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Fork Lift Electrical Charging in Warehouses


Dragon100

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Dragon100

Please can we ask for a steer from you guys on a new warehouse (approx. 6,500m2) where the end user / RP has installed around 5 fork lift truck charging points.

The big question is, does the charging area need to be enclosed within fire rated / non-combustible materials?  In this situation, the charging area is completely open within the warehouse area; but the area is marked off to ensure no storage is kept within 6m.

The charging points are securely fixed to the walls (non-combustible steel profile) and has concrete floors.

The reason for the question is that local FRS have visited and performed an audit.  They have stated that fork lift charging areas should be enclosed in 30 min fire rated area??  

We have found something which an Insurance Company has produced which would reflect this but surely this is for protection of property and not Life safety critical?? 

If the insurance company for the Warehouse are happy and the FRA doesn't state it has to be an enclosed area, is this not sufficient?

Admittedly, we have no real knowledge of the fire risks relating to fork lift charging stations, so any help from you guys would be much appreciated please.

Sorry - I should have added, there IS overnight charging of the FLT's when the premises are unoccupied.  Again, assume this is a query for Insurance Company as opposed to Life safety critical?!

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Noddy

Messyshaw is our resident expert but I’ve been to quite a few buildings like yours where the forklift charging area is not enclosed. 

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Dragon100

Hi Noddy, okay, great - thank you.  I would just be interested to see if the enclosure of the forklift truck charging area is felt compulsory or best practice?

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Messyshaw

Hi Dragon.

I should put @Noddy's statement right in that I am so old I more of a 'resident' than 'expert' - but I have been working in fire safety full time for 11 years, was an inspector for 8 years and (unofficially) worked part time in a FS role for 10 years before that - unbeknown to my fire service employer😮

It is clear that there are fire safety control measures in place in relation to the forklift charging area, and you say a FRA has been completed & maintained (indeed it may have been the FRA which determined the 6m rule). So the enforcing authority are questioning the FRA's opinion about separation?

Some questions:

  1. What goods or materials are you storing in the warehouse? Could it be seen as a high fire loading, extremely flammable or perhaps is there a process carried on that would increase the risk of fire?
  2. Is there a means of escape that runs close to the charging point, or perhaps within the 6m 'combustion free zone'?
  3. If yes to 2 above, is there an alternative means of escape? And are the alternatives sufficient on terms of travel distances and widths to take the expected occupancy of the warehouse?
  4. You say the local FRS have 'stated' what they want. Have they done so in writing, and if so, in what manner? (just verbally? a 'notice of fire safety deficiency?', or is it an 'enforcement notice'?

You are correct - a FRA is all about life safety and it is not designed in any way for property protection of business continuity. That's more of an insurance/corporate policy.

It is very difficult to be precise when giving blind advice. But faced with a fairly significant charging area in a warehouse I consider: a combustible clear zone, along with adequate ventilation, strict servicing of chargers and forklifts (with records) and the provision of suitable fire fighting equipment (perhaps a 5kg CO2) 

I will wait for your reply to the questions above, but I am leaning towards questioning the FRS's advice, insofar as requesting the rationale for a 30m separation. Are you able to say which F&RS is involved??? 

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Dragon100

Hello Messy, thank you for your reply.  My thinking is the visiting officer is going OTT and possibly beyond the requirements of the FSO!  Anyway, my answers as follows:

1) The Warehouse is primarily high level racking of paper and cardboard substances - I cant explain exactly due to client confidentiality but no highly / extremely flammables, gases, cylinders, etc.

2) No - means of escape (2x perimeter exit doors) are a good distance (no less than 25-30m distance) from charging points.

3) N/A

4) Good question - the letter from FRS states the client is in breach of Article 8 - Duty to take general fire precautions.  They say on the letter that the risk of a fire caused by the forklift charging equipment should be addressed by enclosing the area in non-combustible material achieving 30-mins resistance to fire.  At the time of the inspection with the client, they said that ALL (??) forklift charging areas now have to be enclosed due to several fires starting as a result of faults.

Also, worth adding, charging points are annually inspected by engineers.

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Dangly1

I'm not aware of the specifics of the legislation, but I have been on a risk visit recently to a premises which sounds extremely similar to the one you describe. Their forklift charging points were in a specific area, enclosed with 30 minute fire resistance walls. This was a fairly recent build so it does tally up with what you have been told that this is the standard.

