2026 NFPA 855 4.3.3 - Emergency Response Plan & Training

The 2026 code cycle brings updated editions of both NFPA 70, the National Electrical Code (NEC), and NFPA 855, the Standard for the Installation of Stationary Energy Storage Systems. NFPA 855 was first published in 2019, and the 2026 edition introduces new and relocated language that system designers, installers, and owners will need to understand as jurisdictions begin adopting it.

This article will focus on Section 4.3.3, which falls within the emergency planning requirements of Chapter 4 and addresses emergency response plans (ERPs) and the training associated with them. These requirements define what an ERP must include, when it must be coordinated with the authority having jurisdiction (AHJ), and when personnel must be trained on its procedures, both before an energy storage system is installed and throughout its operation.

Chapter 4 applies to every type of stationary storage

Chapter 4 of NFPA 855 sets the general requirements for the construction, installation, and design of energy storage systems before the standard moves into the technology-specific requirements found in Chapters 9 through 13. These general requirements are technology agnostic, meaning they apply to any stationary energy storage system, as well as mobile or portable systems when they are installed in a stationary configuration. While most projects today involve lithium-ion batteries, which are addressed in Chapter 9, the provisions in Chapter 4 apply regardless of the storage technology used.

Chapter 4 also covers construction documents, hazard mitigation analyses (HMAs), emergency planning, and commissioning and decommissioning requirements. Section 4.3 addresses emergency planning as a whole, with Section 4.3.3 focusing specifically on emergency response plans and training.

What changed with the 2026 edition?

The 2026 edition of NFPA 855 was published on September 9, 2025, and supersedes all previous editions of the standard, although adoption varies by jurisdiction and many projects may still be designed to the 2023 edition until the local AHJ adopts the new version. Those reviewing the standard directly can identify revisions through the markers alongside the text, where an “M” denotes relocated language and an “N” denotes new additions.

The new edition reflects lessons learned from battery deployments over the years, with updated language throughout the standard. Within Chapter 4, Section 4.3.3 is a new section that sets the requirements for emergency response plans and training, including when plans must be coordinated with the AHJ and when personnel must be trained, which the following sections cover in detail. Outside of Chapter 4, Section 9.2, Fire and Explosion Testing, is one of the sections that carries new and relocated language.

Who is responsible for emergency planning?

Section 4.3.1 places responsibility for ESS emergency planning and the associated training on the owner of the installation or the owner’s authorized representative. This responsibility extends beyond the emergency response plan itself and includes developing an emergency operations plan (EOP) along with training for the facility and staff involved in operations and maintenance.

The personnel covered by these requirements include not only those who operate and maintain the system but also the installers who put it in place. Section 4.3.2, Facility Staff Planning and Training, addresses these training requirements in further detail, while Section 4.3.3 focuses specifically on the emergency response plan and the training tied to it.

The four elements every ERP must address

At a minimum, an emergency response plan under Section 4.3.3 must address the following four elements:

• Mitigation
• Preparedness
• Response
• Recovery

These elements form the baseline of the plan, which is ultimately developed in coordination with the AHJ to reflect the specific conditions of the site.

Section 4.3.3 also requires that emergency response plans be developed in accordance with NFPA 1660, the standard that governs emergency response planning more broadly. The 2024 edition of NFPA 1660 serves as the primary reference for the detailed requirements behind each of these elements.

How the HMA feeds the ERP

Before a site-specific emergency response plan is developed, much of the product-specific groundwork has already been completed by the BESS manufacturer. In many cases, this work takes the form of a hazard mitigation analysis (HMA), another document addressed in Chapter 4. The HMA is written in technical language by a fire protection engineer and delivered to a fire protection engineer within the AHJ, and the information it contains can then be used to populate the ERP.

This process involves several stakeholders, including the BESS manufacturer and the fire protection engineers on both sides of the HMA review. Teams looking for a starting point can also reference Annex G of NFPA 855, which includes an example of what an ERP document looks like.

When must personnel be trained on the ERP?

Emergency response plans must be coordinated with and submitted to the AHJ before any required training takes place, which means much of this work happens earlier in project development than many teams may expect. The plan needs to be in place before equipment arrives on site and before the ESS is installed and commissioned.

Section 4.3.3.3 then sets the timing for training based on each person’s role. Under Section 4.3.3.3.1, personnel responsible for installing the ESS must be trained in the procedures included in the emergency response plan before the ESS arrives on site. Under Section 4.3.3.3.2, personnel responsible for operation, maintenance, repair, servicing, and emergency response must be trained in those same procedures before the ESS is commissioned.

Refresher Training and Recordkeeping

Training on the emergency response plan is not a one-time requirement. Personnel turnover is common in the operation of any facility, and Section 4.3.3.4.1 requires ESS facility operations personnel to conduct refresher training at least annually so that everyone responsible for the system remains familiar with the plan’s procedures.

Section 4.3.3.4.2 requires that records of this training be retained in an approved manner. In addition, Section 4.3.3.5 requires that emergency responders be notified of training dates and locations, keeping those who may respond to an incident at the facility informed of when and where training takes place.

Conclusion

Meeting the requirements of NFPA 855 involves coordination across manufacturers, fire protection engineers, AHJs, and project teams, often well before equipment arrives on site. Mayfield Renewables provides engineering support for solar and energy storage projects, helping teams address code requirements early in the design process.

Professionals looking to build a deeper understanding of codes and standards can also explore Mayfield Renewables’ online workshops, which offer self paced training on topics including the National Electrical Code, fire codes, and engineering standards, with NABCEP CEUs available upon completion.