# SWP - Solar PV and Energy Storage Systems > Fire Service Safety Management System, version 0.3.3 (2026-10-25). The Human Factor. Document FSSMS-SWP-27. > > Canonical: https://thehumanfactor.ca/library/fire-service-safety/swp-solar-pv-and-energy-storage-systems > > Licence: CC BY-NC-SA 4.0 with the Adopting Agency Grant (https://creativecommons.org/licenses/by-nc-sa/4.0/) > > General information only, not legal, medical or other professional advice. Verify every requirement against the current official text of the law, standards and manufacturer instructions that apply to you. Obtain your own legal review and consult your joint health and safety committee before adopting anything. You adopt, adapt, implement and rely on this material entirely at your own risk and on your own responsibility. Full terms: Terms of Use, thehumanfactor.ca. > **Warning: Adoption without implementation increases legal exposure** > > Adopting this procedure without the training, equipment, supervision, verification and resources to carry it out as written increases municipal and command liability in a regulatory investigation or a fatality inquiry. See [00a Copyright, Licence and Legal Notices](https://thehumanfactor.ca/library/fire-service-safety/copyright-licence-and-legal-notices). > **Speak up: Speak up** > > Anyone can stop this task if it looks wrong. Say the hazard, then the action: “Command, Ladder 1, there are panels on the Charlie roof and the rapid shutdown is not confirmed. Nobody goes up until the utility is on scene.” The officer acknowledges, acts, and reviews it later for learning, never for blame. The one debrief question for this task: did we treat the array as live and the battery room as full of gas until someone proved otherwise? ## 1. Task and when this applies Operating at a fire or emergency in a building, on a site or on a roof that has a solar photovoltaic (PV) array, a stationary energy storage system (ESS), or both. ESS ranges from a wall-mounted residential battery to a container at a utility site or a battery room in a commercial building. Vehicle and portable batteries are in [SWP - EV and Lithium Battery Fire](https://thehumanfactor.ca/library/fire-service-safety/swp-ev-and-lithium-battery-fire). Guidance in this area changes often; the Hazardous Materials team checks this procedure against the current guidance at least annually (MLITSD, n.d., GN 6-34; MLITSD, n.d., GN 6-53). ## 2. Hazards - **PV:** modules are energized whenever there is light, including scene lighting; the DC conductors between the array and the inverter stay live even when the utility disconnects the building, unless a rapid shutdown operates; DC arcs; shock through water streams, cut conduit and tools; roof loading, slippery surfaces and the loss of ventilation area under the array; falling modules (MLITSD, n.d., GN 6-34). - **ESS:** thermal runaway and reignition; flammable and toxic gas accumulating in a room, a closet, a garage or a container with the deflagration risk that follows; high-voltage DC; stranded energy; confined space inside containers; fire suppression systems that may discharge ([IAFF et al., 2023](https://thehumanfactor.ca/library/fire-service-safety/swp-solar-pv-and-energy-storage-systems#ref-iaff-2023); MLITSD, n.d., GN 6-53). - Off-gas treated as IDLH (MLITSD, n.d., GN 6-50). ## 3. Controls in hierarchy order | Level | Control | |:---|:---| | Elimination | Defensive operations at an ESS fire unless there is a life hazard; nobody enters a gas-filled room or container; no roof operations over or through an array | | Substitution | Exterior cooling from a distance in place of interior attack; fog streams at a distance in place of straight streams near energized equipment | | Engineering | Rapid shutdown devices; emergency stops; utility disconnect; gas detection and explosion control at the site; thermal imager and air monitoring; pre-plan and CAD flags; the owner’s emergency response plan [(NFPA 855, 2026)](https://thehumanfactor.ca/library/fire-service-safety/swp-solar-pv-and-energy-storage-systems#ref-nfpa-855) | | Administrative | This procedure; identify, shut down, watch; no overhaul of a damaged ESS; ventilation decided on the deflagration risk; watch period and handover; pre-incident plans; utility coordination | | PPE | Full structural PPE and SCBA near any battery or energized equipment; electrical limits of approach observed for ladders and aerials ([SWP - Downed Power Lines and Utility Emergencies](https://thehumanfactor.ca/library/fire-service-safety/swp-downed-power-lines-and-utility-emergencies)) | ## 4. Required PPE and equipment Full structural PPE and SCBA; thermal imager; four-gas instrument; the site pre-plan and the owner’s emergency response plan; the utility’s emergency number; fog nozzles; a water supply plan; insulated tools and dielectric gloves where carried and tested; fall protection for any roof work per [Working at Heights and Fall