What Goes on the Fire: Lithium-Ion Battery Emergency Response

About this brief

This is original regulatory and documentary analysis published by M Squared Safety Solutions, Inc. It is Edition 2, dated 10 September 2026. It is the companion to our brief on the lithium-ion forklift compliance gap, which established that neither 29 CFR 1910.178 nor 8 CCR 5185 contains any mention of lithium.

This one answers the question that follows. If the regulation does not tell you what to do when the battery ignites, and the standard tells you to follow the manufacturer, then what does the manufacturer actually say, and what does the fire authority say?

New in Edition 2. On 28 August 2026, twelve days before this edition, CAL FIRE withdrew the bulletin that told Californians a lithium-ion battery fire was a Class B fire to be met with a dry chemical extinguisher. The replacement says something materially different. As far as we can establish, nobody has written that up. The first section of this brief does.

This edition is not limited to forklifts. The published guidance is written around the chemistry, not around the machine. What is in the pack drives the agent. What the pack is bolted into drives whether anyone can reach it. This brief separates those two questions, because most of the confusion in the field comes from mixing them.

Free to read, free to quote with attribution, no form in front of it.

What did CAL FIRE change on 28 August 2026?

It withdrew the Class B answer. The Office of the State Fire Marshal issued Information Bulletin 26-007, Lithium-Ion Battery Safety, on 28 August 2026. In its own words it "replaces the Office of the State Fire Marshal's (OSFM) Informational Bulletin-24-001: Lithium-Ion Battery Safety issued on January 23, 2024, and Informational Bulletin-23-003: Lithium-Ion Battery Safety issued on April 3, 2023," and "The update addresses the use of portable fire extinguishers involving lithium-ion battery fires."

Here is what the withdrawn bulletin said, verbatim:

"Lithium-ion batteries are considered a Class B fire, so a standard ABC or dry chemical fire extinguisher should be used."

Here is what replaced it, verbatim and in full:

"There are currently no ANSI/UL standards for testing and listing portable fire extinguishers for the extinguishment of lithium-ion battery fires."

"Portable fire extinguishers intended for fires involving lithium-ion batteries should be selected and installed to prevent the spread of fire to surrounding materials such as paper, cardboard, and plastics. For this purpose, a standard ABC dry chemical fire extinguisher is appropriate."

Read the second one twice. The ABC extinguisher survives, but the reason for it has changed completely. In the 2024 bulletin the extinguisher was the tool for the battery fire. In the 2026 bulletin the extinguisher is there to keep the fire off the cardboard, and California now states in writing that no listing standard exists for putting the battery itself out.

We searched the current bulletin for the phrase "Class B." It does not appear anywhere in it. Neither does Class D, neither does water, and neither does thermal runaway.

That is not a wording tidy-up. It is the state fire authority stepping back from a determination that a great many California fire prevention plans were written around.

So does that mean the extinguisher on the wall is useless?

No, and it would be a misreading of the bulletin to say so. It means the extinguisher has a narrower job than most people believe it has.

The current OSFM position is that an ABC dry chemical unit is appropriate for stopping fire spreading to the paper, cardboard and plastics around the battery. That is a real and worthwhile function. A pack in thermal runaway inside a building will ignite what is near it, and most of what burns in that room is ordinary combustible material that an ABC unit handles well.

What the bulletin no longer supports is the belief that an employee with a 10 pound extinguisher is equipped to end a lithium-ion battery fire. FIRESCOPE, the California multi-agency operational guideline body, put it more bluntly in ICS 1150, October 2025:

"A dry chemical extinguisher is ineffective for any type of lithium-ion-related extinguishment."

Those two documents now point the same way. Until 28 August 2026 they did not, and a California employer reading both would have found the state contradicting itself. The contradiction is gone. What replaced it is an admission that the tool does not exist yet.

FIRESCOPE adds two points worth carrying into any plan. On foam: "The use of foam is not recommended." On carbon dioxide: "CO2 extinguishing agents can be used to aid in cooling batteries and electrical components with some propagation control." And on detection: "Gases related to battery emergencies may not always be detected by traditional four-gas monitoring devices that are calibrated to O2, LEL/UEL, CO2, and H2S."

