Hazard Mitigation Analysis Updates – NFPA 855 (2026)

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August 07, 2026 by Hubert Biteau, PhD, P.E.

Massachusetts, along with many other states across the United States, will be adopting the 2026 Edition of NFPA 855, Standard for the Installation of Stationary Energy Storage Systems. Under previous editions of this standard, a Hazard Mitigation Analysis (HMA) was required only for electrochemical Energy Storage Systems (ESS), including those utilizing Lithium-ion technology, when the ESS’s maximum stored energy exceeded 600kWh. This threshold has been removed, and as such, an HMA should be provided to the AHJ for any indoor or outdoor ESS installation for which the 2026 edition of NFPA 855 is applicable.

Hazard Mitigation Analysis Requirements

The HMA must evaluate the consequences of the following single failures:

  1. Thermal runaway or mechanical failure of a single ESS unit,
  2. Failure of the energy storage management system or protection system,
  3. Failure of a required and/or critical system (thermal management, communication, Battery Management System) that impacts normal operations.

To obtain approval from the Authority Having Jurisdiction (AHJ), the HMA must show that:

  1. Deflagration hazards are suitably mitigated.
  2. A fire involving an indoor ESS does not spread beyond the ESS room for the minimum duration of its compliant fire resistance rating.
  3. Fire and combustion products do not prevent occupant evacuation.

Key Changes in the 2026 Edition

The major revision to the HMA in the 2026 Edition of NFPA 855 involves the evaluation of the consequences related to a thermal runaway failure, which are dependent on the mitigation strategy put in place through fire and explosion (1) prevention, (2) protection, and (3) policy barriers. Therefore, the 2026 Edition of NFPA 855 now requires reliability and survivability analyses for critical safety component systems, including but not limited to the explosion control and prevention system, smoke/fire detection, and fire suppression. These analyses must demonstrate that fire and explosion hazards are suitably mitigated in the event of a thermal runaway.

How Code Red Consultants Can Help

Code Red Consultants helps owners, developers, designers, utilities, and AHJs navigate the evolving requirements associated with energy storage systems. Our team evaluates applicable code and fire protection requirements, identifies compliance challenges early, and supports practical solutions that align with project goals and regulatory expectations. With technical expertise and experience across a wide range of ESS technologies, we help project teams manage risk and advance projects with confidence.

Application of any information provided, for any use, is at the reader’s risk and without liability to Code Red Consultants. Code Red Consultants does not warrant the accuracy of any information contained in this blog as applicable codes and standards change over time. The application, enforcement and interpretation of codes and standards may vary between Authorities Having Jurisdiction and for this reason, registered design professionals should be consulted to determine the appropriate application of codes and standards to a specific scope of work.