Lithium battery risk assessment: what to cover

This is not a template to fill in — a template written for someone else’s premises is worse than no template. It is the set of questions a competent assessor works through, so you can see where your own arrangements have gaps before somebody else finds them.

1. Procurement: what is allowed on site

• Which batteries and chargers are permitted, and who decides?
• Are non-original or marketplace replacement chargers prohibited, and how is that enforced in practice rather than on paper?
• Are converted e-bikes or self-assembled packs permitted? If not, how would you know if one arrived?
• Do personal devices brought in by staff, residents or guests fall under the same rules?

This section is where the largest reduction in probability is available, and it is usually the weakest part of an existing assessment.

2. Charging

• Where does charging physically happen, and what is the relationship to escape routes, final exits and sleeping accommodation?
• How many packs are on charge at once, at what total energy content?
• Is charging supervised? If it happens overnight or unattended, what detects a problem and who responds?
• Can power be isolated quickly, and does anyone know how?
• What stops a damaged pack being put on charge?

3. Storage

• Where, how many, and at what total watt-hours? See capacity and watt-hours explained.
• What is stored next to them — cardboard, packaging, aerosols, flammable liquids?
• What is the temperature range the location actually reaches, in summer and in winter?
• Are packs stored at a controlled state of charge, and does anyone check? See storage temperature and voltage.
• Is there separation between packs, or are they in a single mass where one failure reaches all of them?

4. Damaged and waste cells

• How is damage identified — on receipt, on return, on inspection — and who is trained to spot swelling or heat?
• Where does a damaged pack go in the first five minutes after it is found?
• Is quarantine physically separate from healthy stock, and away from the building where practicable?
• How long do packs wait there, and who collects them? Waste batteries fall under the Waste Batteries and Accumulators Regulations 2009.
• If packs move between sites, have the dangerous goods transport requirements been addressed? Damaged cells attract stricter rules.

In our experience this is the section most often missing entirely. Organisations plan for storing good batteries and then improvise when a swollen one appears.

5. Detection and containment

• What would detect a failure, and how quickly? Cells vent gas before they flame, so gas detection gives earlier warning than smoke detection.
• Where does the alarm go, and who acts on it outside working hours?
• If a cabinet is part of the controls, what was it tested to, by whom, for how long, and was the fire started inside it? See the standards comparison.
• Is the cabinet actually used, or do packs sit on the bench next to it because it is inconvenient?

6. Emergency arrangements

• Does the plan name the battery scenario specifically, including that vented gas is toxic and flammable?
• Are staff instructed to evacuate and raise the alarm rather than to intervene?
• Does the fire service know what is stored and where? For significant quantities this is worth a conversation in advance.
• What is the post-incident arrangement — a pack that has been heated can reignite, so who isolates and observes it?

Recording and review

Record the reasoning, not only the conclusion. “We chose an external store rather than an internal cabinet because the only internal location available is on the escape route” is worth more in two years’ time than a tick in a box. Review when quantity changes materially, when a new battery type arrives, after any incident or near miss, and at whatever interval your general assessment cycle uses.

The HSE publishes general guidance on risk assessment that applies here as it does anywhere else. What it will not do is tell you the answer for your premises, because that depends on facts only you have.

Frequently asked questions

Do I need a separate risk assessment just for batteries?

Not necessarily a separate document, but batteries do need to be identified explicitly within your assessments rather than absorbed into a general electrical equipment entry. Where quantities are significant — a fleet depot, a bike shop, a recycling operation — a dedicated assessment is usually clearer and easier to defend than a paragraph inside a general one.

Who is competent to carry this out?

The law requires competence rather than a particular certificate. In practice that means someone who understands both the failure mode and your premises — often a fire risk assessor with battery-specific knowledge, sometimes an in-house health and safety lead with support on the technical side. If nobody involved can explain why gas detection beats smoke detection here, the assessment is unlikely to be sufficient.

How often should it be reviewed?

When something changes materially — quantity, battery type, location, process — and after any incident or near miss, including one that caused no damage. Beyond that, align it with your existing review cycle. A battery assessment that has not been looked at since stock doubled is out of date regardless of the date on it.