Third Party Fire Safety Audit of Battery Energy Storage System (BESS) 

1. Background:

As mandated under the provision of regulation 122 (L)(1) of the Central Electricity Authority (Measures relating to Safety and Electric Supply) (First Amendment) Regulations, 2025, “an independent third party fire safety audit of the Battery Energy Storage System(BESS) shall be conducted, as provided in the Standard Operating Procedure (SOP) to be issued by the Authority”.

In line with the provision mentioned above, the Central Electricity Authority (CEA) has prepared the Standard Operating Procedure (SOP) for conducting independent third party fire safety audit of Battery Energy Storage System(BESS).

2. Definition: Independent Third Party Agencies: The Independent Third Party Agencies (ITPAs) shall be accredited/empaneled by the office of Directorate General of Fire Services (DGFS) for the purpose of providing qualified auditors for conducting independent third party fire safety audit of Battery Energy Storage System(BESS).

3. Objective: Battery energy storage systems are inherently susceptible to fire hazards, primarily arising from thermal runaway and potential cascading cell failures and require special considerations. This SOP aims to provide an independent third party fire safety audit framework to maintain BESS installations in a condition free from dangers associated with fire related safety hazards of the BESS to avoid any injury to human, animal and property and also ensure the Grid stability. This can be ensured through the regular audits of the BESS installations & putting in place comprehensive measures to mitigate the occurrence of fire, prevent its propagation.

4. Scope and Applicability: This SOP shall be applicable to the Owner of the BESS Installations, Original Equipment Manufacturers (OEMs), Independent Third Party Agencies (ITPAs), Auditors, Directorate General of Fire Services (DGFS) and Central Electricity Authority (CEA).

5. Roles and Responsibilities: 

a) Owner

(i) The owner of the BESS shall arrange for an independent third party fire safety audit of the BESS installations through ITPAs and obtain necessary fire safety approval for the BESS installations before applying for energization approval under the provisions of Regulation 45 of the Central Electricity Authority (Measures relating to Safety and Electric Supply) Regulations, 2023 and its subsequent amendments. The applicant shall submit a copy of Fire Safety Audit report while applying for first time energization application.

(ii) The owner shall ensure that the periodic third party fire safety audit of the BESS installation are conducted at intervals as defined in this SOP and such records shall be made available to electrical inspector, as and when required.

(iii) The owner of BESS installation shall designate a “BESS fire safety officer” for ensuring observance of safety measures specified under these regulations in their organisation for construction, operation and maintenance of BESS. BESS fire safety officer shall have experience in the field of BESS fire safety.

(iv) BESS fire safety officer shall carryout recommended periodic tests as per the relevant standards, and inspect such installations at intervals not exceeding six month once, and keep a records as per the checklist enclosed at annexure-I, test reports and a register of recommendations in regard with BESS fire safety duly acknowledged by owner and compliances made thereafter. Such records shall be made available to the electrical inspector, as and when required.

(v) The owner of BESS installations shall keep the reports of audit submitted by Auditors and the records as mentioned at ‘point (iv)’ of BESS fire safety officer for the period of not less than 10 years.

(vi) It shall be the responsibility of the owner of the BESS installation to inform about occurrence of any fire incident involving the BESS installation within 48 hours to CEA, DGFS and the concerned Auditor/ITPA.

b) Independent Third Party Agency:

(i) An Independent Third-Party Agency (ITPA) shall conduct the third-party fire safety audit of BESS installations through the qualified auditors associated with the agency.

(ii) An Independent Third-Party Agency (ITPA) shall keep records of all the audits conducted by their auditors for the period not less than 10 years.

(iii) The ITPAs shall enroll fire safety auditors for BESS as per the qualification criteria defined in this SOP. It is the duty of the Agency to ensure that the auditors meet required qualification criteria.

c) Auditor: (i) Auditor shall conduct the fire safety audit of the BESS as per the relevant standards and checklist annexed at Annexure-I.  

