The EV-EXBOX Team has been undertaking EV charging infrastructure risk assessments across the UK covering a wide array of EV charging infrastructure located across:
Multi storey car parks
Basement car parks
Open air car parks
Bus depots
Fleet depots
Airport parking land side
Airport facilities air side
EV hubs
Petrol filling stations.
Kerbside (public highways)
The EV-EXBOX Team is incredibly pleased that we are now getting asked to risk asses’ locations before EV charging goes in or where existing EV charging facilities will be extended as part of the design process.
What still surprises us is the amount of locations we are asked to attend where EV charging has been installed where no competent risk assessment process has been applied at either the design, install or operate phases of the project.
As huge supporters of the transition to clean energy the EV-EXBOX Team are fully behind the roll out of EV charging infrastructure in the UK and beyond.
We have carried out extensive research literature reviews of the risks and we agree with the current general consensus that pure EV’s catch fire less than ICE’s and definitely less than HEV’s.
However, our perception of risk cannot be based on frequency alone. Anyone who has worked in the field of risk will know that risk is a measure of both frequency and impact.
The frequency of an EV fire is currently less than that of ICE vehicles, but the risks associated with thermal runaway in an EV manifest themselves in a quite different way to those associated with ICE vehicles.
Today the media only seems to focus on fire as the main risk during a thermal runaway event, but the initial risk is actually a HAZMAT risk and not a fire risk.
During thermal runaway process off gassing from the battery pack can produce a considerable volume of flammable and toxic gasses including hydrogen fluoride.
Hydrogen fluoride goes easily and quickly through some protective clothing and the skin into the tissues in the body where it damages the cells.
Breathing hydrogen fluoride can damage lung tissue and cause swelling and fluid accumulation in the lungs (pulmonary edema).
Children and infants are more susceptible to the effects of (HF) due to their surface area to volume ratio.
A competent risk assessment needs to look at how the location of the EV charging may aid or hinder the dispersal of these gases, where they may enter adjacent buildings through passive vents or impact emergency escape routes and muster points.
Where the EV charging infrastructure is located in an area where the off gassing cannot readily disperse then the risk of a violent vapour cloud explosion (VCE) increases.
Vapour cloud explosions are thankfully rare having only been seen to occur in around 5% of thermal runaway events but are most common within enclosed structures.
A vapour cloud explosion can cause structural damage and impact critical safety infrastructure in the area.
Once we get to the fire stage of thermal runaway studies regarding the heat release rate ( HRR) of EV’s and ICE cars are shown to be comparable.
However, the way in which an EV fire presents itself does play a key role in the speed at which a fire can spread from vehicle to vehicle.
When undertaking an EV charging risk assessment for a brand-new carpark where the EV charging had already been installed the EV-EXBOX team reviewed the fire strategy report for the car park that contained the following statement:
“Whilst the historic assumption might be less true for modern cars, the following statements and assumptions remain valid.”
“Accidental fires in cars are rare and spread of fire between cars is rare.”
“Accidental car fires have a sustained period of slow growth rate (taking in the order of 10 minutes to have sustained flames and smoke outside of the car) before reaching a peak heat release rate”.
“Fire spread between cars is initially slow (taking in the order of 10 to 20 minutes to spread beyond the car of fire origin, then a further 10 minutes between cars”.
These statements were very surprising, especially considering information regarding modern vehicle fires which is readily available in the public domain such as the excellent report by Liverpool Fire and Rescue Services following the Liverpool Echo Arena car park fire in 2019.
Putting EV’s aside Liverpool Fire and Rescue Services reported a vehicle catching fire every 30 seconds once the blaze had taken hold in the car park.
More recently at the Luton Airport car park fire it was only 20 minutes before Bedfordshire Fire and Rescue pulled all crews back as they were unable to safely tackle the fire from within the structure or protected stairwells.
It important to remember the majority of modern vehicles ICE and EV alike are bigger, generally parked closer together and contain more combustible materials than ever before.
When considering the impact of EV’s CCTV footage of EV fires in both open air and enclosed spaces have shown us the spread of fire between an EV in thermal runaway and a car in the adjacent parking bay has taken less than 90 seconds.
CCTV footage has also shown us the impact of fire spread as a result of the changes in car design over the last 25 years with fire spreading from a source vehicle to a third vehicle in under three minutes.
The speed at which a fire can spread is one of the biggest impacts in terms of risks there is on public safety and the overall damage to buildings and structures that will occur.
If the fire brigade has to apply more water it creates more contaminated firewater runoff .