Does the answer depend on what the battery is bolted into?

Not for the agent. Very much for the tactics. This distinction is the most useful thing on this page and almost nobody draws it.

The agent question is a chemistry question. The evidence for that is in how the authorities write. OSFM Bulletin 26-007 makes its extinguisher statement about lithium-ion batteries as a class and never names a machine. FIRESCOPE ICS 1150 does the same. Neither document contains the words forklift, industrial truck or powered industrial truck at all. A cell in a phone, a cell in an e-bike and a cell in a forklift traction pack fail the same way, vent the same family of gases and defeat the same extinguishers.

The warning signs bear that out across the whole size range. Bulletin 26-007 tells a consumer to stop using a device if it emits "an unusual smell," develops "heat," changes "shape/geometry," behaves "abnormally," or develops "a leak or make an odd noise." The KION rescue guides for Linde and STILL industrial trucks list the indicators for a multi-kilowatt-hour traction pack as "Thick smoke, flying sparks, shooting flames," an "Abnormal, aromatic odor," "Noises (hissing, whistling, popping)," and a "Rise in temperature on the battery tray." That is the same list, written for a phone and for a forklift.

What the equipment does change is stored energy and access, and those two govern whether anything a person can carry is relevant at all.

  • Energy. A tool battery is tens of watt hours. A traction pack in a forklift, scissor lift or boom lift is thousands of times that. One can be carried outside by a person who is still calm. The other cannot be moved, cannot be starved, and will burn until it has finished.
  • Access. Water works only if it reaches the cells. The KION guides state the problem plainly: "Due to the thermal insulation of the battery cells, external cooling is not very efficient," and they direct a fog nozzle into the battery tray for that reason. A sealed steel-cased traction pack is a far harder target than an exposed pack on a bike frame.
  • Location. A pack venting outdoors disperses. The same pack venting in a charging room accumulates flammable gas in an enclosed volume, which is a different emergency with a different failure mode.

So the practical rule is short. Treat the agent question as settled by the chemistry and by the manufacturer's document for that pack. Treat the response question as settled by size and location. For anything larger than a hand-carried battery, the answer to "what do we put on it" is that nobody on site puts anything on it.

Do the responder documents actually cover industrial equipment?

Almost none of them do, and that gap has not closed.

The National Transportation Safety Board study is about electric passenger cars. The USFA and NHTSA operations guide is about electric passenger cars. The IAFC bulletin is about passenger vehicles. The research from UL's Fire Safety Research Institute is about passenger vehicles. The IAFF commissioned work is about residential energy storage. FIRESCOPE ICS 1150 does not name industrial equipment at all.

The single exception we found is the National Volunteer Fire Council's sample operating guideline, which is the only responder document that names industrial and construction equipment in its scope. It is a template with the adopting department's name left blank, and the NVFC states plainly that it "assumes no liability for the use and/or implementation of the sample SOG/SOP."

The closest published suppression testing to industrial mobile equipment, rather than to passenger cars, is the NIOSH Mining Program's work on lithium iron phosphate battery fires. That it comes from the mining research program and not from a fire service body is itself the finding.

So the responder guidance your local fire service is most likely working from was written about a car in a driveway, not a multi-kilowatt-hour pack inside an occupied building with racking over it.

What should you put on a burning lithium-ion traction battery?

There is no single published answer, and the disagreement is not at the margins. One manufacturer of lithium-ion industrial batteries lists water as unsuitable. Another lists water first. A third does not list water at all and warns that water on its electrolyte produces hydrogen fluoride.

Every entry below is quoted from the manufacturer's own published document, with the date printed on that document.

