The “Class L” Myth – Managing Lithium-Ion Risks in the Workplace

The Silent Threat in the Server Room

Consider the modern Australian office. It is 5:30 PM on a Friday. The staff have left for the weekend, leaving behind the hum of the server rack and a row of electric scooters charging in the corner of the storeroom—a perk introduced by management to encourage “green commuting.”

On the wall hangs a standard 4.5kg ABE Dry Chemical Powder fire extinguisher. It’s brand new. The tag was punched yesterday. The facility manager believes the office is fully compliant with AS 2444–2001. And legally, they might be right—for now.

But at 2:00 AM, one of the scooter batteries, degraded from months of rapid charging, experiences a micro-short in a single cell. The temperature inside the cell spikes to 120°C. The separator melts. The electrolyte vaporises. Within milliseconds, the cell enters thermal runaway.

The resulting fire doesn’t behave like burning paper or wood. It jets out a focused flame at 1000°C. It hisses like a rocket motor. Critically, it releases its own oxygen supply as the cathode decomposes. If a security guard were to rush in and empty that ABE extinguisher onto the battery, the white powder would coat the casing, but the fire would rage on, unabated, from the inside out.

This is the “Class L” gap. It is the most dangerous blind spot in Australian workplace safety today, and with the National Construction Code (NCC) 2025 mandating EV readiness, it is a risk that is about to scale exponentially.

The “Class L” Mirage | Investigating the Standard That Doesn’t Exist

A dangerous misconception has taken root in the Australian safety market: the belief that you can simply buy a “Class L” fire extinguisher to tick the compliance box for Lithium-ion batteries.

The Australian Standards Reality (AS/NZS 1850)

To understand why this is a myth, we must look at the rulebook. Australian Standard AS/NZS 1850 defines the classification of fires for which extinguishers are rated. Currently, it recognses six classes:

• Class A: Ordinary combustibles (wood, paper).

• Class B: Flammable liquids (petrol, paint).

• Class C: Flammable gases (LPG).

• Class D: Combustible metals (magnesium, lithium metal).

• Class E: Electrically energised equipment.

• Class F: Cooking oils and fats.

There is no Class L in the Australian Standards.

While you may see extinguishers marketed as “Lithium-Ion Ready” or featuring a yellow label, these are not certified to an Australian Standard for Lithium-ion fires because that standard does not yet exist. This leaves business owners in a precarious position: purchasing equipment that marketing claims will work, but for which no official pass/fail criteria exists under AS/NZS 1850.

Class D is Not for Batteries

A common error is assuming that Class D (Combustible Metals) extinguishers are suitable. This is a fatal mistake. Class D extinguishers are designed for lithium metal fires—raw, elemental lithium often found in industrial laboratories. Modern Lithium-ion (Li-ion) batteries contain very little metallic lithium; they contain liquid electrolytes and lithium salts. Using a Class D extinguisher, which is designed to crust over burning metal, does absolutely nothing to stop the chemical boiling of the liquid electrolyte inside a Li-ion battery pack.

The Chemistry of Failure | Why ABE Powder is Useless

The standard red fire extinguisher found in 90% of Australian businesses is the ABE Dry Chemical Powder unit. It is versatile, cheap, and effective against wood, petrol, and electrical fires. However, against a Li-ion battery, it is arguably worse than doing nothing.

Understanding Thermal Runaway

To manage the risk, you must understand the enemy. A Li-ion fire is a chemical chain reaction known as thermal runaway.

1. Stage 1: A cell is damaged (physically or electrically), generating heat.

2. Stage 2: The heat causes the metal oxide cathode to decompose, releasing oxygen inside the sealed shell.

3. Stage 3: The heat ignites the liquid electrolyte (fuel).

4. Stage 4: You now have Heat, Fuel, and Oxygen all trapped inside the battery casing.

The Failure of Smothering

Standard extinguishers (Powder, Foam, CO2) work by smothering—separating the fuel from the oxygen in the air.

