how escalation occurs.

05
Employee roles & training

Document who is authorised to perform battery-related activities and the training relevant to those tasks.

06
Emergency action

Define alarm, evacuation, isolation of the area and communication with emergency responders.

07
Maintenance & inspection

Show how charging systems, storage equipment, alarms and supporting controls are maintained.

08
Incident review

Record significant battery incidents, investigation findings and changes made afterwards.

Primary source OSHA — Lithium-ion Battery Safety

OSHA's current lithium-ion battery fact sheet addresses hazards and controls relevant to battery manufacturing, use, emergency response, disposal and recycling.

OSHA Fact Sheet ↗
Review OSHA & Workplace Lithium-Ion Battery Safety
05
Fire authority / AHJ

Give the authority enough information to understand the proposed arrangement.

Where fire-code review or approval applies, the question is not simply whether a product has a test certificate. The authority may need information about the battery operation, quantities, location, fire protection, emergency planning and technical basis of the proposed arrangement.

Code basis Adopted code & edition

Record the code edition and local amendments being used for the assessment.

Battery scope Inventory & activity

Identify battery quantity, condition, configuration and whether the operation is storage, charging or another activity.

Site Plan / location information

Show the proposed battery area, building context, exits, separation and relevant fire-protection systems.

Product System specification

Provide model information, capacity, installation arrangement, electrical requirements and manufacturer instructions.

Evidence Testing & certification

Provide the evidence supporting the capabilities relied upon in the proposal.

Fire protection Detection / suppression

Document existing and proposed protection where relevant to the applicable code pathway.

Emergency Fire safety / response plan

Show how possible battery fires are detected, reported and addressed within the site's emergency strategy.

Technical basis Report / engineering analysis

Where required, provide the technical opinion, testing or engineering basis supporting the design.

Current model-code example 2024 IFC Section 320 includes explicit documentation requirements for certain lithium-battery storage arrangements.

Section 320.3 requires a fire safety plan for storage within the section's scope. For certain larger indoor storage areas, Section 320.4.2.1 requires a technical opinion and report evaluating fire and explosion risks and making recommendations for protection, with submission to the fire code official.

View 2024 IFC Section 320 ↗
Adoption matters The 2024 IFC is a model code — not a universal nationwide documentation requirement.

Confirm the locally adopted code edition, amendments and AHJ interpretation before assuming that a model-code provision governs a particular facility.

Review Fire Codes, NFPA, UL & the AHJ
06
Operational procedures

Document what happens when the battery is normal — and when it is not.

Normal receipt Battery acceptance

Incoming inspection, identification and battery condition.

Storage Routine storage

Location, inventory controls, separation and housekeeping.

Charging Charging operation

Charger compatibility, connection, supervision and operating hours.

Inspection Abnormal condition recognition

Damage indicators and criteria for removing a battery from service.

Isolation Suspect-battery pathway

Stable abnormal batteries should have a defined route away from normal inventory.

Incident Emergency pathway

Alarm, evacuation, emergency contact and responder information.

Disposition Return / recycling

Supplier return, recycler involvement and transport responsibilities.

Review Lessons & corrective action

Update procedures and controls after incidents or significant changes.

Receipt Store Use / charge Inspect Isolate if abnormal Dispose / return safely
Practical interpretation The documentation should describe the battery lifecycle, not just the moment it sits inside a cabinet.

Batteries move through receipt, storage, charging, use, inspection, damage, isolation and end-of-life stages. Gaps often appear at the handoff between those stages.

Review Emergency Preparedness for Lithium Battery Incidents
07
Product evidence

Record why the selected equipment is appropriate for the defined requirement.

Identity Manufacturer & model

Keep precise product identification rather than only a quotation or brochure image.

Specification Technical data

Capacity, dimensions, electrical ratings, ventilation and system features.

Instructions Installation & operating manual

Intended use, siting conditions, installation requirements and limitations.

Certification Listings & certificates

Record the exact product, standard, certification body and scope.

Testing Relevant reports

Keep evidence supporting the specific capabilities relied upon during selection.

Configuration What was evaluated?

Battery type, loading, energy, state of charge and test configuration where relevant.

Limits Conditions & exclusions

Record where the evidence stops applying rather than documenting only the headline claim.

Selection Decision record

Explain which requirement and capability the product was selected to address.

Site requirement Required capability Product Evidence Documented decision
Avoid “We bought it because the supplier said it was compliant.”

A more useful record identifies the requirement, the relevant capability and the evidence used to support the selection.

Review Understanding Product Testing, Certification & Documentation
08
Maintain the evidence pack

A document pack only helps if it still describes the site.

Suggested structure Battery Safety Site File
01 Battery inventory
02 Site plans & locations
03 Risk / hazard assessment
04 Operating procedures
05 Emergency procedures
06 Training records
07 Product specifications
08 Testing & certification
09 Fire protection information
10 Inspection & maintenance
11 Stakeholder correspondence
12 Incident & review records
Review when Battery inventory changes materially
Review when Charging activity increases
Review when New battery chemistry or format is introduced
Review when Equipment or site layout changes
Review when A battery incident occurs
Review when Codes, insurer requirements or stakeholder expectations change
The documentation principle The objective is traceability: someone should be able to understand what the risk was, what was selected and why.

Good documentation preserves the reasoning behind the battery-safety strategy and makes future insurer, EHS, AHJ or internal review much easier.

Primary references

Use stakeholder requirements and primary sources together.

These references illustrate the kinds of hazards, controls and documentation that can affect battery review. They should be applied according to their actual scope rather than treated as one universal checklist.

Resource Guide 12

You now have the information framework. The next step is applying it to the actual battery operation.

The Battery Safe Systems Resource Guides are designed to move from understanding the battery and site, through operational and regulatory requirements, into evidence-backed system selection.

Need to turn the evidence into a system requirement?

Start with the battery, the site and the capability you need.

Battery Safe Systems can help organise the requirement and compare appropriate storage, charging, isolation, transport and containment approaches against the evidence available.

Start a Guided Assessment