Fire Safety Codes for Electric Vehicles in Buildings: Four Structural Questions for the Next Generation

This open discussion paper examines the emerging normative landscape of fire safety for electric vehicles (EVs) in buildings, with particular attention to parking garages and mixed-use facilities. It frames current standards and guidelines—including DIN SPEC 91489:2024-11, IFC 2024 §1207, and NFPA 855—as an embryonic functional mosaic rather than a consolidated regulatory system. Instead of proposing prescriptive solutions, the paper formulates four structural questions addressing: (i) the historical sequence of maturation between operational practice, insurance underwriting, and codes; (ii) the ontological boundary between vehicles and energy storage systems; (iii) the role of Layer 3 as pre-normative operational science; and (iv) the epistemological shift from object-based fire containment toward function-based controlled exhaust topologies. The paper does not seek to define requirements or performance limits. Its objective is to establish a shared conceptual vocabulary to support international dialogue among laboratories, insurers, and standards committees, and to contribute to the regulatory maturation cycle anticipated between 2026 and 2031.