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Graeme Warnell

Fleet Electrification – Is Infrastructure Investment Looking at All the Risks?

With the Government committing £1.6bn to EV charging infrastructure in the UK the race to electrify is in full swing. Local authorities, distribution companies, public transport providers and many smaller businesses are changing the way they power their fleets.


In 2021 the Royal Mail announced a ten-fold increase in the number of electric vehicles in its fleet planning to introduce a further 3000 EV’s.



Nottingham City Council has 51% of its vehicles powered by electricity, including six bin lorries, road sweepers, and vans. Its bidirectional charging depot incorporates 176 kW of solar PV, 600 kWh of stationary energy storage made using second-life batteries and 40 bi-directional electric vehicle charging units.




At EV-EXBOX we ask, when all this infrastructure for EV charging is being installed is anyone looking at risk mitigation and emergency planning, or is it just a question of installing the chargers and walking away?


When we look at EV charging installations, we see locations that have been repurposed for something they were was never designed to do – essential supply energy to vehicles. If a location was going to have a diesel refuelling facility installed there is a plethora of legislation and best practise that would ensure all the associated risks were designed out or at least mitigated as best as reasonably practical.


In the last 12 months our site surveys have taken us to EV hubs, car parks, petrol filling stations, bus stations and fleet depots. What our surveys of EV charging locations have shown us is nothing more is being considered other than how many chargers can be installed and is there enough power into the location.


On almost every location we attended we found there was:


No consideration for fire suppression

No scheme for firewater retention present – even in highly environmentally sensitive areas

No consideration for public safety on or off site

No amendment to emergency response plans

No staff training on the risks of an EV fire or, how to even recognise the early warning signs of thermal runaway


EV charging operators must not rely on a false sense of security that armed with a few lithium-ion rated fire extinguishers or fire blankets they are going to save their facility in the event of an EV related fire. On July 22nd, 2019, a fire started at the Andover Ocado warehouse following a failure in one of its lithium-ion battery robot goods pickers. The staff turned off the sprinkler system in an attempt to tackle the fire with handheld extinguishers. After staff failed to suppress the fire by hand the sprinkler system was reactivated but by then it was too late. The fire caused £100m of damage, it took 2 years to rebuild the facility and 400 people lost their jobs.





An EV fire can only be tackled by the emergency services. It required professional training and equipment such as fire proof clothing and the use of full face breathing apparatus. However, the way you design your EV charging facilities can help the emergency services to suppress and contain an EV fire quicker which helps protect property, public safety and the environment.


Legislation and best practice guidance for electric vehicles is nowhere near where it is for petrol and diesel site developments, but that’s because we have had over 100 years practice getting it right for hydrocarbons. At best the guidance for designing, installing and operating EV charging facilities is fragmented and incomplete.


The RISC Authority RC 59 Recommendations for fire safety when charging electric vehicles, administered by the Fire Prevention Association covers the installation requirements and fire risks of electrical vehicle charging in good detail. However, it does not mention anything about the severe environmental risks posed by EV firewater run-off and how to control it.


The APEA, Association for Petroleum and Explosives, Electrical Vehicle Installations at Petrol Filling Stations looks at the requirements affecting the electrical installation of EV chargers and its segregation from hydrocarbon refuelling areas. It mentions nothing with regards to other public safety risks such as toxic fumes, risk of explosion, fire suppression or environmental protection. In terms of drainage the only consideration it gives is in preventing fuel from running into the EV charging area, not contaminated firewater escaping through the on-site storm drains, car wash or fuel separators.


CIRIA 736 Containment Systems for The Prevention of Pollution – secondary, tertiary and other measures for industrial and commercial premises, was not designed for EV charging but begins to look at the impact of firefighting water and its pollution potential.


Other best practise guidance for managing firewater pollution can be found within:


  • ISO/TR 26368:2012 Environmental damage limitation from fire-fighting water run-off

  • AVIVA Loss Prevention Standards -Preventing Pollution from Fire Fighting Run Off

  • United nations Economic Commission for Europe – Safety guidelines & Good Practices for The Management & Retention of Firefighting Water


It is important to remember a failure to control firewater can result in a breach of both the 1991 Water Resources Act and the Industry Water Act., fines in excess of £100,000 are not uncommon.


Therefore, everything you need to know to ensure the risks of operating EV charging facilities is available, albeit not available in a single document or best practice guide. Legally this means there is really no excuse for not designing out these risks wherever possible before the installation goes live.


At EV-EXBOX we can only assume the reason best practise for public safety, fire suppression and environmental protection is not being applied to EV charging locations is that there is a lack of awareness of the risks within the EV community – despite the information being available, albeit not in one single document.


What would really concern us however would be if proper risk mitigation was not being undertaken at the design stage due to a need to deliver cost savings or if safety considerations are being pushed aside for the sake of speed of roll out. From our experience the changes required to mitigate most risks are not expensive and would typically cost far less than a single fast charging unit.


In the event of a large EV fire at a charging hub or depot that resulted in harm to the public, extensive property damage and a serious pollution event that could have been mitigated through design, this will make for a very interesting investigation by the Health & Safety Executive, The Environment Agency and probably any loss adjusters involved.


Our concern comes from the fact that the number of EV’s is increasing dramatically, the vehicles and charging infrastructure are getting older and our demand for faster charging grows we will see more incidents that result in EV fires. So far, we have already seen a bus depot fire at Potters Bar, the total destruction of bus depots in Stuttgart and Utrecht, all as a result of battery issues during charging.




More recently on the night of 18th March a large fire broke at the Deutsche Post premises in a Wismar industrial park, Germany. By the time the emergency services arrived, the fire had already spread to other vehicles and the canopy of the distribution centre. In total the fire destroyed seven vehicles and badly damaging seven more.





In all these events the emergency services priority was to control the fire, it’s not their legal responsibility to protect the environment. It is the facility operators legal responsibility to stop highly contaminated firewater entering storm drains, sewers or the environment.


At EV-EXBOX we have a massive focus on the environment, and we do everything we can to run a truly carbon neutral business. We are huge supporters of the transition to clean energy, but this transition has to consider more than just getting chargers into the ground and switched on.


As part of the design and construction of new charging facilities or re-purposing of existing facilities the world needs to keep these sites environmentally clean and safe for their entire life-cycle. At EV-EXBOX we can support your design process by bringing all the aspects of fire, public safety, and environmental protection together through our extensive experience.


Whether it is reviewing plans, surveying sites, delivering awareness training, or providing physical solutions for fire suppression and firewater management the EV-EXBOX team is here to help. From what we have seen there are no good or bad players, every site we have surveyed is in the same place – a place we have to move on from as a responsible EV community.


If you would like to discuss electrical charging safety at any of your facilities, please contact

Graeme Warnell on info@ev-exbox.com Mobile +44(0)7766107088 WWW.EV-EXBOX.COM





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