Put simply, electric vehicle (EV) smart charge points must be treated as work equipment.
According to the 2019 UK Greenhouse Gas Emissions survey, the transport sector is the largest contributor to the UK’s CO2 emissions. To tackle this, the UK government has set out its ‘Road to Zero Strategy‘, which aims to transition the UK to the use of ‘zero emission road vehicles’ and reduce CO2 emissions from standard vehicles.
Organisations can indeed make a positive environmental impact by electrifying their vehicles. To financially support eligible companies with the purchase and installation costs of EV charge points, the Government has set out its Workplace Charge Scheme (WCS).
Having workplace EV charge points installed gives companies the ability to:
- track cost and energy usage of company vehicles;
- provide staff with the option to charge their vehicles onsite; and
- provide a great employee benefit which can lead to worker retention.
However, there are some important things to remember before choosing to install them.
The Electric Vehicles (Smart Charge Points) Regulations 2021 require all EV charge points to have smart functionality. Smart functionality allows communication between other smart charge points, the car, and the grid.
This means that your employees would potentially be using complex software that they may not be familiar with.
The Provision and Use of Work Equipment Regulations 1998 (‘PUWER ‘) impose duties on employers to ensure that work equipment is suitable and safe for use by employees. One employer responsibility is to provide workers with adequate training on how to use the EV charge points properly, so that their actions do not lead to harm to themselves, or others.
Workers must also be instructed to report any hardware or software issues and must not attempt to fix these issues themselves.
PUWER also require the employer to ensure that their work equipment is inspected and maintained regularly by a competent person. According to the Health and Safety Executive (HSE), the frequency and type of maintenance should be determined through a risk assessment, taking into consideration:
- the manufacturer’s recommendations;
- the effect of temperature, corrosion etc. from the natural environment;
- the intensity of use; and
- the risk to health from potential foreseeable malfunction.
EV smart chargers are fixed electrical installations, meaning that they are subject to The Electricity at Work Regulations 1989. These Regulations state that all fixed electrical installations must be regularly maintained to prevent danger, so far as reasonably practicable, to workers, visitors, and others.
With reference to fixed wiring, the Requirements for Electrical Installations – IET Wiring Regulations set out the standard for electrical installation in the UK and can be used to comply with the 1989 Regulations.
As an employer, you need to consider who is competent to carry out electrical inspection and maintenance within your company or if you need a qualified contractor to do the work for you.
Don’t forget: you will also need to keep records of inspection and maintenance of EV smart charge points in your maintenance register.
Before considering installing EV smart chargers in your workplace, you must first understand your health and safety duties. EV smart charge points are work equipment; therefore, you must ensure that they are safe for use by workers by:
- choosing suitable equipment;
- training workers on the proper use of equipment;
- inspecting and maintaining equipment (e.g. software, electrical etc.); and
- keeping the maintenance register up-to-date.