The Lithium-Ion Forklift Compliance Gap

About this brief

This is original regulatory analysis published by M Squared Safety Solutions, Inc. It is Edition 2, dated 10 September 2026. It sets out a specific finding: the American standards that govern powered industrial trucks do not address lithium-ion batteries, while the European standard, the international standards and the industry's own trade associations all do.

We wrote it because we kept meeting the same situation. A contractor replaces a propane or lead-acid fleet with lithium-ion, reasonably assumes the forklift standard covers it, and discovers during an inspection or after an incident that the standard is silent and the obligation sat in documents nobody updated.

Everything below is sourced. Every regulatory quotation was read against the operative text of the regulation rather than recalled or taken from commentary, on the date shown. Where we could not verify something to that standard we left it out and said so. The verification method is set out at the end, and so is the list of what we deliberately did not claim.

New in Edition 2. A companion brief, What Goes on the Fire, sets out what we found when we read the manufacturers own emergency documents: six documents, four incompatible answers on extinguishing agent. It also reports that CAL FIRE withdrew its Class B extinguisher guidance on 28 August 2026 and replaced it with a bulletin stating that no listing standard exists for extinguishing a lithium-ion battery fire. Edition 2 also adds the manufacturers counter-position on safety data sheets below.

It is free to read, free to quote with attribution, and there is no form in front of it.

Does OSHA have a standard for lithium-ion forklifts?

No. The words lithium, lithium-ion and thermal runaway do not appear anywhere in 29 CFR 1910.178, the federal powered industrial truck standard. There is no lithium section, no charging provision written for sealed packs, and no emergency procedure for a cell in thermal runaway.

The standard is older than the technology. Paragraph (a)(2) requires that all new powered industrial trucks "meet the design and construction requirements for powered industrial trucks established in the American National Standard for Powered Industrial Trucks, Part II, ANSI B56.1-1969." That is a 1969 design standard. Commercial lithium-ion cells post-date it by more than two decades.

OSHA proposed replacing that reference on 16 February 2022 at 87 FR 8755, docket OSHA-2020-0008. As of 10 September 2026 the operative text still reads ANSI B56.1-1969, and the proposal itself never mentioned battery chemistry.

California is no different on the chemistry. 8 CCR 5185, Changing and Charging Storage Batteries, was last substantively amended in 2015 and contains no mention of lithium. Neither does 8 CCR 5184, Storage Battery Systems.

Has anyone written rules for this?

Yes. Europe, the IEC and the manufacturers' own trade associations have all done it. The United States regulator has not. That is the gap, and it is a matter of dates rather than opinion.

Date Who What
1969 ANSI B56.1-1969, the design standard OSHA still incorporates by reference today
October 2018 British Industrial Truck Association Guidance Note GN69, Lithium-Ion Traction Battery Applications
31 July 2020 CEN EN 1175:2020, Safety of industrial trucks, electrical and electronic requirements, with Annex C.2 titled Lithium-ion batteries
January 2021 IEC IEC 62485-6:2021, Safe operation of lithium-ion batteries in traction applications
16 February 2022 OSHA Proposes updating the B56.1 reference. Battery chemistry is not mentioned
24 May 2022 IEC IEC 62619:2022 Edition 2.0, industrial lithium cells and batteries, naming forklift trucks
16 August 2024 MHI Advanced Energy Council Lithium-Ion Battery Safety Guidelines and Best Practices for Operation in Electric Lift Trucks
10 September 2026 OSHA and Cal/OSHA 29 CFR 1910.178 and 8 CCR 5185 still contain no mention of lithium

Read that column of dates again. The industry wrote its own guidance eight years ago. The European standard has carried a lithium-ion annex for six years. The international standard for lithium-ion traction batteries names lift trucks by name. The American rule that a Cal/OSHA inspector will open still describes pouring acid into water.

What does the European standard cover that the American one does not?

EN 1175:2020 specifies the electrical requirements for the design and construction of the electrical installation in self-propelled industrial trucks. It was published on 31 July 2020, superseded the three-part EN 1175 series from 1998, and required conflicting national standards to be withdrawn by July 2022. Lithium-ion batteries have their own annex, C.2. A 2025 edition has since followed.

IEC 62485-6:2021 goes further and is the single most on-point document in the world for this equipment. Its title is Safety requirements for secondary batteries and battery installations, Part 6: Safe operation of lithium-ion batteries in traction applications. It applies to battery installations used for electric off-road vehicles, and the applications it names include cleaning machines, material handling trucks (lift trucks, tow trucks, automated guided vehicles) and electrically propelled lifting platforms.