Document Date What it says to use
Crown / Triathlon Batterien, V-Force V-LI1100 lithium-ion battery system, safety data sheet 4 March 2020 Suitable: graphite powder, copper powder, fire-extinguishing powder, dry sand, ABC powder. Unsuitable for safety reasons: water, carbon dioxide, halons
EnerSys SDS 829515H, lithium ion battery module, industrial battery 20 February 2026 "Suitable extinguishing media in this order: excess of water spray, dry chemical, CO2 or foam."
EnerSys SDS EHS-HQC-SDS-012608, CN Module Gen 1.5 17 February 2026 "Use excess of water spray or foam." Dry chemicals and CO2 are "least effective"
Flux Power lithium battery pack safety data sheet No date printed "Type D extinguishers, CO2, Dry chemical or foam extinguishers can be used." Water is not listed
Toyota Material Handling, Li-Ion battery system, product data sheet and safe handling REV.01 "Cold water and dry powder in large amounts are applicable." Water is also listed under incompatible materials
Linde and STILL, KION Group, rescue guide for lithium-ion batteries in industrial trucks Version 07/2025 Water preferred, in large quantities. "Non-cooling extinguishing agents (e.g., powder or CO2) are not recommended"

Four incompatible positions, from six documents, about the same class of product. Two of them are from the same company three days apart and do not agree with each other. Note also that the state fire authority has now said in writing that no listing standard exists for any of it, which is the context in which this table should be read: the manufacturers are not disagreeing because one of them is careless, they are disagreeing because there is nothing to conform to.

The employer sitting between them still has to pick, in writing. The section on the fire prevention plan below says how.

Is the document that lists water as unsuitable really about lithium-ion?

We checked that carefully, because it is the most surprising entry in the table and the easy dismissal would be that it is a lithium metal sheet.

It is not. The document is headed "Safety Data Sheet according to OSHA HCS (29CFR 1910.1200) and WHMIS 2015 Regulations," revision 4 March 2020, twelve pages. The trade name is "V-Force Lithium-Ion Battery System, V-LI1100 Model" and it appears on every one of the twelve pages. The manufacturer is Triathlon Batterien GmbH of Glauchau, Germany, with Crown Equipment Corporation of New Bremen, Ohio as distributor.

Three further confirmations inside the document. The composition section lists lithium hexafluorophosphate, CAS 21324-40-3, at 3 to 5 percent, together with graphite and aluminum. The transport section classifies it under DOT as "Lithium ion batteries" and under ADR, IMDG and IATA as "LITHIUM ION BATTERIES." The phrase "lithium metal" does not appear anywhere in it.

The fire fighting section reads, in full and in order:

Suitable extinguishing agents: Graphite powder. Copper powder. Fire-extinguishing powder. Dry sand. ABC powder
For safety reasons unsuitable extinguishing agents: Water. Carbon dioxide. Halons.

That is a lithium-ion industrial battery safety data sheet, prepared to the OSHA hazard communication standard, telling the reader not to use water or carbon dioxide.

How far away, and for how long?

Three different quantities get quoted as though they were the same number. They are not, and mixing them up is how a plan ends up saying something indefensible.

  • Storage separation after the event. The KION rescue guides for Linde and STILL industrial trucks say to isolate the truck or battery "min 10 m away from buildings, flammable materials, and other trucks" and to protect it from direct sunlight and frost. Much of the vehicle literature uses 50 feet instead. The 2026 full-scale experiments from UL's Fire Safety Research Institute derive 5 m, which they give as 16 ft, from a radiative heat flux threshold.
  • Isolation of non-emergency personnel during the event. FIRESCOPE recommends "330 feet or 100 meters as determined by the Emergency Response Guidebook for gases." That is a different quantity from a storage distance and should never be swapped for one.
  • Duration. Only one document we found gives a number. EnerSys SDS 012608, revision 17 February 2026: "Batteries should be stored in a safe place outside (access restriction, hazard indications) for a minimum of 72 hours."

The KION guides give no fixed period at all. Their criterion is thermal: monitor the battery tray with a thermal imaging camera or infrared thermometer "until the temperature is close to the ambient temperature," with the warning that "Due to battery trays, the interior temperature can be higher than the measured exterior temperature."

Wet quarantine or dry quarantine?

Another straight contradiction, and this one has practical consequences for anyone who owns a dumpster and a hose.