Protection Program](https://thehumanfactor.ca/library/fire-service-safety/working-at-heights-and-fall-protection-program). ## 5. Minimum staffing and competencies A company officer and crew trained in the annual energy-hazards session; the ISO at any ESS incident and any fire in a building with an array where roof work is contemplated; a utility representative requested at every PV or ESS incident; a hazmat officer or the ISO with hazmat operations training for an ESS fire; the site’s technical contact from the pre-plan. ## 6. Step-by-step procedure ### Identify 1. Dispatch flags from CAD: array, ESS, EV charging, chemistry and capacity where known. On the 360, look for modules, conduit, inverters, battery cabinets, container units, warning labels, rapid shutdown switches and disconnects. Say it on the radio. 2. Request the utility and the site’s technical contact. Pull the pre-plan. 3. Full PPE and SCBA for every member who approaches a battery or works near energized equipment. ### Solar PV: shut down 4. Operate the rapid shutdown where installed and labelled, and understand what it does: it de-energizes the conductors from the array to the inverter; the modules themselves remain live (MLITSD, n.d., GN 6-34). 5. The utility isolates the AC service. A building disconnect or a pulled meter does not de-energize the array or the DC conductors. 6. Treat every module, conduit and connector as live for the whole incident. ### Solar PV: operate 7. Do not cut, walk on, break, cover with tarps to “turn off”, or remove modules; do not cut conduit; do not pull wiring from an inverter. 8. Water on or near energized equipment only as a fog stream from at least 10 m, never a straight stream. 9. **Decision point: is roof work needed?** Vertical ventilation on a roof carrying an array is avoided; where unavoidable, cut only in clear areas the array does not cover, with the ISO’s agreement, fall protection in place, and the array treated as live. The array adds load and hides the roof’s condition; the rules in [SWP - Roof and Vertical Ventilation Operations](https://thehumanfactor.ca/library/fire-service-safety/swp-roof-and-vertical-ventilation-operations) apply. 10. Ladders and aerials near conductors observe the limits of approach in [SWP - Downed Power Lines and Utility Emergencies](https://thehumanfactor.ca/library/fire-service-safety/swp-downed-power-lines-and-utility-emergencies). 11. Overhaul around an array is done with the array live; damaged modules on the ground are live in daylight and are handled only with insulated tools and gloves or left for the installer. ### ESS: identify, shut down, watch 12. Identify the system: chemistry (lithium-ion NMC, LFP, flow battery, other), capacity, location (room, closet, garage, exterior wall, container), the emergency stop and disconnects, the suppression and gas detection fitted, from the labels, the owner’s emergency response plan and the pre-plan [(NFPA 855, 2026)](https://thehumanfactor.ca/library/fire-service-safety/swp-solar-pv-and-energy-storage-systems#ref-nfpa-855). 13. Shut down: operate the emergency stop and the disconnects where labelled and accessible from outside the hazard; isolate associated PV and charging; the utility isolates the AC side. A shut-down ESS still holds stranded energy and can still run away. 14. **Decision point: is the enclosure gas-filled or could it be?** Smoke, haze, hissing, a gas detection alarm, a reading at the door, or a fire inside a closed room or container all mean yes. Nobody enters. The ventilation decision is made by command with the ISO on the deflagration risk and the layout, not by habit: opening a door on a gas-filled room can trigger the deflagration, as full-scale testing has shown [(IAFF et al., 2023)](https://thehumanfactor.ca/library/fire-service-safety/swp-solar-pv-and-energy-storage-systems#ref-iaff-2023). 15. Defensive unless there is a known, specific life hazard: evacuate the affected area and exposures, protect exposures, cool the enclosure from the exterior from a distance if cooling will help, or let it burn out under watch (MLITSD, n.d., GN 6-53). 16. Thermal imager on the enclosure and air monitoring at the perimeter continuously; the watch period runs hours to days; handover to the owner’s qualified party in writing with the readings, and a return visit arrangement. 17. **No overhaul of a damaged ESS.** Nobody opens cabinets, cuts, lifts or moves modules (MLITSD, n.d., GN 6-53). 