IEC 62619:2022, Edition 2.0, published 24 May 2022, sets safety requirements for secondary lithium cells and batteries for industrial applications, and names the forklift truck among its motive power uses.

None of those three is referenced anywhere in 29 CFR 1910.178, 29 CFR 1926.602 or 8 CCR 3650. California incorporates NFPA 505-2006 and UL 583-1996 by reference. Both pre-date the technology.

Is the American industry aware of the gap?

The manufacturers say so out loud. At a MODEX 2024 panel reported by MHI with Hyster-Yale Group, UgoWork and Stanbury Electrical Engineering, the assessment was blunt: "The trend is happening so fast that standards are having trouble catching up," and on the electric truck standard itself, that UL 583 "is more driven for the technology before lithium became a thing."

The panel also put the open question plainly: "How do we adapt the (UL) 583 truck standard to also include lithium?"

Meanwhile the standard the American market leans on for the pack itself is ANSI/CAN/UL/ULC 2580, Standard for Safety for Batteries for Use In Electric Vehicles. It is an electric vehicle battery standard being applied to lift trucks because there is no lift truck equivalent.

This matters for how you read the gap. It is not that nobody knows what to do. The manufacturers and the associations know exactly what to do and have written it down. The regulation has not caught up, so none of it is what an inspector will cite, and none of it lands in your program unless you put it there.

What do the trade associations actually tell operators to do?

The clearest single document in the English language is Guidance Note GN69, Lithium-Ion Traction Battery Applications, issued by the British Industrial Truck Association in 2018 and now published by the UK Material Handling Association. It covers specification, transport, storage, charging, handling, use, inspection, maintenance and disposal, for forklifts, reach trucks, powered pallet trucks, tow tractors, scrubbing machines and lifting platforms.

Four instructions from it are worth having in front of you.

  • The battery management system is not optional. "Charging of Li-ion batteries must be carried out via the Battery Management System (BMS). The BMS should never be bypassed or disabled."
  • Damaged means out, immediately. "Batteries that show mechanical damage or signs of gaseous or liquid discharge must immediately be removed from service."
  • Do not fight it yourself. "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."
  • Charging location is a siting decision. "A safe location for charging should be identified where equipment and cables don't cause an obstruction."

The guidance cites BS EN 62619:2017, BS EN 62620:2015, BS EN 62281:2017 and BS EN 62485-3:2014. Not one of those appears in an American safety order.

The ventilation rule is aimed at a gas this battery does not produce

This is where the mismatch stops being academic. GN69 states plainly: "Lithium-ion batteries do not generate hydrogen gas during charging ... No special ventilation is required."

Now read what the American rules require. 1910.178(g)(2): "Facilities shall be provided for flushing and neutralizing spilled electrolyte, for fire protection, for protecting charging apparatus from damage by trucks, and for adequate ventilation for dispersal of fumes from gassing batteries." 8 CCR 5185(c): ventilation "to prevent concentrations of flammable gases from exceeding 20% of the lower explosive limit."

Both are hydrogen rules. They control a hazard that a sealed lithium-ion pack does not present in normal charging, and neither says a word about the hazard it does present, which is a cell going into thermal runaway and venting flammable gas in a failure.

An employer who satisfies the ventilation requirement has not addressed the fire risk. An employer who assumes the ventilation requirement no longer applies has made a determination that needs to be written down and justified rather than assumed.

Which rules still apply to a forklift on a California construction site?

Four layers, and contractors routinely miss the first one.

  • Design and construction. 29 CFR 1926.602(c)(1)(vi) provides that "All industrial trucks in use shall meet the applicable requirements of design, construction, stability, inspection, testing, maintenance, and operation, as defined in American National Standards Institute B56.1-1969." California is stricter: 8 CCR 3650 requires trucks built after 15 March 2009 to be labeled as meeting ANSI/ITSDF B56.1-2005 and, where applicable to the truck, NFPA 505-2006 and UL 583-1996. All three are incorporated by reference into the section.
  • Operator training. 8 CCR 3668 in California and 29 CFR 1910.178(l) federally. The construction requirement is identical to the general industry one.
  • Charging. 1910.178(g) federally, 8 CCR 5185 in California, with 8 CCR 5184 for battery systems.
  • The written programs. The Injury and Illness Prevention Program, the emergency action plan and the fire prevention plan. This is where the lithium hazard actually has to be handled, because the equipment standards do not handle it.

