Best Practise, legal Compliance or Simply Confused – Where Does Your EV Charging Facility Rank?
At EV-EXBOX we are actively looking at EV installations, not matter how big or small. From one lonely charger by the seaside on the Scottish Coast to some of Europe’s biggest EV hubs, the UK has everything.
Whilst there are some infrastructure challenges regarding connectivity in the UK the pace of EV charging both for private and public use is incredible and backed by some serious investment.
Public demand for hydrocarbon-based fuels generally leads us to fill up at dedicated petrol stations, with logistics fleets and buses typically filling up within their own depots. The ability to charge EV’s has developed a footprint like no other vehicle fuelling solution ever has before.
Petrol filling stations, haulage companies and bus depots are now integrating EV charging alongside their traditional hydrocarbon refuelling infrastructure as part of the energy transition. The wider availability of vehicle charging has now meant the installation of EV poles has spread to car parks, public spaces, care homes, hospitals, fast food restaurants and alongside public pavements.
If you are operating an EV facility, have invested in EV charge poles on your plot or you are an insurer covering the automotive sector you should be asking, “how legally compliant am I in the event that something goes wrong”.
With the UK 2030 and EU 2035 rulings on the production of hydrocarbon vehicles gets closer the number of internal combustion engine (ICE) cars will
eventually decline as the take up of EV’s rises. So, for the future have we asked ourselves the following questions:
Has the risk profile of ICE’s vs EV’s changed?
Do we have the same level of best practise in the EV community that has evolved in the ICE community?
Is fire safety and environmental legislation really up to speed with the roll out of EV infrastructure in the UK?
Has the risk profile of ICE’s vs EV’s changed? - I am not saying EV’s are more dangerous than ICE’s but they do bring new risks and any new risk must to be managed responsibly. Without going into pages of technical details we know that EV’s can emit explosive gasses which can ignite at relatively low temperatures, we know EV cars burn at high temperatures and we know the contents of the car and battery can produce highly toxic smoke and as a result produce a lot of highly toxic fire water run-off.
We have first-hand accounts from firefighters that EV fires are very difficult to extinguish typically generating over 10,000 litres of toxic firewater. We also know that EV charging now takes place in very public, often unmanned areas. What has happened in the EV roll out phase so far is charging posts have been installed into locations where there has been no review of the impact of the new risks and no assessment of how to mitigate them. So definitively YES, the risk profile for EV’s has changed from the risk profile of ICE’s.
Do we have the same level of best practise in the EV community that has evolved in the ICE community? – Firstly, it is important to understand we have had more than one hundred years to understand the risk profile of ICE vehicles and not much more than a decade to understand the risks of EV’s.
The how to install a charger, and its associated substation infrastructure is well documented. It is covered by Electrical Installation Regulations and is supported by a best practise guide from the Institute of Technology in association with the Association for Petroleum & Explosives, (APEA).
For fire safety best practise tends to become a bit of a grey area. The current go to document seems to be RC59 Recommendations for fire safety when charging electric vehicles, produced by the RICS Authority in collaboration with the Fire Prevention Association.
The RC59 document attempts to offer guidance from members of the UK insurance industry. It has some common-sense advice but displays a lack of understanding regards the risks and hazards associated with electric vehicles during thermal runaway. It does not consider the vapour cloud hazard and the highly directional nature of flares from the battery packs. What is particularly concerning from a safety perspective is that it implies hand-held CO2 fire extinguishers are suitable for dealing with EV fires of any size and that staff can deal with such fires.
Regarding the potential environmental impact of an EV charging facility the EV-EXBOX team sees this as an area that has been totally overlooked on every installation we have surveyed. In the event of an EV related fire landlords and EV hub operators must consider firewater runoff prevention. It is not the responsibility of the emergency services to protect the environment. If you are a landlord, owner, or operator of an EV charging facility you are responsible for preventing contaminated firewater from entering public sewers or the environment. There is a lot of good practise guidance out there such as CIRIA 739, The AVIVA Loss Prevention Standards and from the United Nations Economic Council on firewater management.
Is legislation really up to speed with the roll out of EV infrastructure? – Peoples lack of understanding of the risks associated with an EV related fire and its consequences is in itself probably the biggest unmanaged risk we have seen across the EV sector. It is essential that EV installers and operators understand that best practise is not a substitute for statutory obligations.
Whereas I believe the EV industry has developed some “good practises” due to its infancy we are still a long way from delivering truly “best practise” in terms of public, fire, and environmental safety.
Existing UK Legislation that can be applied to a range of EV installations especially where EV charging is within or adjacent to a building here the installers must consider statutory guidance meeting the functional requirements of the Building Regulations (as amended) or the Regulatory Reform (Fire Safety) Order 2005 as well as other legislation.
In terms of environmental protection EV hubs will also be bound by statutory obligations such as the 1991 water Resources and Water Industry Acts.
Now here comes the rub, just because the risks are not covered in statutory guidance or accepted code of practices e.g., British Standards, due to the pace of technological advancement, does not mean the requirement to comply with the appropriate legislation is removed.
If you are complying with good, (best) practise guides and you believe this makes you legally compliant you are seriously misinformed. From looking at both current installations and schemes in the planning stage we are seeing a lack of understanding of the risk at every stage of the design and build process.
It is for those responsible to demonstrate how they meet the relevant legislative requirements, by providing appropriate evidence from a competent person, and not by following guidance alone that may not be wholly appropriate.
When you are asking yourself the question how your EV installation or operation ranks in terms of legal compliance, please be very clear on where you applied statutory regulations and good practise into your design and build process remembering the latter is not a substitute for the former.
As an EV community let us keep sharing good practise, let’s try and support and guide each other if we see an installation that we feel may pose a risk that has been inadvertently overlooked. In time this will get EV charging from good practise to best practise, and we can then use that best practise to help drive appropriate amendments to UK legislation and statutory requirements.
The EV-EXBOX team regularly visits EV installations to point out risks that may have been overlooked. We always post our feedback out on LinkedIn to try and help the EV community. At present we are reviewing legal requirements and good practise to help provide EV operators and installers with sensible check lists and risk awareness training. The EV-EXBOX team is here to provide surveys and reviews of existing installations or comment on designs and plans for new. Our extensive knowledge base and experience allows us to provide physical solutions to improve fire suppression and prevent firewater run-off from contaminating the environment across a wide range of facilities and locations.
Website: www.ev-exbox.com Tel: +44 (0) 7766107088 email: firstname.lastname@example.org