Networks, generation and renewables, UK wide
Utilities and Energy Health and Safety
Utilities and energy work concentrates the highest consequence hazards in British industry into a small number of tasks. Most of them are only safe because somebody proved an isolation. AL23 Safety provides health and safety, fire safety and fire engineering support to network operators, generators, renewable developers and their contractors across the UK.
Why it matters in utilities and energy
The risks are real and so are the duties
This is a sector where the regulator charges differently because the work is different. From 1 April 2026 HSE recovers its standard Fee for Intervention at £188 per hour. Energy duty holders pay more. Wind and marine renewables are charged at £253 per hour, offshore installations at £332 per hour, onshore oil, gas and geothermal at £210 per hour and gas transportation and pipelines at £178 per hour. Those rates are a fair proxy for the regulatory attention the sector attracts.
Growth is also outpacing maturity. SafetyOn, the onshore wind body hosted by the Energy Institute, reported rising injury rates in its 2025 incident data report alongside rapid UK and Ireland growth. The offshore G+ data moved the other way, with improving rates despite expansion. Where contractors arrive faster than the safe systems of work mature, the numbers go up.
The main risks
Where the harm comes from
Electricity
High voltage switching, arc energy, induced voltages and work on or near live conductors, where regulation 14 of the Electricity at Work Regulations 1989 prohibits live working unless the strict three-part test is met.
Isolation and stored energy
Hydraulic accumulators, pitch systems, springs, pressurised systems and capacitance hold energy after the supply is off. A permit that only addresses the electrical source is not an isolation.
Confined spaces
Chambers, valve pits, wet wells, culverts, digesters and vessels produce this sector's recurring multiple fatality scenario, where an untrained rescuer follows the first casualty in.
Work at height on wind assets
Nacelle and hub access, rescue from height, blade work, dropped objects and transfers to offshore structures, all with lone or two-person teams a long way from help.
Flammable and explosive atmospheres
Hydrogen evolution in battery rooms, biogas and anaerobic digestion, gas networks and bulk fuel storage bring DSEAR zoning and ignition control into scope.
Battery energy storage
Lithium-ion thermal runaway produces flammable and toxic gas, is difficult to extinguish once propagating and is the fire risk that planning authorities and fire services now scrutinise hardest.
The regulations that apply
Your legal framework, in plain terms
The Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999 sit underneath everything. The Electricity Safety, Quality and Continuity Regulations 2002 place duties on generators, distributors and meter operators for safe design, construction, installation, protection and continuity of supply. HSE enforces them. The Electricity at Work Regulations 1989 govern the work activity itself, supported by HSG85 on safe working practices, GS38 on test equipment and HSG230 on keeping electrical switchgear safe. The Confined Spaces Regulations 1997 and ACOP L101 govern entry. The Dangerous Substances and Explosive Atmospheres Regulations 2002 and ACOP L138 govern flammable atmospheres, with the Pressure Systems Safety Regulations 2000, the Pipelines Safety Regulations 1996 and the Gas Safety (Management) Regulations 1996 applying to the assets that carry the energy. Sites holding 25 tonnes or more of dangerous substances must notify the local fire and rescue service under the Dangerous Substances (Notification and Marking of Sites) Regulations 1990.
Where the law stops and judgement starts
Regulation 14 of the Electricity at Work Regulations 1989 allows live working only where it is unreasonable to work dead, reasonable to work live and suitable precautions are taken. It does not tell you how to write that justification, who signs it or what evidence sits behind it. HSG250 on permit to work systems fills part of the gap with guidance rather than prescription. Most live working arguments we see fail on the first limb rather than the third. The outage was inconvenient rather than genuinely unreasonable.
Fire safety in utilities and energy
Battery storage is where fire strategy meets planning objection
Grid scale battery storage has become the fire question the sector cannot avoid. HSE treats these systems under general law, applying the Health and Safety at Work etc. Act 1974, the Electricity at Work Regulations 1989, the Management Regulations, CDM 2015, DSEAR and the notification duty at 25 tonnes. The Department for Energy Security and Net Zero, working through the Electricity Storage Health and Safety Governance Group, publishes health and safety guidance for grid scale electrical energy storage systems. It was published on 18 April 2024, last updated on 23 March 2026, mapping the applicable standards to each stage of deployment.