Why do the battery charging rules not fit a lithium-ion pack?

Because every one of them was written for a flooded lead-acid battery. A carboy tilter or siphon for handling electrolyte at 1910.178(g)(6). Acid poured into water and never the reverse at (g)(7). Vent caps at (g)(9).

California reads the same way. 8 CCR 5185(f) governs mixing electrolyte. Subsection (g) covers taking hydrometer specific gravity readings. Subsection (n) requires eyewash and drenching facilities unless the batteries have flame arrestor vents or are located to preclude exposure.

What does survive the chemistry change is the part about location and control: charging in a designated area, protecting the charger from being struck by trucks, the truck positioned with the brake set, no smoking, and no open flames, sparks, static discharge or arcs. Build the site rule on those and on the manufacturer's instructions, and record why the rest is inapplicable.

Does the rule about opening the battery cover apply to a lithium pack?

This is the sharpest conflict in the regulation and it needs an answer in writing before anyone charges a truck. 1910.178(g)(9) says "Care shall be taken to assure that vent caps are functioning. The battery (or compartment) cover(s) shall be open to dissipate heat." 8 CCR 5185(m) says "When charging batteries with vent caps, the vent caps shall be kept firmly in place to avoid electrolyte spray. The battery compartment cover(s) shall be open to dissipate heat."

A sealed lithium-ion pack has no vent caps and is not designed to be opened by an operator. Its thermal management is engineered into the pack and its battery management system, which GN69 says must never be bypassed or disabled.

The way out is not to ignore the rule. Follow the manufacturer's written instructions for that specific pack, record why the vent cap and open cover provisions are inapplicable to a sealed system, and keep it in the equipment file. 1910.178(q)(6) already prohibits altering a truck from the condition in which it was received from the manufacturer, which is what makes those instructions load bearing rather than advisory.

Is there a small battery exemption a forklift pack could use?

No. 8 CCR 5185(p) exempts "Batteries and battery charging equipment of less than 100 watt hours" from the vent cap requirement for batteries being moved. A lithium-ion forklift pack is measured in kilowatt hours, orders of magnitude above that.

The 100 watt hour figure is worth knowing for a different reason. It is the same order of magnitude as the tool batteries, power banks and survey equipment in the job trailer, which is where most lithium fires on a construction site actually start. The exemption covers a vent cap rule, not the fire hazard.

What is thermal runaway, and why does it break a conventional fire plan?

Thermal runaway is a self-sustaining reaction inside a failing cell. The cell generates heat faster than it can shed it, the heat propagates to neighboring cells, and it needs no external ignition source to continue.

  • It vents flammable gas. The U.S. Fire Administration warns that "Reintroducing air into an oxygen-depleted accumulation of unburned flammable battery gases can increase the risk of an explosion."
  • It reignites. Fire Safety Research Institute guidance is to "Assume persistent reignition risk," and before releasing a scene to "Inspect for signs of active thermal runaway, including smoke, audible cues, and increasing temperature."
  • It leaves stranded energy. Charge remains in undamaged cells after the event.

A plan that says extinguish, ventilate and resume work does not survive any of the three.

What do the manufacturers themselves say to do when one ignites?

At least one manufacturer publishes a rescue guide for exactly this, and it is more specific than anything in the regulations. Linde Material Handling's rescue guide for lithium-ion batteries in its industrial trucks is worth reading in full. The instructions that matter most:

  • Recognition. "Thick smoke, flying sparks, shooting flames," an "Abnormal, aromatic odor," and "Noises (hissing, whistling, popping)," with temperature rising at the battery tray.
  • Extinguishing media. "Large quantities of extinguishing water are required to ensure effective cooling and extinguishing," and "Non-cooling extinguishing agents (e.g., powder or CO2) are not recommended."
  • Temperature. Monitor cooling with thermal imaging, remembering that "Due to battery trays, the interior temperature can be higher than the measured exterior temperature."
  • Afterwards. Batteries "may self-combust or reignite after a fire has been extinguished."
  • Quarantine. A damaged battery goes "min. 10 m away from buildings, flammable materials, and other trucks" and is protected from weather.
  • Runoff. Extinguishing water "can be contaminated with lithium as well as the heavy metals cobalt, nickel, and manganese."

Read the second bullet next to the extinguisher hanging on the truck. Dry chemical and carbon dioxide are the two agents most likely to be within reach on a job site, and the manufacturer says neither is recommended, because neither cools.