(ii) The auditors shall strictly adhere to the timelines provided in this SOP for efficient discharge of their duties.

d) Central Electricity Authority (CEA): CEA shall also review this SOP from time to time to align it with best international practices. The periodicity of this review shall be two years.

6. Criteria for Empanelment of Independent Third Party Agencies (ITPA)  An ITPA shall be a legal entity in India or a reputed International Inspecting body having an office in India.

An ITPA shall have at least 3 auditors on its regular rolls.

The ITPA shall carry out audit through qualified auditors who meet the qualifications/ requirements provided in this SOP. The ITPA shall ensure competence of its auditors.

The ITPA shall have an effective organization, monitoring and control mechanism that enables it to maintain the capability to perform the audit functions satisfactorily.

The ITPA shall have experience of audit in the field of conducting BESS related Fire Safety.

DGFS/Authority may, at its discretion, consider an ITPA as an entity which does not possess the requisite minimum experience in the Fire & Safety Audit provided it has adequate qualified personnel having experience in Fire & Safety Audit.

Independence, Impartiality Integrity and Confidentiality of ITPA

The ITPAs shall not have any commercial relationship with the entities other than third party audit.  The ITPA shall ensure confidentiality of information obtained in the course of its audit.  The ITPA shall ensure that all of its manpower including outsourced manpower responsible for carrying out audit related tasks and/or having access to related data/information/document are not only aware of the requirements under this head but shall also ensure compliance of the same through an appropriate mechanism.

7. Qualification of the Auditors

(i) A person possessing Diploma in fire safety from recognized institute/ Registered CLI (Central Labor Institute) or RLI (Regional Labor Institute) and having undergone the training and certification course from a recognized institute as per the guidelines specified by the Directorate General of Fire Services (DGFS) for the purpose of BESS fire safety aspects may be appointed as fire safety auditor for BESS. Person must go through Continues improvement year by year.

(ii) BESS Industry expert may also be certified as fire safety auditor for BESS. In this regard, such industry expert should possess experience of at least 2 years in the field of fire safety of BESS installations provided that such person should have undergone the training and certification courses from a recognized institute as per the guidelines specified by the Directorate General of Fire Services (DGFS) for the purpose of BESS fire safety aspects within 2 years from the notification of guidelines by the DGFS.

(iii) A person having ISO 45001, ISO 50001 lead auditor certificate from recognise body. Experience in Fire Safety Field is at list 10year. If person have NFPA certification or Level 6 Diploma or Level 7 Diploma will be count as under extra qualifications. Document submission mandatory.

8. Audit and Audit Frequency

i. The Third-Party fire safety audit of the BESS installation shall be carried out by an Audit Team comprising of at least two qualified Auditors appointed by

Independent Third-Party Agency (ITPA). The final audit report shall be duly signed by all the auditors and the Owner of the BESS installation.

ii. It shall be ensured that fire safety audit should be conducted for at least two man days for BESS installations up to 100 MWhr capacity, and one man day for each additional 50 MWhr capacity or part thereof, for thorough audit of the BESS installations.

iii. The frequency of conducting the independent third-party fire safety audit shall be as follows:

Pre-commissioning Fire Safety Audit: The Audit shall be conducted at the pre- commissioning stage, before applying for first time energisation to concerned Electrical Safety Inspectorate.

Periodic Fire Safety Audit: Periodic fire safety audits shall be conducted and periodicity of the audit shall not exceed 5 years from the date of previous audit.

Special Fire Safety Audit: In case of any major upgrades/repairs or after occurrence of any fire incident, special audit shall be required to be conducted.

9. Checklist and Key Areas of Evaluation

Auditors shall adhere to all relevant standards/guidelines related to Fire & Safety aspects of BESS Installation. A check-list including key area of evaluation to be followed is appended at Annexure-I.