The document that decides most planning arguments is the National Fire Chiefs Council guidance on grid scale energy storage system planning for fire and rescue services, now at version 2 revised in December 2025. It recommends about 0.9 metres between units where UL 9540A testing shows no propagation. Where it does not, NFPA 855 separation applies. It sets an initial minimum of 30 metres to occupied buildings before mitigations such as blast walls, 3 metres of vegetation clearance around cabinets and a hydrant flow of at least 25 litres per second. Where that flow is not achievable it suggests a static supply of around 180,000 litres for 120 minutes, with tanks at least 10 metres from containers. It also recognises that manufacturers increasingly advise letting a cell in thermal runaway burn out, with water used to protect surrounding equipment rather than to fight the cell.
Two honest points. It is guidance rather than law. The distances are a starting position rather than a fixed standard. Fire and rescue services are not statutory planning consultees for these developments, although the NFCC asks each service to nominate a battery storage contact and to engage with developers early. The operator who engages before submission usually gets a better outcome than the one who waits for an objection.
How we help
Built around your operation
We work at the point where a written system meets a live asset. That means watching the isolation being applied and asking the person doing it what proves the conductor is dead.
- Permit to work system design and audit, covering authorised person appointments, isolation standards, lock off hardware and the handback discipline that closes a job out, through our permit to work systems work.
- Confined space entry reviews against L101, including whether rescue arrangements exist before entry rather than a phone call to the fire service, supported by dedicated confined space safety support.
- Work at height reviews for turbines, substations, tanks and fragile roof solar arrays, applying the regulation 6 hierarchy through our working at height safety service.
- Electrical safety audits against HSG85, GS38 and HSG230, including live working justifications and switching procedures.
- DSEAR assessments and zoning for battery rooms, biogas plant, fuel storage and gas assets.
- Battery energy storage fire reviews covering separation, water supply, detection, gas venting and fire service access.
- CDM 2015 support through construction and commissioning, including interface management on live sites.
Why AL23 Safety
Sector-aware support that gets used
Accountable
If permits are being signed by people who did not walk the isolation, we say so and name the control that failed rather than the individual.
Expert and chartered
Qualified, chartered professionals who work to current standards and legislation. We read the standard rather than the summary of it.
One team, three disciplines
Health and safety, fire safety and fire engineering in-house. Battery storage sits across all three and we do not hand you between suppliers halfway through the question.
Nationwide
We support utilities and energy operators across the UK, from single substations and solar sites to distributed asset portfolios.
Get in touch
Tell us about the asset and the work on it
Send us the asset type, the tasks that worry you and any recent near miss. We will tell you whether the priority is the permit system, the entry procedure or the fire case.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usSometimes. The bar is high. Regulation 14 of the Electricity at Work Regulations 1989 requires that it is unreasonable in all the circumstances to work dead, that it is reasonable to work live and that suitable precautions are taken. Commercial inconvenience is not unreasonableness. We review live working justifications and tell you which ones would not survive an investigation.
There is no statutory separation distance. The National Fire Chiefs Council guidance, version 2 of December 2025, sets an initial minimum of 30 metres to occupied buildings before mitigations such as blast walls. It gives about 0.9 metres between units where UL 9540A testing shows no propagation. Those are recommendations to fire and rescue services rather than law, which is why the fire strategy behind them matters more than the number.
You are, before anyone enters. Regulation 5 of the Confined Spaces Regulations 1997 requires suitable and sufficient emergency arrangements before work starts. They cannot rely on the fire and rescue service alone. That means trained rescuers protected from the same hazard, appropriate rescue and resuscitation equipment and a way of raising the alarm from inside the space.
A single site permit and isolation review is usually a day on site plus reporting. A portfolio review is programme work, scoped by asset count, travel and whether fire and DSEAR sit alongside the occupational work. Ad hoc support runs at £95 per hour or £695 per day plus VAT. Send us the asset list and we will scope it properly.
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