• Why ABE Fails: You cannot “smother” a fire that generates its own oxygen. You can bury a Li-ion battery in a mountain of dry powder, and it will continue to burn underneath until the chemical reaction is exhausted.

• The Insulation Effect: Worse, dry powder acts as a thermal insulator. By coating the battery in powder, you may actually trap the heat inside, accelerating the propagation of the fire to neighbouring cells.

The NCC 2025 Curveball | “Special Hazards” and Clause J9D4

The regulatory landscape is shifting beneath our feet. The NCC 2025, published 1 February 2026, introduces strict mandates that transform the risk profile of commercial buildings.

Mandated “EV Readiness” (Clause J9D4)

Under Clause J9D4 of NCC 2025 Volume One, commercial buildings (Class 3, 5-9) must be equipped with electrical distribution infrastructure to support Electric Vehicle (EV) charging. This is not optional for new builds. This effectively mandates the introduction of high-density energy storage systems into basements and car parks that were previously designed only for inert steel and concrete.

The “Special Hazard” Trap (Clauses E1D17 & E2D21)

Because standard extinguishers don’t work, regulators like Fire & Rescue NSW and the Australasian Fire and Emergency Service Authorities Council (AFAC) have pushed for these installations to be treated as “Special Hazards”.

• The Implication: You cannot rely on the “Deemed-to-Satisfy” (DtS) tables in AS 2444. You cannot just look up a table and see “1 extinguisher per 15 metres.”

• The Requirement: You must use a Performance Solution. This requires a qualified fire engineer to assess the specific chemical load of the batteries and design a bespoke suppression strategy. If your fire safety auditor sees an EV charger next to a standard ABE extinguisher in 2026, they should flag it as a non-conformance.

The 2024-2025 Data | A Warning Shot for Australian Business

The statistics from the last 24 months provide a sobering validation of these regulatory changes.

• The NSW Surge: Fire and Rescue NSW reported a dramatic spike in Li-ion incidents, recording 323 battery fires in 2024 alone—almost one every day. This represents a doubling of incidents in just two years.

• The Insurance Reality: QBE Insurance revealed that in the 12 months leading to August 2025, they paid out over $34 million in claims specifically related to lithium-ion battery fires.

• Fatal Consequences: The risk is not just financial. The tragic death of two people in a Teralba townhouse fire in March 2024, caused by a charging battery, highlighted the lethal speed at which these fires consume a room.

Key Insight for Directors: Data from the Australian Securities and Investments Commission (ASIC) shows that corporate insolvencies hit a decade-high in 2024. For a small to medium enterprise (SME), a major fire event—exacerbated by toxic smoke contamination from a battery fire—is often a terminal blow. The business does not just lose stock; it loses operational continuity.

The Solution Stack | What Actually Works?

If “Class L” is a myth and ABE powder is useless, what should a business owner install? The answer lies in cooling, not smothering.

F-500 Encapsulator Agents

Currently, the most effective portable solution recognised by industry experts is the F-500 Encapsulator Agent.

• How it Works: Unlike foam (which creates a blanket), F-500 mixes with water to form “micelles”—tiny spheres that encapsulate the fuel molecules.

• The Cooling Factor: Critically, F-500 drastically reduces the surface tension of water, allowing it to penetrate the battery casing and cracks. It absorbs heat at a rate 6-10 times faster than plain water. By rapidly dropping the temperature below the ignition point of the electrolyte, it stops the thermal runaway.

• Recommendation: For offices with e-bikes or server rooms, replacing standard extinguishers with F-500 rated units is a robust risk mitigation strategy.

Water Mist Systems

For larger installations (like basement EV charging), high-pressure Water Mist is superior to traditional sprinklers.

• Mechanism: It creates a fog of microscopic droplets. These droplets have a massive surface area, converting to steam instantly upon contacting the heat plume. This phase change (water to steam) absorbs massive amounts of energy, cooling the fire without the conductivity risks of a solid water jet.