10. Findings and Recommendations

The Auditor shall submit the audit report within the stipulated timelines. The report shall include, but not be limited to, the following parameters:

The availability of the provisions as per the enclosed checklist;

List of observations and any non-conformities as per relevant standards;

Recommendations to address the observed deficiencies and non-conformities along with suitable deadlines,

Any other recommendation for further safety improvements.

11. Timelines

Following timelines shall be adhered to by the Auditors and the Owner of the installation:

The Auditor shall submit the Audit Report within 3 working days from the last date of the completion of audit.

The owner shall take corrective action and comply with all the observations/recommendations, as suggested in the Audit report and submit a compliance report to the Auditor.

After receipt of satisfactory compliance report from the Owner, the Auditor shall issue the approval within 3 working days.

12. Dispute Resolution

In case of any dispute or in case of any deviation from the aforementioned guidelines; the owner or the Auditor may approach CEA for resolution of the dispute/issue in coordination with DGFS.

Note: Auditors use this checklist when they conduct audit inspections of battery installations.

This battery audit checklist:

a.    is specific to the battery fire safety stream

b.   comprises the questions for the audit of battery installations nominally performed within six months of the battery installation date – focusing on safety and standards

c.    is NOT and should not be regarded as an audit checklist for battery installations more broadly

d.   is NOT a checklist for installing a battery system.

 Key Aspects of the Audit

• Regulatory Compliance: Verifies adherence to national (CEA) and international (NFPA 855, UL 9540, IEC 62619) standards.
• Risk Assessment: Identifies hazards like thermal runaway, fire propagation, and explosion risks.
• Design & Installation Review: Checks for appropriate separation, fire-rated barriers, ventilation, and passive safety features.
• Fire Detection & Suppression: Assesses the functionality of smoke/flame detectors, alarms, and automatic suppression systems (gaseous, water-based).
• Emergency Preparedness: Ensures manual emergency stops are accessible and assesses training for fire personnel.
• Testing Verification: Reviews results from large-scale fire testing (like UL 9540A) for passive containment and alarm reliability. 

Annexure-I

Fire Safety Audit Checklist for Battery Energy Storage Systems (BESS)

Facility Name: ___________________

Location: _______________________

Date of Audit: ___________________

Name of Auditor(s): ______________________

Name of the Audit Agency: ________________

BESS Technology Type: ___________________

Total Energy Capacity: ____________________ kWh

 

