The British Standards Institution (BSI) recently published PAS 63100:2024, a specification which aims to help manage fire safety related hazards associated with battery Energy Storage System (ESS) installations in the UK*. A PAS (Publicly Available Specification) is a fast-track document developed to address a perceived market need, and is produced much quicker than conventional standards. A PAS can be considered for further development into a British Standard, or its requirements considered during the development of European or International Standards.

Tesla has a strong commitment to safety, as demonstrated by over 600,000 Powerwalls operating safely and reliably around the world. Tesla has a relentless program of testing, monitoring, and continual improvement, including robust fire safety testing. Tesla has also consistently participated in the development of global regulations concerned with ESS fire safety, including the influential U.S. National Fire Protection Agency (NFPA) documents that are referenced in the PAS.

PAS 63100:2024 covers a wide range of topics. Tesla participated in the development of the document and considers most of the document to be helpful and positive. However, we have concerns on a few provisions in the published document, which while well intended, we consider to be of limited value or can be better addressed by other existing means.

This paper identifies compliance of Tesla Powerwall 3 with key provisions of PAS 63100:2024. This paper also highlights provisions which are of concern and suggests alternative means of addressing the topic.

* PAS 63100:2024, Electrical installations – Protection against fire of battery energy storage systems for use in dwellings – Specification