Can a jobsite fire extinguisher put out a lithium-ion forklift fire?

Do not assume the extinguisher on the truck is the answer, and do not assume a Class D unit is either. The Class D confusion comes from the word lithium appearing in two different places.

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 is lithium as a combustible metal. A lithium-ion cell is a different construction, and a burning pack presents flammable electrolyte, plastics and casing, and energized electrical equipment at once.

What the fire research bodies recommend is water. Fire Safety Research Institute guidance for responders is to "Use water from a handline; added suppression agents are not required." That matches the manufacturer guidance above, which asks for large quantities of water for cooling.

A handline is not a 10 pound extinguisher and it is not a task for a framing crew. For most construction sites the correct procedure is to get people away and let the fire service do it. Any on-site extinguishing equipment should be selected from the pack manufacturer's instructions and your authority having jurisdiction, not from a category name.

Is a fire blanket a good idea on a lithium-ion battery?

The U.S. Fire Administration issued an advisory on 11 June 2025 warning that it can create an explosion hazard. A blanket smothers visible flame, but the cells keep running away and keep producing flammable gas, which accumulates in an oxygen-depleted space. Air re-entering that space is the hazard.

Read the advisory before anyone buys blankets on the strength of a product page. If they are already in the trailer, the emergency plan needs to say who may deploy one and when, which for most contractors will be nobody and never.

What should happen when a lithium forklift starts venting or burns?

The sequence below combines the emergency requirements that already apply with the published manufacturer and response guidance. It is a template. Your competent person writes the site plan.

  1. Treat the warning signs as the emergency. Smoke, popping or hissing, a sweet or solvent odor, or a hot battery tray are pre-fire indicators, not a maintenance question.
  2. Raise the alarm and evacuate. GN69 is unambiguous that firefighting "should only be carried out by trained personnel." 8 CCR 3220(b)(1) and (b)(3) already require evacuation procedures and procedures to account for all employees afterward.
  3. Call 911 and say the words lithium-ion. Have the manufacturer, model and rated capacity ready.
  4. Keep people upwind and clear. The vented gas is the hazard, not just the flame.
  5. Do not move the truck and do not load it on a trailer while it is an active event.
  6. Do not close it out early. Reignition is the assumption, not the exception.

All of it has to exist on paper before the day it is needed.

What happens after the fire is out?

The pack stays dangerous. The manufacturer guidance is a minimum of 10 m from buildings, flammable materials and other trucks, protected from direct sunlight and frost. Fire Safety Research Institute guidance for a vehicle after a battery fire is to "Escort the tow truck with a suppression unit and maintain a minimum 5 m (16 ft) quarantine distance at the tow yard."

  • Isolation and watch. Separation from structures, vehicles, fuel and anything combustible, and somebody looking at it.
  • Removal from service. 1910.178(p)(1): "If at any time a powered industrial truck is found to be in need of repair, defective, or in any way unsafe, the truck shall be taken out of service until it has been restored to safe operating condition." 8 CCR 3650(t)(7) puts the same duty on the start of shift check.
  • Runoff. Extinguishing water can carry lithium, cobalt, nickel and manganese, which makes it a waste handling question rather than something to hose into the street.
  • Disposal and transport. A damaged pack is a regulated item to move. That is a conversation with the manufacturer and a qualified hazardous materials contractor before anyone loads it.

What does California require a contractor to have in writing?

Bringing a lithium-ion truck onto a site is a new hazard, and California treats a new hazard as a trigger rather than an option.

  • 8 CCR 3203(a)(4)(B): the Injury and Illness Prevention Program requires inspections to identify and evaluate hazards "Whenever new substances, processes, procedures, or equipment are introduced to the workplace that represent a new occupational safety and health hazard."
  • 8 CCR 3220: the emergency action plan, in writing, covering evacuation procedures and exit route assignments, accounting for employees afterward, rescue and medical duties, and the preferred means of reporting fires.
  • 8 CCR 3221: the fire prevention plan, in writing, listing "potential fire hazards and their proper handling and storage procedures, potential ignition sources (such as welding, smoking and others) and their control procedures, and the type of fire protection equipment or systems which can control a fire involving them."
  • 8 CCR 1920(a): on construction, a fire protection program followed throughout all phases of the work, with a note that more restrictive local orders prevail.
  • 8 CCR 1922: extinguisher coverage, including a 2A rated extinguisher for each 3,000 square feet of floor area and a travel distance to the nearest extinguisher of no more than 75 feet.

