Li-Ion Fire Position on the Latest FPA TAN-09 Update

Li-Ion Fire Position on the Latest FPA TAN-09 Update
You may have recently seen the latest revision of FPA Australia’s Technical Advisory Note TAN-09, which has now been released in its third revision.
 
It is encouraging to see constructive discussion and movement in this area. We agree that the absence of an Australian Standard specifically addressing lithium-ion battery fire risks has created uncertainty for both industry and end users. The work currently progressing through Standards Australia is necessary and should be welcomed, particularly given the complexity of lithium-ion technology and the importance of prioritising safety.
 
We wanted to take this opportunity to clearly outline Firebox’s position and to ensure customers have access to accurate, factual information.

Our Scope and Responsibility

While there is no standard, we do supply a 4L and 9L portable fire extinguishers to mitigate the risk of lithium-ion battery fires. These extinguishers comply with the Consumer Goods (Portable Non-aerosol Fire Extinguishers) Safety Standard 2021, the mandatory Australian standard for portable fire extinguishers, and are certified to AS/NZS 1841.2:2007 as water-type extinguishers. Firebox has also undertaken independent third-party testing to support the performance and safe use of these products, and we are comfortable with the outcomes of that testing. Supporting evidence is available via a link in this email for your reference.

No Lithium-Ion-Specific Australian Standard (Yet)

At the same time, it is important to be clear and transparent. There is currently no Australian Standard that provides a lithium-ion-specific fire classification or performance test for portable fire extinguishers.

Accordingly:
• Firebox does not claim compliance with a lithium-ion-specific Australian Standard, as none currently exists.
• We do not suggest that portable extinguishers are a solution for every lithium-ion fire scenario.
• Clear communication regarding appropriate use, product limitations, and operator safety remains essential.

We cannot speak for other manufacturers, suppliers, or testing methodologies. For transparency, Firebox has made its supplier test reports available and encourages customers and stakeholders to review this information and form their own view based on the evidence currently available.       

Additional information

TAN-09: Guidance, Not Regulation

It is important to note that TAN-09 is guidance only. It is not an Australian Standard, nor is it government regulation.

The disclaimer within TAN-09 makes this clear. FPA Australia states that the document represents opinion and guidance, does not accept responsibility for accuracy, and must be interpreted alongside applicable regulations, standards, certifications, and manufacturer documentation.

Current Standards Gap

The single indisputable fact is that current Australian Standards contain no test methods for lithium-ion battery fires. This is not unique. For example:

  • Australian Standards do not specify test methods for alcohol-resistant foam extinguishers, yet these are widely supplied and accepted.
  • Australian Standards do not provide test methods for fire safety systems protecting battery energy storage systems, despite such systems being routinely installed across Australia.

 International Context

Internationally, lithium-ion-specific testing is already progressing:
  • Europe: KIWA NTA 8133 is widely recognised as the accepted lithium-ion battery fire test method, with EN 3-11 expected to formalise this approach in early 2026.
  • United States: While UL 711 does not yet include lithium-ion testing, UL engineers have witnessed extinguishers tested under NTA 8133 demonstrating effective performance.
  • Asia: South Korea released a national lithium-ion fire standard in late 2024, closely aligned with NTA 8133.
Notably, these international standards do not require testing at the 100 kV threshold applied to Australian Class E extinguishers. Lower voltage limits, such as the 1000 V threshold in EN 3-7, are considered appropriate for practical lithium-ion applications.

Using a Class E-rated fire extinguisher for lithium-ion battery fires? 

In Australia, only powder, CO₂, and clean‑agent extinguishers are certified as Class E under current standards. However, all of these have been tested and found ineffective against lithium-ion battery fires. Using them on such fires poses serious safety hazards, including the potential for operator injury and significant property damage.
 
Additional considerations include:
  1. Voltage Loss During Thermal Runaway:
    A lithium-ion battery typically drops to zero voltage during or shortly before thermal runaway due to internal short-circuiting (dendrite formation).
  1. Effective Agents Are Water-Based:
    Globally, all extinguishing agents proven effective against lithium-ion battery fires are water-based, due to water’s superior heat‑absorption capability.
Examples include F‑500EA, AVD, Orchidee XF‑3000, and Kanex K36, all tested and approved to Kiwa NTA 8133.
 
  1. Electrical Safety:
    Both F‑500 and AVD extinguishers have been tested in accordance with EN 3‑7 and are verified as safe for use on electrical equipment up to 1000 V.
    For comparison:
    • Typical Li‑ion battery cells: ~3.2 V
    • EV battery modules: 300–400 V
  1. Conflict Within Australian Standards
    • AS 2444‑2001 states that water-based extinguishants (water, foam, wet chemical) are conductive and must not be used on energised electrical equipment.
    • However, AS/NZS 1841.1‑2007 clause 5.4.2 allows water-based extinguishers to be tested for Class E rating using ASTM D1125 Method A.

Beyond Portable Fire Extinguishers

Firebox’s approach to lithium-ion battery fire risk extends beyond portable fire extinguishers. We offer an evolving suite of lithium-ion fire protection solutions, recognising that no single product addresses every scenario. Since 2019, Firebox has invested in product design, innovation, and testing through recognised certification bodies, education institutions, and industry studies to better understand and mitigate these emerging risks. While this remains a developing field, we continue to refine and expand our product range based on evidence and real-world learnings. Customers are encouraged to view our full range here and to contact our team to discuss specific applications, risks, or tailored solutions.

Solutions 

 

Our Commitment

Firebox remains committed to evidence-based decision-making, transparency, and alignment with evolving standards. We will continue to actively monitor regulatory and standards developments in Australia and internationally, and as lithium-ion-specific standards are finalised, we will ensure our products, branding, and supporting information are aligned accordingly.
We welcome continued industry engagement and the development of a clear, lithium-ion-specific Australian Standard that provides certainty and improves safety outcomes for all stakeholders.
If you have any questions or would like to discuss this further, our team is available to assist.