18. A residential ESS in a garage with an EV present is handled under both this procedure and [SWP - EV and Lithium Battery Fire](https://thehumanfactor.ca/library/fire-service-safety/swp-ev-and-lithium-battery-fire); the garage is treated as gas-filled until proven otherwise. > **Warning: Stop-work triggers** > > Stop and withdraw, and tell command, when: a member is about to cut, step on or cover an array; a straight stream is directed at energized equipment; a ladder or aerial is inside the limit of approach; a member proposes to enter an ESS room or container that is or may be gas-filled; the imager shows heat spreading in an enclosure; the perimeter reading reaches an action level; anyone proposes to overhaul a damaged ESS; the utility has not confirmed isolation and the plan depends on it. ### Termination 19. Readings and imager observations logged; handover record; exposure reports for every member near the battery or the array; gross decon and post-call station decon; hot debrief; triage under [Incident Investigation and Learning Program](https://thehumanfactor.ca/library/fire-service-safety/incident-investigation-and-learning-program); the pre-plan updated with what was learned. ## 7. Emergency and contingency - **Deflagration:** emergency traffic; withdraw; PAR; EHS for burns and blast injury; reassess from a greater distance. - **Member shocked:** isolate the source or pull the member clear with a non-conductive tool; cardiac emergency; EHS. - **Suppression system discharge in a battery room:** nobody enters; treat the room as oxygen-deficient and gas-filled; ventilation decision as above. - **Module fall or roof failure under the array:** mayday procedure; RIT; collapse zone below the array. ## 8. Documentation and reporting Air monitoring log; thermal imager observations with times; handover record; exposure reports; the ESS pre-incident plan ([Hazardous Materials, CBRN and Energy Hazards Program](https://thehumanfactor.ca/library/fire-service-safety/hazardous-materials-cbrn-and-energy-hazards-program) toolkit item 6) updated; near-miss reports; triage (Tier 1 every PV or ESS incident; Tier 2 any deflagration, shock, entry to a gas-filled enclosure, or reignition after handover). ## 9. Training and review Every suppression member: the annual energy-hazards session, with the guidance version recorded; officers: the ventilation and entry decision points in the annual command simulation; pre-plan walk-throughs of ESS sites with the owners annually. The Hazardous Materials team checks this procedure against new guidance at least annually. Sign-off: the program manager; consulted: the JOHSC. ## 10. Related - Program: [Hazardous Materials, CBRN and Energy Hazards Program](https://thehumanfactor.ca/library/fire-service-safety/hazardous-materials-cbrn-and-energy-hazards-program) sections 5.9 and 5.10. - Policy: [Policy - Hazardous Materials and WHMIS](https://thehumanfactor.ca/library/fire-service-safety/policy-hazardous-materials-and-whmis). - Procedures: [SWP - EV and Lithium Battery Fire](https://thehumanfactor.ca/library/fire-service-safety/swp-ev-and-lithium-battery-fire); [SWP - Downed Power Lines and Utility Emergencies](https://thehumanfactor.ca/library/fire-service-safety/swp-downed-power-lines-and-utility-emergencies); [SWP - Roof and Vertical Ventilation Operations](https://thehumanfactor.ca/library/fire-service-safety/swp-roof-and-vertical-ventilation-operations); [SWP - Hazmat Entry and Decontamination](https://thehumanfactor.ca/library/fire-service-safety/swp-hazmat-entry-and-decontamination). - Forms: [Form - Hazmat Entry Log and Air Monitoring Record](https://thehumanfactor.ca/library/fire-service-safety/form-hazmat-entry-log-and-air-monitoring-record). > **Note: Customize** > > Set the fog-stream distance after consultation with the utility, the threshold size of array that gets a pre-plan, the watch period and return visit arrangement for ESS sites, who holds the owners’ emergency response plans, and the utility’s emergency number. ## Jurisdiction requirements This chapter relies on the following legal requirements, which differ by province and territory. Check your jurisdiction’s section on each topic page before adopting it. | Topic | What to check in your jurisdiction | Page | |:---|:---|:---| | Fall Protection and Rope Access | The height that triggers fall protection for roof work | [J16 Fall Protection and Rope Access](https://thehumanfactor.ca/library/fire-service-safety/j16-fall-protection-and-rope-access) | | Lockout, Machine Guarding and Electrical Safety | The approach distances to energized conductors for equipment, ladders and aerials, and the electrical code edition adopted, including PV rapid shutdown | [J19 Lockout, Machine Guarding and Electrical Safety](https://thehumanfactor.ca/library/fire-service-safety/j19-lockout-machine-guarding-and-electrical-safety) | ## References International Association of Fire Fighters \[IAFF\], UL Solutions, & Fire Safety Research Institute \[FSRI\]. (2023). *Considerations for fire service response to residential battery energy storage system incidents*. National Fire Protection Association. (2026). *NFPA 855, Standard for the installation of stationary energy storage systems*. Ontario Ministry of Labour, Immigration, Training and Skills Development \[MLITSD\]. (n.d.). *Firefighter guidance notes* (Section 21 Advisory Committee; individual notes revised to 2026).