Because the equipment standard does not name the hazard, these documents are where the hazard gets named. If the fire prevention plan does not list the battery with a handling procedure, it is incomplete on its face the day the truck arrives.

What has to be added to operator training?

Charging is already a required training topic, and the switch to lithium is already a refresher trigger. Both sit in 8 CCR 3668 and both are commonly missed.

  • (c)(1)(K) requires initial training on "Refueling and/or charging and recharging of batteries."
  • (c)(1)(M) requires training on "Any other operating instructions, warnings, or precautions listed in the operator's manual for the types of vehicle that the employee is being trained to operate." For a lithium truck, the manual is where the real requirements live.
  • (c)(2)(I) requires training on "Other unique or potentially hazardous conditions in the workplace that could affect safe operation."
  • (d)(1)(D) requires refresher training when "The operator is assigned to drive a different type of truck," and (d)(1)(E) when "A condition in the workplace changes in a manner that could affect safe operation of the truck."

An operator certified on a propane truck is not certified on the lithium unit that replaced it. Subsection (f) requires the employer to certify each operator by name with the date of training, the date of evaluation and the identity of the person who performed them, and (d)(2) requires an evaluation at least once every three years.

Do lithium-ion batteries need a safety data sheet?

Yes, and OSHA has said so directly. In a letter of interpretation dated 23 June 2021, OSHA concluded that it "does not consider lithium-ion batteries to be articles under its HCS," because cell or battery failure during use and handling can present a fire hazard and toxic air contaminants can be released when the battery is damaged or catches fire.

The article exemption therefore does not apply, and hazard communication obligations do: safety data sheets, compliant labels and employee training. If your hazard communication program has no SDS for the pack, that is a gap you can close this week.

Be ready for your supplier to tell you otherwise. Reading the manufacturers' own sheets for the companion brief, we found three of them asserting the article exemption in the very documents OSHA's position says are required. 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, revision 20 February 2026: Li-Ion batteries "are defined as 'articles' they are exempted from the requirements of the Hazard Communication Standard." Toyota Material Handling cites the European REACH regulation to the same effect.

EnerSys is not consistent with itself on it. Its SDS 012608, dated three days earlier, hedges the same sentence to "often considered" and "may be exempted." Keep the sheet, train on it, and file the supplier's statement alongside OSHA's interpretation. The details are in What Goes on the Fire.

Is a lithium-ion battery injury recordable?

Yes, if it meets the general recording criteria. OSHA issued a letter of interpretation on 9 February 2026 stating that if a work-related injury caused by a lithium-ion battery meets one or more of the general recording criteria in 29 CFR 1904.7, it must be recorded on the OSHA logs.

The letter addressed injuries from personal rechargeable batteries, which is the more surprising half of it. Recordability does not turn on whether the employer supplied the battery. See the OSHA release.

Where can the truck be charged on a job site?

Start with the two provisions that survive the chemistry change. 1910.178(g)(1) requires that "Battery charging installations shall be located in areas designated for that purpose," and 8 CCR 5185(b) says the same and adds that "Employees assigned to work with storage batteries shall be qualified employees and shall be instructed in emergency procedures."

That last clause is the one to build on. Instruction in emergency procedures is already required of anyone working with the batteries, and for lithium-ion the emergency procedure is exactly the part the equipment standards do not write for you.

Beyond that, charging location is a fire code question as much as a Cal/OSHA question. The 2025 California Fire Code carries a Section 320 addressing battery storage, and local amendments and the authority having jurisdiction can be stricter. Confirm the location with your AHJ before the charger is set. 8 CCR 1920 carries a note that where orders of local jurisdiction are more restrictive, those orders prevail.

How do you check whether your own program has this gap?

Twelve items. Each one is a document or a determination that has to exist somewhere, and each one names the provision that creates the duty. If you cannot put your hand on it, that is the gap.

