RIVM maps out safety risks of battery storage, ESNL warns against unnecessary objections

Today, RIVM published a new calculation method to map the environmental safety risks of energy storage systems (EOS) and the storage of lithium-ion batteries. The method was developed on behalf of the Ministry of Infrastructure and Water Management (IenW) and will be included in future legislation and regulations in this area . Energy Storage NL is concerned about the practical feasibility and that unnecessarily long safety distances will apply to battery systems.

Reason for the investigation

The rise of large-scale energy storage systems in the Netherlands, such as batteries based on lithium-ion technology, has drawn attention to their potential risks to the environment. In 2023, the RIVM was commissioned by the Ministry of Infrastructure and Water Management to investigate whether these systems pose relevant safety risks to the external environment, particularly in the event of incidents such as explosions or the release of toxic substances.

The study is an addition to the so-called Publication Series on Hazardous Substances (PGS37-1), which sets out guidelines for the safe handling of hazardous substances, including lithium-containing energy carriers (batteries) above 20kWh. The insights from the RIVM study are intended as scientifically substantiated advice to the Ministry of Infrastructure and Water Management, which uses them to make policy choices and ultimately draw up new regulations.

The calculation method developed by RIVM can be used to calculate the safe distances that must be maintained between these storage systems and vulnerable objects, such as homes, schools and hospitals.

Conclusions and proposals of the RIVM

The RIVM concludes that energy storage systems can indeed pose risks to the immediate environment in certain scenarios, particularly when there is an explosion or the formation of a toxic cloud. The full study is summarized and downloadable here .

The RIVM therefore proposes to explicitly take into account environmental safety when installing energy storage systems. The published calculation method enables policymakers and planners to determine per situation at what distance from buildings a system can be safely installed.

In addition to this customizable method, the report also contains a table with fixed distances. These distances are based on conservative calculations that summarize different scenarios. Although this table provides clarity, in some cases it can lead to larger – perhaps unnecessarily large – distance requirements. That is why the RIVM advises to keep the possibility of calculating with the method open, so that smaller, but still safe, distances can be determined in specific cases.

Response Energy Storage NL (ESNL)

Energy Storage NL (ESNL) actively contacted RIVM about this research in May 2024. Together with the members of the Safety Working Group, ESNL shared data sheets of battery storage systems and information about incidents. Since October, ESNL has also been part of the steering committee for the calculation methodology. This involvement reflects the sector's desire to think constructively about safe and workable regulations.

Although ESNL acknowledges the importance of the method, there is also criticism from the sector. Many companies have difficulty understanding the content of the method. The concepts used, the assumptions made and the implications of choices are not always clearly explained. This has led to unrest, particularly around the published fixed distance table, which in some cases seems to suggest significant restrictions for market developments.

ESNL therefore calls on the Ministry of Infrastructure and Water Management to examine the practical feasibility of the recommendations together with the sector. The organisation strives for a balance between safety and innovation and would like to discuss this with the ministry. ESNL also advocates clear communication towards market parties and municipalities and will continue to provide input during consultations and in-depth sessions.

Coherence with EU legislation: Battery Regulation

In addition, ESNL points out the importance of aligning with existing European regulations. The EU Battery Regulation (EU 2023/1542) has been in force since 18 August 2024. This regulation sets sustainability rules for batteries throughout their entire life cycle and applies to all batteries that store and supply electricity, including Battery Energy Storage Systems (BESS).

Article 12 of the Regulation specifically states that stationary battery systems (as defined in Article 3(15)) must be safe in normal use. This must be demonstrated through technical documentation, including testing against the safety parameters set out in Annex V of the Regulation. The European Commission may adapt these parameters through a delegated act. To date, there are no indications that the Commission will do so in the short term. Recent discussions with the Ministry indicate that the precise technical requirements are currently still under development; delivery is expected in the course of this year.

ESNL emphasises that national safety frameworks such as the new RIVM calculation method must be in line with these European obligations to avoid duplication of regulations, ambiguity and unnecessary burdens for companies.

Next steps of the Ministry of Infrastructure and Water Management

The Ministry of Infrastructure and Water Management indicates that it wants to limit the risks to the environment as much as possible when making policy, while leaving room for the development of battery systems. Therefore, the following actions have been announced:

• In-depth sessions with RIVM , with room for technical questions and practical examples.
• A consequence study after the summer, to obtain a realistic picture of the application of the method in practice.
• Research into regulatory pressure and business burden , to test feasibility for companies and municipalities.
• An internet consultation in the autumn , in which stakeholders can give their opinion on the proposed legislation and regulations.

The ministry emphasizes that it keeps the sector closely informed of all developments and offers room for input from all parties involved. ESNL continues to work for a joint course in which battery storage is given a responsible place within the energy system of the future, whereby it is important for ESNL that projects are not hampered by unnecessary objections.