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EV Charge Points – New Risk Considerations

Following the UK Government’s plans to make electric vehicle charging points mandatory for new homes, organisations must give careful consideration to where points are to be located.

Following COP26, the UK Government outlined plans to make electric vehicle charging points mandatory items when building new homes,[i] or renovating residential properties — subject to some exceptions. While these plans suggest the minimum requirements in terms of introducing charging infrastructure, many organisations are already planning, or are in the process of, electric vehicle (EV) charge point installation at their locations.

The installation of high voltage charge points in close proximity to buildings and other infrastructure is, however, becoming an increasing concern for property insurers and it is important that organisations give careful consideration to where points are located. Failure to do so could result in requests from insurers for charge points to be relocated, incurring significant expense. Insurers may limit or refuse cover where clients decline to relocate charge points.

What is the issue?

Insurers are taking a keen interest in the risks that may be associated with electric charge points. Guidance on electric charge points has been provided by the industry body, RISCAuthority[ii]. This body is comprised of a number of insurers who actively support a range of expert working groups in developing risk management best practice relating to fire and other risks. The guidance issued gives a strong indication of insurer’s attitudes to how this risk should be managed and their expectations.

This document sets out a number of criteria relating to the location and risk management of EV charge points that organisations should consider prior to charge point installation.

The key concern is around the risk of fire developing as a result of charging issues and then spreading to nearby buildings. The below measures are aimed at ensuring steps are taken to comply with the above guidance to minimise and mitigate this risk.

What is the guidance on location of EV charge points?

Organisations should consider the following when locating charge points:

  • Notify Insurers at the outset of the intent to install charging points. Insurers may be able to offer further guidance and support, as well as notify any potential impacts on cover so that appropriate mitigating action can be taken. This will also help avoid potential cover difficulties at a later stage.
  • Locate charging points externally where possible instead of under canopies or inside other enclosed areas of the building. This, however, may not be possible in environments with only basement car parking facilities, for example. For multi-storey car parks, charging should be installed only on the open air/roof/top deck, where possible. Careful consideration should be given to appropriate fire protection provisions at the planning stage, where car parks are located beneath ground level.
  • No charging should be undertaken within 10 metres of any combustible materials — be they waste materials, stock, or combustible elements of the structure.
  • No charging should be undertaken within 15 metres of hazardous installations such as transformers, flammable liquid stores, and liquefied petroleum gas tanks.
  • Where separation or external location is not achievable it may be possible to take other mitigating actions, such as:
    • Locating points away from external building walls where cladding or other flammable decorative elements are located. It is preferable to have chargers close to a structure’s non-combustible walls (such as brick or single skin steel).
    • Exploring whether chargers could be separated from buildings and structures through the use of a non-flammable enclosure.
    • Exploring whether flammable materials, such as shrubbery and other plant life for external areas, or waste storage for internal ones, can be removed from the perimeter around the charger to minimise the risk of fire spreading.
  • Ensure the nominated charging area provides suitable space for vehicles to park and connect safely.
  • Ensure there is sufficient electrical infrastructure for the electrical supply at the point of installation. The circuit should be dedicated to the use of the chargers, and not be part of a ring main or used for other purposes.
  • Explore installing bollards or other measures to provide mechanical protection for charging points.

Other considerations

As well as the consideration around location of charging points, organisations should also ensure they implement and are able to evidence to insurers that they have:

  • Nominated a suitably qualified provider who will be responsible for the installation of any charge points. This provider should be confirmed to the insurer when proposing the installation.
  • Confirmed that charging cables will not present a trip risk to passers-by or be located where they could be damaged by passing traffic. This may require relocation of access and walkways.
  • Undertaken a suitable and sufficient fire risk assessment.
  • Installed clear signage, where multiple chargers are in use.
  • Clearly differentiated from conventional charging points and rapid charging points, because of the hazards associated with the direct current (DC) fast charge. 
  • Provided employees with adequate training covering the safe use of such chargers.
  • Included charge points in regular fixed wiring inspections. Best practice would be testing of the system every three years with inspection of conductors annually. This is on the basis that:
    • The circuit is powered on and off at irregular times and potentially left unused over weekends or other periods of time.
    • The terminals are outside and exposed to environmental conditions such as moisture, frost, or direct sunlight.
    • Users may be pulling the cabling, stretching the cable and there is contact of conductors when placing it into the vehicle terminal and charging point terminal when finished.

As with any new risks, organisations should consult with their advisers when considering installation, in order to avoid difficulties at a later stage. 

 

[i] https://www.gov.uk/government/consultations/electric-vehicle-chargepoints-in-residential-and-non-residential-buildings

[ii] https://www.riscauthority.co.uk/public-resources/documents/resource/rc59-fire-safety-when-charging-electric-vehicles-401

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