The KION guides are explicit that submerging a battery as a precaution is wrong: "Preventive wet quarantine if there are no signs of an actively reacting battery must be avoided." They allow immersion only as a fallback: "In exceptional cases, the battery can be stored in a water-tight container and immersed up to its top edge. But this method requires a significant amount of logistical time and effort and should only be used in an emergency or if no dry quarantine options are available."

EnerSys goes the other way in SDS 012608: "Complete immersion into water can be used to effectively impede fire from spreading to battery cells which still have not reached the critical ignition temperature."

Both are current manufacturer documents about lithium-ion industrial batteries. The employer sitting between them has to pick, in writing, and be able to say which document governs that specific pack. That is the whole point of the exercise.

What are the warning signs before it goes?

This is the one place every source agrees, at every size of battery, and it is the most useful thing on this page for a supervisor.

CAL FIRE OSFM Bulletin 26-007 tells the user to stop operating the device or charging the battery if the battery or device does any of the following: emits "an unusual smell," develops "heat," changes "shape/geometry," behaves "abnormally," or develops "a leak or make an odd noise." Its instruction is then unambiguous: "If any of the above happens and you feel in danger, call 9-1-1. If safe, move the device away from anything that can catch fire."

The KION rescue guides list the indicators of battery involvement in an industrial truck as: "Thick smoke, flying sparks, shooting flames," an "Abnormal, aromatic odor," "Noises (hissing, whistling, popping)," and a "Rise in temperature on the battery tray."

The National Volunteer Fire Council template gives the same family of cues for re-ignition: "watch for: Arcing, Unusual noises coming from ESS, popping, crackling, hissing, etc." and warns of "the potential for explosion, rapid fire build-up, and/or fragmentation."

None of those is a fire yet. All of them are the emergency. A plan that starts at flame starts too late.

Should anyone on your crew fight it?

Our answer is no, and the published guidance supports that more strongly than most contractors expect. California's own fire authority has now removed the sentence that was most often cited to argue otherwise.

The British association guidance is unambiguous: "Where a fire may involve a lithium-ion battery, raise the alarm and immediately evacuate the area. Firefighting should only be carried out by trained personnel."

Every responder document assumes structural turnout gear and self contained breathing apparatus. The IAFC bulletin: "Wear full PPE with SCBA with face-piece." FIRESCOPE: "Ensure all personnel are wearing full structure fire PPE with a donned SCBA." The USFA and NHTSA operations guide states that with confirmed or suspected battery fires "the use of SCBA is mandatory," because the products of combustion "can include hydrogen fluoride, hydrogen cyanide, polycyclic aromatic hydrocarbons, PFAS, perfluorooctanoic acids, aromatic hydrocarbons and other known carcinogens."

Nobody on a construction site is wearing that. The employee standing in front of a venting pack with a 10 pound extinguisher has none of the protection every one of these documents treats as the baseline, and now has a state bulletin telling him the extinguisher in his hands has no listing for the job.

There is also a legal point hiding in the fire class. 29 CFR 1910.155(c) defines a Class D fire as "a fire involving combustible metals such as magnesium, titanium, zirconium, sodium, lithium and potassium." That definition is about lithium as a metal. A lithium-ion cell is a different construction, and the "lithium rated" label on an extinguisher is not a classification anyone has adopted. Bulletin 26-007 now says the same thing in the state's own words: there are no ANSI or UL standards for testing and listing portable extinguishers for lithium-ion battery extinguishment.

What about a fire blanket?

The research says it can make things worse, and equipment specific blankets are marketed on exactly the promise the research undermines.

The Fire Protection Research Foundation and the Fire Safety Research Institute issued a joint advisory on 30 May 2025 after experiments on four tactics: "While the flaming was eliminated, battery thermal runaway propagation continued after blanket deployment, which resulted in the continued release and accumulation of flammable battery gases into the volume under the blanket." The U.S. Fire Administration carried it on 11 June 2025 with the warning that "Reintroducing air into an oxygen-depleted accumulation of unburned flammable battery gases can increase the risk of an explosion."

The advisory notably does not tell responders what to do instead. It says the findings reinforce the need for continued research.