  1. A written hazard evaluation done when the truck arrived. 8 CCR 3203(a)(4)(B), triggered by new equipment representing a new hazard.
  2. A fire prevention plan that names the battery. 8 CCR 3221(b)(1) requires the fire hazards, the ignition sources and their control procedures, and the fire protection equipment that can control a fire involving them.
  3. An emergency action plan with a lithium sequence in it. 8 CCR 3220(b), including accounting for all employees after evacuation.
  4. A construction fire protection program that covers the charging area. 8 CCR 1920(a), across all phases of the work.
  5. A designated charging location, confirmed with the authority having jurisdiction. 1910.178(g)(1) and 8 CCR 5185(b), plus the fire code.
  6. A written determination on the vent cap and open cover provisions. 1910.178(g)(9) and 5185(m) tell you to open the battery compartment. Say in writing why that does not apply to a sealed pack, on the manufacturer's authority.
  7. A written determination on the gassing ventilation provisions. 1910.178(g)(2) and 5185(c) control hydrogen. Say what you did instead about the hazard that does exist.
  8. The manufacturer's operating and emergency instructions, on site, in the equipment file. 1910.178(q)(6) and 8 CCR 3668(c)(1)(M).
  9. Operator refresher training and a fresh evaluation for the new truck type. 3668(d)(1)(D) and (d)(1)(E), certified under (f) with names and dates.
  10. Named qualified employees instructed in emergency procedures for battery work. 5185(b), which requires this already and is the hook the lithium procedure hangs on.
  11. A safety data sheet for the pack in your hazard communication program. Required because OSHA has held that lithium-ion batteries are not articles, and required even if your supplier tells you otherwise.
  12. A damaged pack procedure. Removal from service under 1910.178(p)(1) and 8 CCR 3650(t)(7), an isolation distance, a watch, and a disposal and transport route agreed before you need it.

In our experience the first four are the ones that are missing, and item six is the one nobody has ever written down.

What is the honest summary for a contractor?

The gap is real, it is documented, and it does not protect you.

The equipment standards were built around a battery that leaks acid and vents hydrogen. The battery you are buying does neither, and fails in a way those standards never contemplated. Europe wrote lithium-ion into its industrial truck standard in 2020, the IEC published a standard for lithium-ion traction batteries in lift trucks in 2021, the British association issued guidance in 2018, and the American industry group published its own in 2024. The American regulation has not moved.

None of that removes liability. It moves it. Because the standard does not name the hazard, the hazard has to be named in your Injury and Illness Prevention Program, your emergency action plan, your fire prevention plan, your operator training file and your equipment file, using the manufacturer's instructions as the source. Those are all documents an inspector can ask for, and the general duty to provide a safe workplace does not wait for a rulemaking.

If you want a second set of eyes on those documents before the truck shows up, call 949-954-6581 or book a call.

How this brief was verified

Method matters more than conclusions, so here is ours.

  • Regulations were read, not recalled. Every quotation from 29 CFR and from Title 8 was taken from the operative text on 9 and 10 September 2026. Twelve of the California quotations on this page were additionally checked character by character against captured copies of the section text.
  • The rulemaking record was checked, not assumed. The status of the 2022 proposal to update the design standard was confirmed against the Federal Register notice, the regulatory agenda entry and the current CFR text.
  • Association and manufacturer documents were read in the original. The guidance note, the standards catalogs and the rescue guide are linked below so you can check us.
  • We refused to publish what we could not verify. No incident statistics appear anywhere on this page, because none of the figures in circulation could be traced back to a raw source we could recompute. We do not claim that a Class D extinguisher will not work, because we did not verify that against NFPA 10. We do not quote California Fire Code Section 320 thresholds, because the code text was not retrievable. We do not characterize the contents of the American industry guidance beyond confirming it exists and is dated 16 August 2024.

If you find an error in this brief, tell us and we will correct it and say that we did. That is the standard we hold our client documents to and it is the standard this page is held to.

How to cite this brief

Quote it, link it, use it in a toolbox talk, hand it to your insurer. No permission needed. If you are citing it formally:

Horovitz, M. The Lithium-Ion Forklift Compliance Gap, Edition 1. M Squared Safety Solutions, Inc., San Clemente, California, 10 September 2026. https://msquaredsafety.com/pages/lithium-ion-forklift-safety-california

This brief is versioned. When the standards move, and they will, the edition number and the date at the top change and the change is described here rather than quietly edited in. If OSHA finalizes the design standard update, if the California Fire Code section is confirmed, or if UL 583 or ANSI/ITSDF B56.1 add lithium provisions, this page gets a new edition.

Who wrote this

M Squared Safety Solutions, Inc. is a California occupational safety consultancy and training provider in San Clemente. We write safety programs, fall protection plans and site audits for construction and general industry, and we deliver the training that goes with them.

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 write the hazard evaluation, the fire prevention plan language, the emergency action plan sequence and the operator training file for contractors bringing lithium-ion equipment onto a site, and we do the written determinations at items six and seven of the check above, which is the part that has no template anywhere. If that is the position you are in, 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.