Three editions of the International Fire Code are live at the same time. The 2018, the 2021 and the 2024. Which one an energy storage project has to satisfy depends on which city or county it is being built in.
That gap, rather than the content of any individual requirement, is what Kevin Fok keeps returning to. Fok is Director of Compliance at LG Energy Solution Vertech, and he was speaking in Las Vegas. His view of the requirements themselves is calm. His view of when they arrive, and of how much they vary between one jurisdiction and its neighbour, is where the real difficulty sits.
The stack follows the hardware
Fok sets the standards out in the order the system is put together. An ESS is built from components: the cell, then battery modules, then racks, then enclosures.
The cell and the module are covered by UL 1973. Those roll up into the system, which is covered by UL 9540. Both of those are product-level standards.
Above them sits the installation standard, NFPA 855, which he calls the key standard used for governing ESS installations in the US market.
NFPA 855 is not a single document in practice. It carries referenced standards that have to be met alongside it, covering things like fire alarm design and the way the communications are set up. Meeting the installation standard means meeting a set of documents rather than one.
At the headline level, what it asks for is fire protection, explosion mitigation and enclosure spacing. None of that stays on paper. Those requirements feed straight into system design, because the manufacturer and the system designers have to make sure the designs are compliant.
A model code is a starting point, not the final text
The complication arrives between a standard being written and a standard being enforced.
The International Fire Code is a model code, which Fok defines precisely: something a standards development organisation develops and maintains, which each individual government then adopts and puts into law, amending it according to local requirements. So the model code is a common starting point, and everything downstream of it is where projects diverge.
Divergence happens in two ways. Local amendments, because some areas will change the code to meet local needs. And timing, because the different editions all exist and cities and counties sit on different ones.
Fok describes trying to work with all of the stakeholders towards a common set of requirements as one of the challenges the industry faces, and is straightforward about why it is hard: the requirements are not always standardised. Asked whether going international makes it more complex again, he agrees that it does.
Engineers would rather know
His position on the requirements themselves is that they are not the problem.
If the system designers understand the requirements in advance, he says, then it is straightforward. The system, the software and the entire package can be designed accordingly, and his read is that designers and engineers would prefer to know what the requirements are up front rather than find out later.
What stops that from happening is structural. Technology development is much faster than codes and standards development, so there is always a little bit of lag.
That lag is also where the money goes. Fok splits the cost question by horizon. In the longer run, he argues, codes and standards make projects more economically viable and sustainable, because systems that are built to withstand disasters and the normal rigours of operation are safer for the community and better things to own. In the shorter term, new requirements that were unforeseen and suddenly have to get designed in bring added cost and added complexity that were not originally envisioned. Known in advance, the same features could simply have been built in.
Chemistry is handled by the paperwork, not the code
Put to him that Chinese energy storage has gone heavily to LFP for regulatory reasons, and asked whether an LFP system in the US faces a different set of rules than an NMC one, Fok's answer is that the same codes and standards apply.
What captures the chemistry is a document rather than the code text. The hazard mitigation analysis is prepared for the product or the system being installed, regardless of chemistry, and it is the submitter who prepares it based on the technology going in. That extends to newer chemistries, sodium-ion among them, without anything upstream needing to change. The safety documents for emergency response and mitigation are built to cover different technologies already.
The practical consequence is flexibility. The code does not have to be revised every time a new chemistry reaches the market.
Genuinely new technology still has a route in, and it runs through task groups. Committees will often set several up, and usually one of them handles emerging technologies. Fok describes cases where emerging technology companies were invited to present: what the technology is, what some of the hazards might be, what mitigation approaches exist. That input then gets factored into the codes and standards. He reads the willingness to hold those sessions as a good sign, saying the committees recognise that emerging technologies exist and welcome the input.
The room is much bigger than the battery industry
One committee Fok mentions has something like 120 or 130 people on it. The reason is the number of vantage points involved, each arriving with a different set of input, and the effect he points to is dialogue among technical committee members that otherwise would not happen.
His argument for why that matters is that ESS has long gone past being a battery system that only battery manufacturers need to be involved with. The list he gives runs through system integrators, site owners, the authorities having jurisdiction, insurance companies, investors and the general community.
Asked for a takeaway from years of this work, he gives the same thing back in personal terms. What he gained a better appreciation for was simply how many stakeholders there are. He would go in looking at one aspect, and several people would raise points he had not considered before, which is how he came to understand what the concerns actually were.
Which leaves the gap he named at the start as an education problem more than a technical one. Once the stakeholders understand what the requirements are and why they are set up that way, there is a basis for commonality in system design and in getting the approvals. Because differences remain, and because the education is not yet even, there is a little bit of catch up going on.
This piece draws on the full conversation, which is available with a complete transcript on the episode page.