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Dragon100

Hi Dangly1 - thank you for your reply 👍 that is interesting to know.  This is a fairly recent build too, but as Building Control signed it off knowing that the charging points were not enclosed, I am second guessing that their is no legislative requirement to enclose the charging area, and it all comes down to risk assessment?! 

I've trawled through ADB Vol 2 and cannot see that the charging points would be deemed a place of special fire hazard (such as plant rooms would); also, the location of the charging points does not hinder means of escape if one of them caught fire, and the control measures in place such as the 6m clearance and annual testing may have led to the FRA agreeing that they could be left in open space area - again, second guessing here...

Its just interesting that the FRS are going in quite strong on the client in this situation, but we are struggling to see what legs they have to stand on?  And if we wish to challenge, how does the RP go about doing so...?

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Messyshaw
6 hours ago, Dragon100 said:

  And if we wish to challenge, how does the RP go about doing so...?

That is why my question 4 is so important. The status of the communication is critical:

  • If the advice is verbal or 'words of advice' - you can easily choose to take that advice or ignore it.
  • A Notice of Fire Safety Deficiency is not part of the legislation. Its a memo disguised to look like an enforcement notice. Its crap as in these days of open and transparent Govt, its a con. Indeed the layout can often be near identical. However it is an official communication between the fire service and the RP like a letter, but cannot be enforced or appealed. That is good news as there is no time restrictions so you can talk to the FRS in slow time
  • An Enforcement Notice is a different kettle of fish. This is the big one and the clock is already running. The enforcement authority will have put a date on the notice in which you must comply with the schedule of improvements listed. That date cannot be less than 21 days, as you have that long to serve an appeal via a Magistrate. Failure to comply with an enforcement notice is a stand alone offence in itself so DONT ignore it!!

My advice is to contact the FRS Fire Safety Team Leader by telephone (esp if an enforcement notice) and let him/her know that you do not understand the rationale as  to why this instruction has been given.  Always follow up every conversation with an email and keep everything.

Perhaps say you most certainly want a safe premises and naturally will do all you can to comply. The 6m safe area was a finding of the FRA and that area along with other measures have been maintained. Try not to mention 'Place of special fire hazard' as this may be useful as part of your appeal if it comes to it. (as I agree, a charging area is not a POSFH)

You may wish to ask for a meeting to agree on a voluntary action plan, which will save the FRS and yourselves the risk of expense if you go to appeal. This also gives the FRS a mechanism to gracefully withdraw from a poorly worded enforcement notice (if that is the case) and save face. Everyone makes mistakes, and giving them a place to safely do a U turn is better than fighting them in Court where they will feel threatened and where a bog standard Magistrate will be swayed by uniforms and the brand of the Fire Service over a paper warehouse owner

More here on appeals - Good luck and keep us informed of how you get on

Regulatory Reform (Fire Safety) Order Appeals

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Dragon100

Hi Messyshaw - the Officer who attended site advised verbally that the forklift charging area had to be enclosed, but I have now seen the letter issued post-visit and it does not specifically mention this?!  It states that Article 8 is being breached due to risk of fire occurring in forklift truck charging area, but that is it!!  No mention / explanation as to why.

My only thoughts are that, on the day of the visit, he saw something in the charging point area he didn't like.  But I know the area was clear of any combustible / flammable materials as the client has shown me the CCTV of when the Officer was walking around the site.

Definitely no form of Notice has been issued - just this letter.  No mention of follow up visit at all.

Do you think it is worth the client contacting the FRS Fire Safety Team Leader to clarify what exactly needs to be done and why this was noted?

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Messyshaw

I am still unsure of what the nature of the communication was 

A notice of fire safety deficiency AND the more formal enforcement notice would give notice of the article the issue relates to and a brief action thar is required.

This letter seems like neither. It sounds like what could be words of advice.

I would be minded to staple it to your FRA with a note/memo detailing what was said during the inspection, the fact that the notice is vague and that the advice contained in it has been considered as part of a FRA review (triggered by the advice) which found the charging points has sufficient life safety control measures .. Furthermore,  the charging points do not fit the description of places of special fire hazard that would attract separation 

Stress thar as the letter was not a NOFSD or an enforcement notice its been taken as advice and your firm welcomes the FRS support and assistance 

Thats the brave method.

The alternative is contacting the TL who is likely to support their colleagues to save face . This might end up very expensive  for your firm 

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