EV Charging & Fire Safety: What Your Business Needs to Know
Electric vehicle charging points are appearing across workplaces, business parks, fleet depots and residential car parks at a remarkable pace, driven partly by demand and partly by the building regulations, since Approved Document S now requires charge points or their cabling in many new and renovated buildings. What many of the businesses and managing agents installing them have not yet caught up with is that adding charging changes the fire risk profile of the building, and that the building regulation which puts the chargers in place expressly does not deal with electrical or fire safety, leaving that to be picked up elsewhere. In practice that means your fire risk assessment, and for a great many premises the assessment on file was written before a single charger was installed and no longer reflects the building as it now operates.
This article explains why charging matters for fire safety and what your fire risk assessment now needs to take into account, whether you run a workplace or a fleet, or you manage a residential or mixed-use block. It draws on the Fire Protection Association and RISCAuthority guidance RC59, which sets out current best practice for the responsible person.
Why EV charging changes the picture
Electric vehicles are powered by lithium-ion batteries, and while serious incidents remain infrequent given the sheer number in use, the way these batteries fail is what sets the hazard apart. A lithium-ion cell stores a large amount of energy alongside a flammable electrolyte, and if a cell generates more heat than it can shed it can enter a self-sustaining process known as thermal runaway, releasing a mix of gases that are variously flammable, toxic and corrosive, and leading to a fire or even an explosion. The risk is at its highest while a battery is charging, particularly if a cell is already defective, which is precisely the activity these charging points exist to carry out. A fire of this kind can burn for hours, can produce a jet of burning gas from beneath the vehicle, and can reignite some time after it appears to have been put out, which is why the precautions are more demanding than for a conventional petrol or diesel car.
Why a lithium-ion battery fire behaves so differently from a conventional vehicle fire.
The overnight problem
The single most important point for a business is that charging usually happens when nobody is watching. Vehicles are routinely left on charge overnight and across weekends, exactly when premises are at their least occupied and a developing fault is least likely to be noticed, so the hazard sits in the category of an unattended process, with all the additional risk that implies. For a fleet operator with vans charging in a depot, or a managing agent responsible for a residential car park where residents are asleep above, the consequence of a charging fire taking hold unobserved is a great deal more serious than the frequency of such fires might suggest, and that combination of low likelihood and high consequence is the heart of why the assessment needs to be revisited.
What your fire risk assessment now needs to cover
Where electric vehicles are charged on commercial or industrial premises, the guidance is clear that the fire risk assessment should specifically address the risk this introduces, and it sets out a number of measures to consider. These include the physical segregation of charging areas from process and storage areas, a power supply and control arrangement that allows the chargers to be isolated from a safe location without shutting down the rest of the business, particular provision for the period when the premises are unoccupied, suitable automatic fire detection, portable firefighting equipment together with fixed suppression where that is proportionate to the risk, an emergency action plan that protects both people and the continuity of the business, and training for staff in the safe use of the equipment and in what to do if a fire occurs, including how to isolate the power and evacuate. The same thinking applies in residential settings, with particular care where people may be sleeping in the building.
- Charging points should normally be located outside the building where this is possible, and protected from vehicle impact by kerbs, bollards or a raised island.
- An internal charging area should ideally be a detached single-storey structure, and where it is not, it should be separated from the rest of the premises by construction giving at least 60 minutes fire resistance.
- Enclosed charging areas should be kept clear of storage, with at least 6 metres separation, and at least 10 metres from any hazardous-substance zone.
- Basement parking with charging should be separated from the rest of the building by structure giving at least 120 minutes fire resistance, with sprinklers and ventilation considered at the planning stage.
- Internal charging areas should have automatic fire detection to at least a P2 standard under BS 5839-1, installed by third-party certificated contractors.
- Sprinklers are strongly recommended for enclosed car parks with charging points, and are regarded as the best form of active protection in that setting.