GENERAL REQUIREMENTS AND DOCUMENTATION
Sl No.	Items to be Checked/Verified	Status	Comments (If Any)
1	Does the facility have a safety plan documented?
2	Is emergency contact information for qualified service personnel (fire brigade, police, hospitals etc.) available?
3	Whether local fire department should be consulted during the design and planning stages of BESS installations to ensure that local emergency response capabilities and constraints are adequately factored in?
4	Are operations and maintenance manuals readily accessible to the O&M personnel?
5	Does the facility have a monthly in-service inspections and maintenance checklist?
6	Does the facility have maintenance records, such as a preventative maintenance log?
7	Have the electrical engineers undergone any specific electrical energy storage systems training courses?
8	Have certificates been provided to evidence the above?
9	Has the BESS systems and associated components been manufactured and tested to be compliant with safety standard UL 9540: Energy Storage Systems?
10	Has the BESS been installed in accordance with national or international regulations, standards, or codes, such as NFPA 855 – Standard for the Installation of Energy Storage Systems, NFPA 68 – Passive Explosion Mitigation, NFPA 69 – Standard on Explosion Prevention Systems?
11	Are all BESS enclosures of non-combustible construction with any insulation materials also rated as non-combustible and achieving a fire resisting rating (insulation and integrity) of 120 minutes?
12	Whether scheduled drills conducted for procedures involving emergency operations plan?
13	Is the Hazard Mitigation Analysis (HMA) available and approved by concerned utility officials? (NFPA 855)
14	Whether Safety signage displayed for identified hazard zone?
15	In case of batteries having acidic/basic aqueous electrolytes in liquid form, whether provisions for electrolyte spills containment have been provided as per relevant standards.
16	Whether Area around BESS free of dry vegetation, combustible debris, flammable material, scrap accumulation, vegetation growth and have free walkways/passage/Staircase etc?
17	Permit-to-Work system / LOTO for carrying out maintenance works in place.
18	Are outdoor equipment cabinets for inverters etc., securely locked, and any switch/control panels also secured to prevent malicious interference?
SPECIFIC DESIGN CONSIDERATIONS
Sl No.	Items to be Checked/Verified	Status	Comments (If Any)
1	Has at least 3 metres separation been maintained between the BESS enclosures in an installation? (Note: 4.5 metres separation is recommended where achievable)
2	Has at least 1.5 metres separation been maintained between BESS enclosures and inverters and Medium Voltage (MW) transformers?
3	Has at least 10 metres separation been maintained between BESS enclosures and switchgear rooms; High Voltage (HV) Transformers; back-up generators; fuel tanks; electrical vehicle charging facilities; sprinkler tanks and sprinkler equipment, waste enclosures, compactors, pallets stores, smoking shelters?
4	Whether forced ventilation system and automated louvers for safe release of the flammable gases and maintain internal pressure within safe limits?
5	Are any building heating and ventilation system inlets sited within 10m proximity to the BESS installation?
6	Is the area between the BESS enclosures and other buildings, plant etc., maintained clear of vehicles, combustible items etc., to prevent the risk of fire bridging?
7	Is the BESS housed in a dedicated fire compartment with at least 120 minutes fire resistance rating (insulation and integrity)?
8	Are openings for pipework, ducting, services etc., adequately fire-stopped?
9	Is BESS compartment maintained clear of other contents? If not, will this be rectified?
10	Are heating/ cooling systems suitably rated for use in potentially explosive environments?
11	Are the inverters adequately IP rated for external use and not unduly exposed to harsh weather conditions or impact damage from vehicles and other moving plant? (Note: UL1741 Safety of Inverters, Converters, Controllers, and Interconnection System Equipment for Use with Distributed Energy Resources sets out the manufacturing (including software) and product testing requirements for inverters used for grid connection applications).
12	Are transformers manufactured, tested, and installed to BS EN IEC 60076 - Power Transformers?
13	Is the BESS be protected against the risks of lightning damage including surge and transient surge?
14	If a detector activated Video Surveillance System (VSS) monitored by main security control or Remote Video Response Centre (RVRC) and response.
Cooling Systems
Sl No.	Items to be Checked/Verified	Status	Comments (If Any)
1	Are the enclosure and battery racks cooled evenly to help prevent hot spots developing?
2	Are thermographic cameras used to help identify cooling issues within the enclosure?
3	If any air-cooled systems are utilised - Are the batteries adequately cooled?
4	If any air-cooled systems are utilised - Is a formal housekeeping regime in place to clean and replace air filters regularly?
5	If any air-cooled systems are utilised - Is the BESS enclosure regularly inspected to ensure moisture levels are appropriate and no wear or corrosion is developing?
6	If any air-cooled systems are utilised - Are any moisture damaged components replaced promptly?
7	Are dust levels/accumulations monitored and BESS enclosures cleaned as necessary to ensure a sterile environment is maintained?
Ventilation Systems
Sl No.	Items to be Checked/Verified	Status	Comments (If Any)
1	Where passive ventilation is utilised: Are such systems designed, tested, installed, and maintained by a competent and experienced company in accordance with appropriate testing standards? (Note: NFPA 68 - Passive Explosion Mitigation, NFPA 69 – Standard on Explosion Prevention Systems, BS EN 14797:2006 - Explosion venting devices or FM7730 Examination Standard for Explosion Venting Devices apply)
2	Where active ventilation is utilised: Is the ventilation rated as suitable for use in explosive atmospheres and interlocked to the BMS and/or gas detection to activate upon detection of early gas release or potential faults identified by the monitoring equipment?
3	Does the exhaust point of any active or passive ventilation systems vent to a safe area in the open, and not located in an area where any exhausted smoke could compromise the air intake of other enclosures or buildings in proximity?
FIRE DETECTION SYSTEMS
Sl No.	Items to be Checked/Verified	Status	Comments (If Any)
1	A copy of the Fire Alarm Installation Certificate and Record of completion is availlable from Customer/End User.
2	More then one Service Provider was responcible for Maintaining Fire Alarm System