Meanwhile the KION rescue guides do recommend a blanket in one narrow circumstance, and are careful about it: "If extinguishing activities cannot commence immediately, the use of a fire blanket as per DIN SPEC 91 489 is recommended. The blanket does not extinguish the fire, but limits its spread and protects the environment. It is important to note that the fire can flare-up again after the blanket is removed and the use of extinguishing water is still necessary."

If blankets are already in your trailer, the emergency plan has to say who may deploy one and in what circumstances. For most contractors the honest answer is nobody, and never.

How much water, if water?

No manufacturer document we found gives a quantity or a flow rate. The KION guides say only that "large quantities of extinguishing water are required to ensure effective cooling and extinguishing," and that a fog nozzle should be used to get water into the battery tray, because "Due to the thermal insulation of the battery cells, external cooling is not very efficient."

Anyone quoting you gallons for a traction pack is not getting it from a manufacturer. The figures in circulation come from vehicle work and should be labeled as such. The National Volunteer Fire Council template says to expect "3000 to 8000 gallons of water per passenger Hybrid/EV" and "12000 gallons or more for commercial vehicles." The National Transportation Safety Board recorded more than 20,000 gallons applied over at least two hours in one passenger vehicle case, and a reignition five days after the crash.

And the newest full-scale work argues the opposite of the received wisdom. The Fire Safety Research Institute's August 2026 experiments on eighteen vehicles concluded that "copious application of water to the battery pack is both ineffective and unnecessary," and that disciplined application resolved incidents with far less water. That research is about passenger cars. Whether it transfers to a traction pack inside a building is not established, and we are not going to assert that it does.

Then what does the fire prevention plan actually say?

This is where it lands, and it is more workable than the mess above suggests. It is also the section that changed on 28 August 2026, because a plan that cites Bulletin 24-001 is now citing a withdrawn document.

8 CCR 3221(b)(1) requires the plan to identify the fire hazards, the ignition sources and their control procedures, and "the type of fire protection equipment or systems which can control a fire involving them." You cannot satisfy that with a generic sentence, because the published guidance does not supply one. What you can do, and what we do for clients, is five things.

  1. Check what your plan currently cites. If it references CAL FIRE Information Bulletin 24-001, or repeats the Class B and ABC extinguisher line from it, that language is superseded as of 28 August 2026 and should be replaced with the current bulletin.
  2. Name the pack. Manufacturer, model and rated capacity, and the specific emergency document that governs it, attached to the plan. Not "lithium batteries." That specific pack.
  3. Adopt that manufacturer's position and say you did. Where documents conflict, the one that governs is the one for the battery you own. Record the choice and the date, so the decision is defensible rather than accidental.
  4. Write the response as evacuate and call, not fight. Set the trigger at the warning signs rather than at flame, name who calls 911 and what they say, and state that no employee attempts suppression. State what the extinguisher on that wall is actually for, which per the current bulletin is protecting surrounding combustibles. That single paragraph is the most protective thing in the document.
  5. Decide the afterwards in advance. Where the unit goes, how far, who watches it, for how long, and who removes it. Agreeing that with a hazardous materials contractor before the event costs nothing and is impossible during one.

8 CCR 5185(b) already requires that employees assigned to work with storage batteries "shall be qualified employees and shall be instructed in emergency procedures." That duty exists today. The conflict in the source documents does not suspend it, it just means the procedure has to be written rather than referenced.

One more thing the manufacturers say that OSHA does not accept

While reading these documents we found a second conflict, and this one is between the manufacturers and the regulator.

OSHA held in a letter of interpretation dated 23 June 2021 that it "does not consider lithium-ion batteries to be articles under its HCS," because failure during use and handling can present a fire hazard and toxic contaminants can be released. The consequence is that safety data sheets, labels and hazard communication training are required.

Three manufacturers say the opposite, in the documents themselves.

  • Flux Power: "The battery is considered an article under OSHA regulations, and an MSDS is not required but provided as a courtesy."
  • EnerSys SDS 829515H, 20 February 2026: "This standard is not applicable on 'articles' Li-Ion batteries are defined as 'articles' they are exempted from the requirements of the Hazard Communication Standard."
  • Toyota Material Handling: "This battery is an article pursuant to REACH regulation 1907/2006/EC and, as such, do not require the publication of a safety data sheet." That one is a European law reference, not a reading of the American standard.