Where the chargers go
Location is the first decision, and the guidance favours putting charging points outside the building wherever that is practical, well lit and protected from vehicles being driven into them. Where charging has to be indoors, the segregation requirements described above come into play, and the aim is to ensure that a fire in a charging vehicle cannot readily spread into production areas, storage or the occupied parts of the building. Multi-storey car parks call for charging to be placed in open areas with good access for firefighting, and basements are treated with particular caution given how hard a battery fire is to reach and extinguish below ground, which is the reason for both the higher fire-resistance standard and the early consideration of sprinklers. These are the sort of judgements that a fire risk assessment is there to make for your particular building, and they are difficult to retrofit sensibly once chargers have already been positioned without that thought.
A particular word for managing agents
If you manage a residential or mixed-use block, the guidance treats a multi-tenanted residential building with internal or underground charging in the same way as a commercial or industrial site, which means the detection, segregation and protection expectations apply to your car park just as they would to a factory. That is a significant point, because charging is increasingly being added to existing blocks where it was never contemplated when the building was designed, and where residents are sleeping directly above or beside the parking. For managing agents and the responsible persons in residential buildings, the installation of chargers is a change that should prompt a review of the building's fire risk assessment rather than being handled purely as an electrical or parking matter, and it sits alongside the wider duties that already apply to the structure and common parts.
Detection, isolation and the emergency plan
Three practical provisions tend to need attention once chargers are in. The first is detection, since an internal charging area should be covered by a properly designed and maintained automatic fire detection system, installed and serviced by certificated contractors and tested regularly, so that a fire developing out of hours is picked up as early as possible. The second is isolation, because there should be a clearly signed emergency means of cutting the power to the charging points from a safe location, accessible both to trained staff and to the fire service, with lock-off so that it cannot be reinstated during an emergency. The third is planning, which means an emergency plan that takes account of how long a battery fire can burn and the specialist clean-up a thermal event can require, a hazard information point so that firefighters know on arrival where the chargers are and how to isolate them, and trained staff who understand the procedure. For businesses, a business continuity plan that anticipates the loss of a charging area or the vehicles in it is a sensible companion to all of this.
The legal backdrop
The duty that ties this together is the familiar one. Under the Regulatory Reform (Fire Safety) Order 2005, the responsible person must ensure the fire risk assessment considers practical passive, active and managerial measures when areas are selected and designed for electric vehicle charging, so charging is squarely within the scope of the assessment you are already required to maintain. Depending on the premises, two further regimes may apply, namely the Dangerous Substances and Explosive Atmospheres Regulations where flammable or hazardous substances are present nearby, and the Electricity at Work Regulations, under which duty holders must keep the charging installation safe as they would any fixed electrical installation. The point worth holding on to is that none of these is satisfied automatically by the building regulations that required the chargers, and the responsibility for fire safety rests with the responsible person and is discharged through the assessment.
What to do now
If you have installed electric vehicle charging, or you are planning to, the practical step is to have your fire risk assessment revisited so that it reflects the building as it now functions rather than as it did before the chargers arrived, and ideally to do this at the planning stage, when the location, segregation and protection can still be shaped rather than worked around. We carry out fire risk assessments for workplaces, industrial sites and commercial premises, as well as for the residential and mixed-use blocks managed by agents, across business parks and developments in places such as Greater Manchester and Cheshire, and because we do not sell or install charging or detection equipment, our advice is concerned only with whether your arrangements are safe and compliant.
Installed EV charging, or planning to?
Fletcher Risk carries out fire risk assessments for workplaces, fleet operators, managing agents and industrial sites across the North West, North Wales and the West Midlands. We will review how electric vehicle charging affects your building and advise plainly on segregation, detection, isolation and the emergency plan, independently of any installer. If we can help, please get in touch.
We cover Cheshire West, Cheshire East, Merseyside, Greater Manchester, Lancashire, Flintshire & Wrexham, the North Wales Coast, Gwynedd, Shropshire and Staffordshire.
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