3	A Copy of as-build Fire alarm system drawing signed by competent body is availlable on site.
4	A Copy of Fire Panel operation process is installed near Fire Panel.
5	For addressable system a list of each devices with corresponding location is provided. The devices addressing shall reflect actual room names or numbers that are current to the building use.
6	The dedicated 220-240V AC branch circuit for the fire alarm control panel is labeled " Fire Alarm Circuit" on the electrical panel or actual circuit breaker is colored RED as per NFPA 72
7	The dedicated 220-240V AC branch circuit shall be permanantly marked inside the Fire alarm control panel as per NFPA 72
8	UPS is use for powering up Fire Alarm Control Panel
9	Fire Alarm Panel is grounded properly by earth continuity conductor. Connection can be taken from electrical panel board's earth point.
10	Batteries are permanatly marked with Month & Year of Manufacture as per NFPA 72
11	Modbus / BACnet card is properly installed and output cable is properly terminated.
12	Graphic communication card us properly installed and output cable is properly terminated.
13	Any obstruction to access freely of Fire Alarm Control Panel
14	Fire Alarm Panel display properly shows FIRE, Trouble/Fault as with proper location text or information. Dedicated LED also indicate accordingly.
15	During Activation of MCP Fire Alarm panel are shown proper information
16	During Activation of Gas Detector Fire Alarm panel are shown proper information
17	After Activation of Gas Detector / MCP Fire Alarm panel are alarming, When Press Silence, the System is Silenced
18	After Pressing RESET key, Fire Alarm panel is Shows "SYSTEM NORMAL"
19	Repeater Panel / Annunciator Panel are installed ?
20	Fire Alarm Signaling devices sound throughout the occupancy
21	If sounder with flasher used, flasher is working properly
22	Check During Fire alarm PA system is turn ON automatically
23	Does the actuation of any gas detection systems and other BESS alarm automatically de-energise the power supplies and isolate charging equipment?
24	Check During Fire alarm Fire damper oparate automatically
25	Check During Fire alarm Smoke damper activate / oparate automatically
26	Check During Fire alarm AHU / HVAC oparate automatically
27	Check During Fire alarm Emmergency light oparate automatically
28	Check During Fire alarm Emmergency Exit Door unlock automatically
29	Check During Fire alarm Presharization Fan working automatically
30	Check During Fire alarm FIRE signal shown in BMS system software automatically
31	Check During Fire alarm FIRE signal shown in PLC/SCADA/DCS system software automatically
32	Check Gas detector Caliberation document
33	Check Bump test Details
34	When the fire detection system was last tested?
FIRE SUPPRESSION AND PROTECTION SYSTEMS
Sl No.	Items to be Checked/Verified	Status	Comments (If Any)
1	Whether hazard detection systems for smoke, gas, heat and flame have been provided as per relevant standard and whether the same is being monitored?
2	Whether Automatic fire suppression system has been installed and tested? Type of Automatic suppression system is installed (sprinkler, gaseous, water mist, etc.)?
3	Whether the suppression system designed based on fire and explosion testing data?
4	Fire-water supply (if applicable): whether hydrants, monitors, ring main etc. checked and accessible
5	Are fire pumps available and their testing frequency?
6	Whether manual activation capability provided for suppression systems?
7	Any Tube based Protection System installed at Main Incomer / Outgoing / Control Panel
8	Protection Agent details with capacity
9	Whether portable fire extinguishers of correct type installed and maintained as per relevant standard?
10	Whether fire-extinguishers visually checked daily (or at least weekly) for external condition, pressure gauge?
11	Whether Sand buckets filled with dry sand, free of lumps, kept covered and placed in designated positions?
12	Are all PFEs accessible and properly numbered for identification?
13	Whether sufficient number of gas mask has been provided?
14	Whether gas masks are conspicuously installed and maintained at accessible places?
15	Whether an artificial respirator, fire extinguishers, first-aid boxes and gas masks have been provided and kept in good working condition and locations of the same have been displayed in the control room and operator cabin?
16	Whether address and contact number of the nearest ambulance service and fire service, Doctor, Hospital with a facility for first-aid treatment for electric shock and burns, have been prominently displayed near the electric shock treatment chart in control room and operator cabin?
MISCELLANEOUS - Maintenance
Sl No.	Items to be Checked/Verified	Status	Comments (If Any)
1	Is all BESS equipment including batteries, cooling, and ventilation, BMS, controller systems and monitoring systems along with associated equipment such inverters, transformers, gas detection systems, lightning protections etc., maintained in accordance with Original Equipment Manufacturer (OEM) and/or system installer guidelines instructions?
2	Is maintenance undertaken by competent, experienced, and accredited companies?
3	Are maintenance records regularly audited to ensure adequacy of arrangements and compliance with operating procedures, protocols etc.?
4	Is a programme of monthly self-inspections in place? Does this include: ·        External inspections of BESS enclosure, including openings vents, footings, security locks, protective seals etc? ·        External checks of the cabling systems, inverter(s), and transformer(s) for signs of damage, leaks, corrosion, water ingress etc? ·        Visual inspections of the battery racks and modules for evidence of damage, leaking, corrosion etc? ·        Visual inspections of electrical wiring, joints, connectors, junction boxes and lightning protection for evidence of wear, fraying, loose connectors? ·        Visual inspections of the ventilation and cooling systems to ensure correct functionality? ·        Visual checks of the liquid cooled systems for signs of leaks, loss of pressure and repaired/topped up as necessary? ·        Visual checks of the air cooled system including filters, airflow, and dust depositing? ·        Checks of any gas and fire detection systems and automatic fire suppression systems present for signs of damage, leaks, pressure reduction, or other performance issues? ·        Thermographic cameras checks for overheating or unusual hot spots? ·        General housekeeping checks including dust, and presence of combustible materials or waste within BESS enclosures or within 10m of the installation? ·        Alarm or fault lights?