When the EV-EXBOX Team attend a site as part of the design process for installing EV charging infrastructure we are always looking at.
How to avoid a build up of toxic and explosive gas
How to slow down the spread of fire within the structure
How to reduce or limit the number of vehicles involved in a fire
How to avoid fire crossing the site boundary
How to ensure public safety is not compromised.
How to ensure fire fighters can access the EV charging area
In trying to understand why there is so little competent risk assessment documentation available for EV charging infrastructure in the UK the EV-EXBOX team engaged in dialogue with designers, installers, and operators.
What was clear from these conversations was that throughout the end-to-end supply chain there was generally :
Little understanding of the risks.
No experience of dealing with or managing the risks
No clear ownership of the risks
One of the biggest challenges cited was the lack of statutory regulation and industry approved codes of best practise, however, a lack of regulatory standards or industry approved codes of best practise does not mean that there are no legal implications for what is being designed, specified, installed, and operated.
In terms of legal compliance Building Regulations play a crucial role, especially in fire safety as outlined in the Regulatory Reform (Fire Safety) Order 2005 which applies to all buildings and commercial premises.
The Regulatory Reform (Fire Safety) Order 2005 emphasises the responsibility of the "responsible person" in ensuring premises' safety, with regards to risk assessment The Regulatory Reform (Fire Safety) Order 2005 states:
"Any such assessment must be reviewed by the responsible person regularly so as to keep it up to date and particularly if:
(a) there is reason to suspect that it is no longer valid; or
(b) there has been a significant change in the matters to which it relates including when the premises, special, technical and organisational measures, or organisation of the work undergo significant changes, extensions, or conversions."
To help designers, installers and operators understand why competent risk assessment is so important we took our key questions to the insurance industry for feedback.
Q. In the event of a serious incident related to EV charging infrastructure who would be responsible ?
A. This is an area where blame could attach to both site owners/operators as well as the contractors involved in the design and construction of the installation.
If the site owner/operator provides the design brief to the contractor on the positioning of the charging area, then any property losses or physical injury claims arising from the positioning of the charging area would likely rest with them.
However, any changes to that brief made by the contractor could pull them into the claim.
If the contractor was responsible for the design of the site, then they would most likely be joining the site owner in any subsequent legal action.
Q. As the operator of an EV charging facility would my insurance policy cover me ?
A. Insurers for the site owners/operators might take the view that positioning an EV charging area close to business-critical areas or combustible materials was negligent, and that the policyholder has failed to mitigate their exposure in doing so.
If the same insurers were not told about the installations, then it’s certainly feasible that any claim resulting from the installation could be declined.
Unless they have cover for own site pollution clean-up costs, then the costs of remediating their own site would not be covered, and depending on the wording of the pollution cover, the policy might not even deal with any third party pollution damage; the word “unexpected” has found its way into many UK pollution cover wordings, and it could be argued that if suitable precautions had not been in place (failing to place drainage protections around an area that would leach toxic pollutants in the event of a fire for example) then the pollution could hardly be considered unexpected if there was a fire.
Q. As a contractor or designer would my insurance policy cover me ?
A. Contractors who assume responsibility for the design risks could also find themselves involved in claims where the positioning of the charging area has either led to or exacerbated any losses or personal injury, or indeed if they have suggested moving the area to make the installation project easier and/or cheaper to deliver.
Contractors could also have issues with their own insurance cover if they’ve completed an installation despite voicing their professional concerns about the design or location of the area and there are claims that have arisen from the design or location of the charging area.
The insurance problem gets amplified if the contractor has delivered multiple iterations of this site design and is consequently required to carry out remedial works to sites where there has been no damage.
Here we reach the question the EV-EXBOX Team always asks itself – why then would you not ensure your existing or planned EV charging infrastructure was covered by a competent risk assessment process ?
The EV-EXBOX Teams concerns regarding the lack of a competent risk assessment process across the majority of EV charging infrastructure are evidenced based on what has been recorded through its risk assessment surveys undertaken across a wide range of charging infrastructure in the UK.
A competent risk assessment can give designers installers and operators options with regards to the best place to install the EV charging from a risk perspective which can be overlaid with other important factors such as cost of installation and user friendliness.
A risk assessment does not slow down the process of rolling out EV charging infrastructure, but it does allow you to do it responsibly.
If you have any questions or concerns regarding risk assessment for EV charging infrastructure please contact the EV-EXBOX Team at info@ev-exbox.com or visit our website www.ev-exbox.com
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