A question about EV charging was raised recently at the Petroleum Enforcement Liaison Group (PELG) where I have just been made the first chairman to be appointed from ’industry’ rather than from ’enforcement’. The question was ’Who would enforce EV charging and how would they know if any had been installed that didn’t comply with the guidance and therefore could be dangerous?’.
The responsibilities lie with the site operator to employ ’competent persons’ to carry out any works on their premises. They cannot sub contract this responsibility ie expect the company installing the EV charging to comply. The competent electrician should comply with relevant guidance and adhere to the Electricity at Work Regulations 1989 (EWRs), the current version of BS 7671, and The IET Code of Practice for Electric Vehicle Charging Equipment Installation 3rd Edition due to be published this month. Or be able to justify how any alternatives are equally as safe. Should there be a contravention of the EWRs, the enforcement authority is the LA Environmental Health Department, who are extremely unlikely to also be the department enforcing Petroleum Regulations.
There is no requirement for a site operator to inform the Petrol Enforcement Authority that they intend installing EV charging. Therefore, the most likely scenario is that inspectors only discover that it has been installed at the time of an inspection. I therefore conclude that an inspector would only become aware of possible contraventions involving EV charging on a petrol forecourt as the result of an incident or by auditing a Hazardous Areas Electrical Test Certificate and finding that the electrician had noted and categorised deficiencies involving EV charging infrastructure. If this were the case, they would have to assess whether it was appropriate to take action. The risk to the forecourt operator would be the curtailment of use of all or part of their fuel (electric and/or liquid) infrastructure by the issuing of either an Improvement or Prohibition Notice.
My advice to forecourt operators is to ensure they employ competent people!