 

As mandated under the provision of regulation 122 (L)(1) of the draft Central Electricity Authority (Measures relating to Safety and Electric Supply) (First Amendment) Regulations, 2025, an independent third-party fire safety audit of the Battery Energy Storage System (BESS) shall be conducted, as provided in the Standard Operating Procedure (SOP) to be issued by the Authority.

CEA has prepared draft Standard Operating Procedure (SOP) for conducting independent third-party fire safety audit of Battery Energy Storage System (BESS). The draft SOP is enclosed herewith. The draft Standard Operating Procedure (SOP) is also available on the CEA Website (www.cea.nic.in)

About me:

Dr. Arindam Bhadra is a Fire safety consultant & ISO Auditor based in Kolkata, India, with over 20 years of experience in Fire safety systems. He’s currently founding director of the Sprinkler Fire Safety Awareness and Welfare Foundation & SSA Integrate. He working on Fire Safety awareness, training, consultancy & Audit in same field. Dr. Arindam Bhadra is popularly known as "Fire ka Doctor" because of his expertise in fire safety, prevention, and awareness, helping people and organizations stay safe from fire hazards. He is Member of NFPA, Conformity Assessment Society (CAS), FSAI, Institution of Safety Engineers (India) etc. He is certified fire Inspector and certified Fire Protection professional.