EnerSys is not even consistent with itself. SDS 012608, dated 17 February 2026, three days before 829515H, hedges the same sentence: Li-Ion batteries "are often considered 'articles', therefore they may be exempted."

For a California employer this is not an academic dispute. If your hazard communication program leaves the pack out because the supplier said no sheet was required, the person answering for that is you. Keep the sheet, train on it, and file the supplier's statement next to OSHA's interpretation so the reasoning is on the record.

What changed between Edition 1 and Edition 2

Edition 1 of this brief, published 10 September 2026, reported that two California agencies held opposing positions on dry chemical extinguishers: CAL FIRE OSFM Bulletin 24-001 recommending them, FIRESCOPE ICS 1150 calling them ineffective.

That conflict no longer exists, and we say so rather than leaving it up. Bulletin 24-001 was withdrawn on 28 August 2026 and replaced by Bulletin 26-007, which does not use the Class B classification and which limits the ABC extinguisher to exposure protection. The two California positions now agree. Edition 2 reports the change, keeps the withdrawn language on the record because plans written to it are still in circulation, and removes the claim that the state contradicts itself.

Edition 2 also widens the scope from forklift batteries to lithium-ion batteries in powered equipment generally, and adds the section separating the chemistry question from the size and access question.

How this brief was verified

Documents were read in the original. Every quotation above was taken from the manufacturer or agency document itself, not from commentary about it.

  • CAL FIRE OSFM Information Bulletin 26-007 was retrieved and its text extracted page by page. The quotations above are complete sentences from it. We searched it for the terms Class B, Class D, water, thermal runaway, forklift, industrial truck, workplace and employer. Of those, only the ones we report as present are present.
  • Bulletin 24-001 was retrieved separately so that the withdrawn language could be quoted accurately rather than recalled.
  • The Crown and Triathlon safety data sheet was verified page by page: twelve pages, native text layer, trade name carrying "Lithium-Ion" on every page, lithium hexafluorophosphate in the composition section, lithium ion battery classifications in the transport section, and no occurrence of the phrase "lithium metal." Its fire fighting section is reproduced in full above rather than excerpted.
  • ICS 1150 was searched for the words forklift, industrial truck and powered industrial truck, which do not appear in it.
  • Revision dates are as printed inside each document. Where a document carries no date, we say so rather than estimating one. The Flux Power sheet carries no date, no year and no version number anywhere in it.
  • Where a figure comes from vehicle research rather than industrial equipment research, we label it. The water volumes, the 16 foot separation and the reignition intervals are passenger vehicle findings and we do not claim they transfer.
  • We do not assert that any particular agent will or will not work on your battery. We report what each document says and who published it.

If you find an error here, tell us and we will correct it and say that we did.

How to cite this brief

Horovitz, M. What Goes on the Fire: Lithium-Ion Battery Emergency Response, Edition 2. M Squared Safety Solutions, Inc., San Clemente, California, 10 September 2026. https://msquaredsafety.com/pages/lithium-ion-battery-fire-response

This brief is versioned. If a manufacturer revises a sheet, if a further bulletin supersedes 26-007, or if a responder standard adopts a lithium classification, the edition number changes and the change is described here rather than quietly edited in.

Who wrote this

M Squared Safety Solutions, Inc. is a California occupational safety consultancy and training provider in San Clemente. This brief was written by Matthew Horovitz, Competent Person and former OSHA 500 authorized construction outreach trainer, with 20 years in risk management.

What we do about this problem. We read the emergency documentation for the specific pack on your site, write the fire prevention plan and emergency action plan language around it, record the determination where the sources conflict, and train the people who will be standing there. If your plan still cites the withdrawn bulletin, that is a twenty minute fix and we would rather you made it than not. Call 949-954-6581 or book a call.

Related guides

Primary sources

This brief describes what the standards say. It is not a fire plan, and whether any procedure is right for a particular job site and a particular battery is a determination for that employer, its own competent person, the equipment manufacturer and the authority having jurisdiction.