Fire Blankets (The Containment Strategy)

For smaller devices (laptops, phones, scooters), a specialized Li-ion Fire Blanket is an essential “first responder” tool.

• The Goal: A blanket will likely not extinguish the fire (due to the internal oxygen generation). However, it will contain the toxic plume and prevent the jet-flame from igniting the curtains, ceiling tiles, or carpet. It buys you time to evacuate.

The Insurance Nightmare | “Change of Risk” Clauses

This is the section that should make every Facility Manager sit up and take notice. Your current insurance policy likely has a “Change of Risk” or “Non-Disclosure” clause.

The Scenario: You renewed your commercial property insurance in 2023. At the time, your warehouse stored timber pallets. In 2025, you allowed staff to start parking and charging their e-bikes inside, and you installed two wall-box chargers for the company EVs. You did not notify the insurer.

The Breach: By introducing high-density chemical energy storage (Li-ion batteries) into a timber storage zone, you have fundamentally altered the risk profile of the building.

• The Consequence: If a fire starts—even if it has nothing to do with the bikes—the insurer may investigate, find the undeclared chargers, citing a breach of duty of disclosure, and void the entire policy.

Action Item: You must notify your broker immediately of any charging infrastructure or significant battery storage on site. Ask specifically: “Does our current fire suppression equipment meet your requirements for this specific hazard?” Get the answer in writing.

The WHS Hammer | Person Conducting a Business or Undertaking (PCBU)

Under the harmonised Work Health and Safety (WHS) Act, the onus is on the PCBU to eliminate risks so far as is reasonably practicable.

Ignorance is not a defence. The risks of Li-ion batteries are now “reasonably foreseeable” due to the high volume of public warnings from AFAC and WorkSafe. If a worker is injured by an exploding battery, and your risk assessment still lists “Class A/B Extinguisher” as the only control measure, you are arguably negligent.

The 2026 Standard: “Reasonably practicable” in 2026 means acknowledging that standard fire equipment is insufficient. It means training staff not to fight a battery fire with a powder extinguisher, but to evacuate and isolate.

Strategic Action Plan for 2026

To navigate the “Class L” myth and ensure genuine safety, businesses should implement the following audit immediately:

1. Map the Batteries: Conduct a physical audit. Where are the laptops charged? Where are the power tools stored? Are staff bringing e-scooters into the lift lobby?

2. Segregate Charging: Move charging stations away from egress paths. Never charge a scooter under the only fire exit sign.

3. Upgrade Extinguishers: In high-risk zones (server rooms, charging bays), install F-500 or equivalent cooling-agent extinguishers. Label them clearly: “FOR BATTERY FIRES”.

4. Install Early Warning: Standard smoke alarms are often too slow for the explosive speed of thermal runaway. Consider Aspirating Smoke Detection (ASD) in sensitive areas to detect off-gassing before the flame appears.

5. Review the “Special Hazard” Status: If you are fitting out a new office or refitting a car park, ensure your Fire Engineer addresses NCC Clauses E1D17/E2D21 explicitly. Do not accept a generic DtS solution.

The “Class L” extinguisher may be a myth, but the danger it represents is very real. As we approach 2026, Australian businesses must move beyond the “red cylinder” mentality. Compliance is no longer about having a tag on a wall; it is about understanding the chemistry of your workplace and deploying the right physics to counteract it. Don’t let a gap in the Standards become a gap in your survival plan.

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References & Further Reading:

• AGWA, NCC 2025 Adoption Dates. 

• Fire & Rescue NSW, Position Paper on EVs in Built Environment. 

• AFAC, Lithium-Ion Battery Safety. 

• QBE Insurance, Lithium-ion battery risk insights, 2025.

• Fire & Rescue NSW, 2024 Annual Fire Data Report.

• AS/NZS 1850:2009 Portable fire extinguishers—Classification, rating and performance testing.