EV Battery Management

Emerging Trends in EV Battery Management: Illinois Moves to Tighten EV Battery Storage and Emergency Planning Requirements

STC’s Regulatory Information Services continues to lead the way in providing timely summaries that allow our clients to stay ahead of both emerging EHS trends and related compliance requirements. As an example of emerging trends with respect to the EV battery management, STC has reviewed a proposed rule from the Illinois Environmental Protection Agency (IEPA) to implement a January 1, 2025 amendment to the Illinois Environmental Protection Act that would establish new safety requirements for facilities storing more than 5,000 kg (11,023 lbs) of used EV batteries. The proposal is designed to reduce fire risk, address thermal runaway hazards, and strengthen emergency response preparedness – specifically with respect to Emergency Response Plans (ERPs).

Emergency Response Planning

This is a critical change that facilities shouldn’t gloss over and where the value of STC’s team of EHS professionals are ready to assist. Once you cross the 5,000 kg threshold, the proposal shifts from “how you store batteries” to how ready you are when something goes wrong with lithium-ion batteries, that’s the right focus given the known hazards of used EV batteries.

Under Section 1220.220, facilities must develop a formal contingency plan in collaboration with the local fire department. This requirement is intended to be much more than the typical “send a copy” to the agency obligation. Applicable sites are expected to coordinate with their local fire department with respect to the site-specific provisions of the ERP. Coordination involves walking the site, talking through access points, and making sure first responders understand the layout and hazards of the site – before an emergency happens.

The ERP must clearly spell out who at the facility is in charge and what happens during an EV battery fire. Facilities need a designated primary emergency coordinator plus alternatives, and they must be available on-call 24/7, familiar with the site, the hazards, and the response procedures.

Another big emphasis is equipment readiness and communication. Facilities must maintain an up-to-date list of emergency equipment, including fire suppression systems, spill control materials, communication systems, and decontamination equipment. Importantly, if a battery fire occurs – the proposal also tightens incident response expectations – including, Agency notification; managing contaminated runoff; documenting related injuries; materials used for suppression and environmental impacts.

Finally, the rule requires facilities to actively maintain and update the contingency plan. That means reviewing it after fires, layout changes, staffing updates, or anything else that could affect response. In other words, this isn’t a one-and-done document – it becomes a living part of operations.

Did you know?

Occupational Safety and Health Administration (OSHA) recently issued a new January 20, 2026 letter of interpretation clarifying recordkeeping requirements for lithium-ion battery injuries. The guidance explains that injuries caused by lithium-ion batteries in the workplace are generally considered work-related and must be recorded if they meet OSHA’s standard recording criteria.

The letter specifically addressed a scenario where an employee brought a personal rechargeable lithium-ion battery to work and was injured when it caught fire. OSHA concluded that the case is recordable because injuries occurring in the work environment are presumed work-related unless a specific exception applies.

These recent agency actions reinforce the importance of including lithium-ion battery hazards in hazard assessments, training, and incident tracking… especially as EV battery storage expands. STC’s team of EHS professionals is ready to help you stay ahead of emerging trends like these. Ask us about our regulatory monitoring services – and learn how we can support your broader compliance needs across EHS Auditing, Regulatory Information, Health & Safety, Management Systems & Strategies, and Remediation Oversight. Please contact Holly Pups for more details at [email protected].