Does a Water Storage Tank Need to be UL Listed?

3/31/2026

Is a water storage tank for an NFPA 13 system required to be UL listed, or does it need to simply be NFPA 22 compliant?

I was always taught that a tank had to be at least UL Listed for fire protection, but I have a supplier telling me otherwise, and the price he offers is less than half that of a UL/FM tank.

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9 Comments

Pete H

3/31/2026 06:44:42 am

Doesn't fully answer the question but this page does have a tangentially interesting write up on the difference between NFPA 22 compliant and NFPA 22 Equivalent:

https://waterstoragetanksinc.com/category/nfpa-22/

Dan Wilder

3/31/2026 08:11:09 am

Since I was in this section yesterday...

13 requires the water supply from a tank to be installed in accordance with NFPA 22 (Chapter 5 - Water Supplies)

NFPA 22 Chapter 4 provides General Information, none of which states anything listed or approved is required, other than for the AHJ. I also searched for the words "listed" and " approved" and they are rarely mentioned beyond specific parts or assemblies (ladder safety, roof construction by the AHJ,

There are requirements for approval from the AHJ, so that may be a limiting factor upon submittal. Materials must be listed and/or approved for their use in construction of the tank, but I don't see anything on the overall. I also checked out some bids we have received and very few showed anything more than verbiage about "meets industry standards of NFPA 20, 22, 1142" or "manufactured in compliance with NFPA requirements"...for fiberglass, concrete and steel construction.

John Callahan link

3/31/2026 08:15:17 am

The welded or bolted steel tank shall conform to the requirements of AWWA D102-17 for welded tank, AWWA D103-19 for bolted tanks, FM Global Data Sheet 3-02 and NFPA 22 - Standards for Water Tanks for Private Fire Protection, Current Edition.

Moderator

3/31/2026 08:20:16 am

John - appreciate the input. On what basis do these standards apply? Generally speaking, code and standard references help substantiate requirements for readers going forward. Thanks!

Glenn Berger

3/31/2026 08:32:47 am

NFPA 22 - 2023 edition has the following statements that are applicable to this topic:

4.11 - Materials produced and tested in accordance with the requirements of a recognized national standard and within the mechanical (strength), metallurgical, and chemical limitations of one of the material grades specified in this document shall be permitted.

5.2.1 - All tank foundations, materials, accessories, fabrication, construction, and welding shall be in accordance with AWWA D100 or AWWA D107. (welded Tanks)

6.2.1 - All design materials, fabrication, and installation shall be in accordance with AWWA D103. (Bolted Tanks)

I am sure that other references can be found. But a direct relationship to UL listed or other nationally recognized testing labs is not present in this standard for the entire water storage tank assembly.

Side note: Be careful when you see a "label" saying that a tank is "NFPA approved." You were correct is asking about NFPA 22 compliant.

Ken Thackery

3/31/2026 10:06:29 am

The short answer is no. The tank is under Div 33, not Div 21. We have done 2 in the last 2 years one Xerxes, one Fiberglass Tank Solutions in MO- made tanks for Xerxes, 1/2 the cost- It's just a water storage tank buried in the ground. Think if you had a concrete tank under a high rise for a vert turbine or horizontal pump, obviously not UL approved, it's essentially a giant swimming pool. Sometimes we tend to overcode everything when we need to keep it simple.

Josh

3/31/2026 11:03:48 am

I have specs in div. 21 for ground-suction tanks. It's fire-only. 24 41 23. I think it depends on the type of tank. I think the underground fiberglass go in division 33 where others like ground-suction steel, bolted are 21.

Jose R Figueroa

3/31/2026 10:31:27 pm

There are “FM Approved” fire tanks, and they are widely used to ensure reliable water supply for fire protection systems, meeting strict FM Approval standards (Class 4020/4820) for structural integrity, earthquake resistance, and wind resistance. These tanks comply with NFPA 22 standards, and are manufactured by companies like CST Industries, Center Enamel, Fire Tank Pros, Balmoral Tanks, and others. These tanks should probably carry the UL listed seal.

Jose R Figueroa

4/1/2026 10:19:02 am

I forgot to mention: The AHJ and insurance companies might require water tanks to be FM Approved or UL Listed. For example, if this is an FM client, please contact FM Engineering for more information before investing in the fire water tank.

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Does a Water Storage Tank Need to be UL Listed?

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