Risk assessment and EV charging infrastructure tenders.
- Graeme Warnell
- Oct 31
- 6 min read
Introduction to the problem
As we are fast approaching the end of the year the EV-EXBOX team always likes to reflect on interesting topics that came up during are very hectic 2025 delivering EV charging Infrastructure risk assessments and risk awareness guidance across a range of clients and building structures including :
Residential basements
Multi storey car parks
Bus depots
Fleet depots
Airports
Police stations
EV hubs
Petrol filling stations.
2025 was particularly busy with regards to supporting local authorities with access to LEVI funding for the roll out of EV charging infrastructure.
The EV-EXBOX team follows the local authority tenders very closely but when we read them we are always surprised by one common feature – there is nearly always nothing in the tender package regarding risk assessment.
Whenever we deliver our risk awareness guidance sessions one of the key topics that always comes up is insurance. At some point, you would think that insurance and the need for risk assessment would be closely linked ?
So why do tenders keep omitting a risk assessment section that sets out expectations and responsibilities for the designers, installers and operators of EV charging infrastructure ?
From our conversations with clients there are several reasons why risk assessment is not included in the tender documents :
Lack of clear statutory guidance
Lack of industry approved codes of practice
Abundance of generic information, misinformation, conflicting information – it is all just too confusing !
EV’s catch fire less often than petrol and diesel vehicles so I do not need a risk assessment.
It's not a recognised or perceived risk - people are therefore desensitized to the risk.
There is no ownership of the risk.
This is not a new issue, back in 2019 the National Fire Chiefs Council raised similar concerns to the Department of Transport stating that :
"We are also seeing a lack of understanding of the risk amongst the industry (clean energy sector), in every stage of the design and build process.
Just because the risks are not covered in statutory guidance or accepted code of practices due to the pace of technological advancement, this does not mean the requirement to comply with the appropriate legislation is removed.
It is for those responsible to demonstrate how they meet the relevant legislative requirements, by providing appropriate evidence from a responsible (competent ) person“.
Although the National Fire Chief Councils Statement can read as a little confusing it hits directly on the key aspect of risk management which is providing appropriate evidence from a responsible (competent ) person - this is risk assessment.
So, who is this a responsible (competent ) person is it:
The designer ?
The equipment supplier ?
The installer ?
The operator ?
The landlord ?
An independent third party ?
Everyone above ?
The answer to that question is it can be any of them so it is clear in the tender documents who is expected to take on the responsibility and ensure they have the competency to do it correctly.
EV charging infrastructure risk assessment vs. fire risk assessment.
One of the most common enquiries we get at the EV-EXBOX team is:
"We are going to, or we have installed EV chargers can you please come and carry out a fire risk assessment please ?"
This may sound strange but out standard answer is always NO.
If you are already operating a building or facility, then you should already have a valid fire risk assessment document as per the requirements of the Part B of the Buildings Regulations 2010 and the Regulatory Reform (Fire Safety) Order 2005.
The problem is these documents do not really cover the range of risks that need to be considered when dealing with an EV fire or thermal runaway event.
This is why the EV-EXBOX team provides a site-specific risk assessment in relation to planned or pre-existing EV charging infrastructure that can be used as a supplement to the existing fire risk assessment.
(At this point I always must add that simply stating that EV ‘s catch fire less than petrol and diesel vehicles whilst being a true statement does not constitute a risk assessment).
The EV-EXBOX EV charging infrastructure risk assessment considers the following areas:
Training and awareness
Vapour cloud explosion.
Detection
Suppression
Fire spread within a facility.
Fire spread beyond the boundary of a facility.
Management of contaminated fire water below ground
Management of contaminated fire water above ground
Vehicle quarantine
Public safety
Emergency services accessibility
Emergency response procedures
Alternative EV charging locations( where applicable).
The key with all of thee above factors is that they will have different likelihoods and different impacts on different structures which is why risk assessment is always a site-specific process.
What we have seen however is sweeping generic safety statements, often made by insurers, causing confusion and concern in relation to how organisations can safely roll out EV charging infrastructure.
Insurance companies’ perspective
When we sat down with one of the world’s biggest insurances brokers, we asked them three key questions regarding risk and what a lack of risk assessment could entail with regards to existing insurance policies held by our clients.
1. Question - In the event of a serious incident related to EV charging infrastructure who would be responsible ?
Answer - 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.
2. Question - As the operator of an EV charging facility would my insurance policy cover me ?
Answer - 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 is certainly feasible that any claim resulting from the installation could be declined.
3. Question - As the operator of an EV charging facility would my insurance policy cover me for the potential environmental impact of a fire ?
Answer - Unless they have cover for own site pollution clean-up costs, then the costs of remediating their own site would not be covered.
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.
It could be argued that if suitable precautions had not been in place, then the pollution could hardly be considered unexpected if there was a fire.
Whether it is for private dwellings or commercial premises we have not seen an insurance premium applied to facilities that have installed EV charging but please always make sure you inform your insurers and of course, risk assess the potential impact of the installation on the premises should something go wrong.
What should I do now ?
At EV-EXBOX we do not believe electric vehicles bring more risks, but they do bring new risks and, as opposed to petrol and diesel vehicles where facilities were purpose designed for the storing and discharging of fuel EV chargers can be installed almost anywhere with a lot of the charging process being carried out unsupervised.
If you are unsure if you have covered the risk assessment process properly at any of your planned or existing sites then please feel free to email the EV-EXBOX team , we would be more than happy to talk to you and help info@ev-exbox.com
If you would like to talk to a local authority or private commercial client, we have worked with regards either the risk assessment process or the risk awareness training then please let us know so we can make the relevant introductions.
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