By Joshua Marshall, product manager at CheckFire
As we near the turn into the final calendar quarter, the warehouse and logistics sector is gearing up for what is typically a pacey and high-pressure period. Peak holiday shopping and major retail events like Black Friday make for a denser product inventory, with goods requiring rapid order fulfilment and being subject to capacity-straining return volumes. Meanwhile, high labour demand means organisations often lean heavily into temporary workforces that are unfamiliar with the specific environment in which they are working.
Naturally, these factors have a significant financial and operational impact. But more than this, they also reshape the fire risk landscape across an estate. Even if a thorough risk assessment has been conducted in recent months – or remains accessible from the same time the previous year, even – it cannot be relied upon to inform current fire safety strategies in their totality. A new product offering alone can alter the presence of combustible materials on site, while a reconfigured layout can block an escape route that was previously clear, for example. Under the Regulatory Reform (Fire Safety) Order 2005 (RRFSO), compliance depends on continual evaluation and measures that are proportionate to the risks present right now.
What peak end-of-year pressures mean for fire safety
Guidance from the UK Health and Safety Executive (HSE) suggests a series of precautions to reduce the risk of fire. In a warehouse setting, this includes: leaving adequate clear space around electrical switchgear, distribution boards, and fuse boxes for safe operation and emergency isolation; keeping boxes and flammable materials a safe distance away from hot light fixtures, halogen lamps, and ceiling-mounted electrical equipment to prevent ignition; and ensuring stock stacking leaves adequate clearance underneath fire detection units and sprinkler heads (typically at least 500mm) so as not to block essential fire safety systems. However, when the priority becomes fulfilling orders at pace and packing as much stock into the available space as possible, these measures can unintentionally become compromised.
Furthermore, mechanical handling equipment, from forklifts and pallet trucks to order pickers and conveyor belts, sees near-continuous use during peak trading, with less downtime afforded for the checks that would ordinarily catch a fault early. This equipment is generally treated as a general health and safety concern rather than an explicit fire risk, yet faulty wiring, overheating motors, and damaged batteries are all recognised ignition sources in their own right. A site running more machines for more hours carries more of this exposure by extension, even if nothing about the equipment itself has changed.
Seasonal staff add a further, distinct layer of risk. Even if a warehouse worker is highly experienced, they face unfamiliar layouts, products, and fire safety procedures when they move between sites – an increasingly common occurrence throughout busy Q4 periods. Without formal inductions, a new starter may not know where the nearest fire extinguisher is located, which fire door leads where, or how to raise the alarm in the event of an emergency.
How rechargeable technology increases the dangers
Lithium-ion batteries sit at the centre of warehouse operations, powering a variety of everyday equipment such as forklifts, pallet trucks, barcode scanners, autonomous mobile robots (AMRs), automated storage and retrieval systems (ASRS), handheld tablets, charging stations, e-bikes, and beyond. Many lithium-ion battery-powered products pass through the warehouse as stock too, adding a further layer of exposure beyond the equipment used to move them.
Thermal runaway presents a significant danger here. When a lithium-ion battery cell is damaged, overcharged, or overheats, it can enter an uncontrollable self-heating state that releases flammable and toxic gases, often igniting and rapidly spreading fire between neighbouring cells. These fires burn intensely, resist conventional extinguishing agents, and can reignite hours after they appear to have been brought under control. The risk has become significant enough to be formally recognised as its own category, with BS ISO 3941:2026 introducing Class L for lithium-ion battery fires in January 2026. As such, while not currently a legal requirement, operators regularly handling lithium-ion battery-powered goods and equipment would be wise to ensure this risk is considered within their fire risk assessment, rather than folded into a general electrical hazard category.
What is legally required of the ‘responsible person’
Under the RRFSO, every non-domestic premises in England and Wales must have a designated ‘responsible person’ who is legally tasked with ensuring fire safety. In a warehouse, this duty typically falls to the employer or, where the employer is a company rather than an individual, whoever holds control of the site on the business’ behalf – such as a warehouse or facilities manager acting under board-level authority. Day-to-day tasks within that duty can be assigned to competent staff or external advisers, but legal accountability for fire safety remains with the responsible person regardless of who carries out the work. Where a site is shared between multiple occupiers, more than one responsible person may hold duties concurrently.
Undertaking a current and comprehensive fire risk assessment is at the core of this requirement, identifying the fire safety hazards specific to each premises and outlining proportionate measures designed to reduce their impact. This assessment must be recorded and kept under regular review to make sure it evolves in tandem with the business – including the changing risk profile brought by a busy quarter of operation – and satisfies the golden thread of information required for building compliance.
Other obligations include emergency planning, which means designing and maintaining clear fire escape routes, functioning emergency lighting, and an evacuation plan that has been tested in practice. It is also important that essential fire safety equipment, from fire extinguishers to detection systems and alarms, is inspected and serviced on a routine basis so it performs when needed. Comprehensive staff training should be delivered in the form of clear fire safety information, instruction, and routine emergency practice for every warehouse worker. Meanwhile, hazard communication extends the responsible person’s duty beyond their own workforce to ensure employees and external contractors alike are informed of any fire risks identified on site.
Practical priorities for every warehouse operator
As Q4 nears, warehouse operators are not forced to choose between speed and safety – the two are inherently linked. A fire that breaks out mid-peak does not simply pause fulfilment for a few hours – it could halt it entirely, creating a hazardous environment for staff, potentially damaging significant volumes of stock, and putting the operator at risk of legal liability. As such, revisiting the fire risk assessment with the pressures of this period should not be viewed merely as a compliance exercise, but as a form of financial and operational insurance that safeguards high-throughput success.
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