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Some EVSE installations aren’t “normal”

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The requirements for the appropriate design, selection, installation, verification and maintenance of electric vehicle supply equipment (EVSE) have been around for some time now. However, with the constant evolution of better EVSE equipment and charging technology, as well as the rapidly changing electric vehicle (EV) battery and on-board charging technology, it is a challenge for those bodies responsible for writing standards and codes of practice to keep up with the changes. Add into that mix updates and amendments to BS 7671 and it is little wonder that the IET published a new edition of the Code of Practice for Electric Vehicle Charging Equipment Installation in 2023. 

The Code of Practice for Electric Vehicle Charging Equipment Installation, 5th Edition took into account legislative changes reflecting:

  • new regulations covered in the Smart Charging Regulations 2021
  • changes to Part S of the Building Regulations 2022
  • physical installation requirements and accessibility for Part M of the Building Regulations and PAS 1899 guidance
  • new guidance on the installation of telecommunications and auxiliary cabling
  • the revision of the requirements of a simultaneous contact assessment to accommodate a mix of earthing arrangements
  • considerations for fire safety in EV charging installations (recognizing RiscAuthority publication RC59) for domestic and commercial properties
  • new and updated appendices covering:
    • installation practices for earth electrodes
    • Mode 4 charging equipment, including details of pantograph connectivity systems for heavy goods vehicles (HGVs) and public service vehicles (PSVs)
    • guidance regarding the minimum depth of buried cables and minimum height of overhead suspended cables in different environments.
  • extended guidance covering earth fault loop impedance and residual current device (RCD) testing, including use of vehicle simulators for Mode 3 charging equipment and testing in prosumer's electrical installations
  • an expanded distribution network operator (DNO) notification section to include vehicle-to-grid (V2G) and vehicle-to-home (V2H) applications
  • updated guidance on inductive charging installations.

Although this is well and good for those designers and installers that install EVSE in domestic, commercial, retail and industrial settings (as long as they consider exactly the location of where the EVSE is being installed), as I’m sure readers of Wiring Matters will know only too well, there are always situations that are not “normal”!

It is one of those situations that falls into my specialist area of work. In the Code of Practice for Electric Vehicle Charging Equipment Installation, 5th Edition, in Section 4.2, the publication mentions “potentially explosive atmospheres”. I think it goes without saying that most people, both technically competent and non-technical, would understand that electricity, electrical equipment and EVs being charged, are not items that one would wish to install in a potentially explosive atmosphere, due the ignition risk of non-ex certified equipment, the likelihood of uncontrolled electrical sparks (especially where DC is involved) and hot surfaces.

Section 4.2.2 of the Code of Practice for Electric Vehicle Charging Equipment Installation, 5th Edition specifically mentions “fuel filling stations”

Given the many thousands of fuel filling stations storing and dispensing hydrocarbon fuels, and their ideal locations on the UK’s road network, it was of course going to be the case that the operators of those facilities, particularly those being approached by EVSE charging companies and equipment suppliers, would install EVSE on their filling stations. It was also a way of indicating that those selling hydrocarbon fuels wished to be seen as embracing and promoting “greener” alternatives, and it allowed those fuel retailers to offer their customers a variety of fuels.

The IET and the Association for Petroleum and Explosives Administration (APEA) worked together to publish a supplementary guide, Electric Vehicle Charging Installations at Filling Stations, in 2020. That publication provided the unique and critical information that should be applied when EVSE is being considered, or being installed, in those locations. The publication gave specific details to be followed, model examples of survey sheets and paperwork to be completed and retained, and references to other technical publications and codes of practice.

It was five years ago that the supplement was published and of course, as mentioned earlier, lots of changes have taken place since then, so it’s now time that the supplement is reviewed, updated and a new edition published.

Following the completed technical review and update of the supplement by the IET and the APEA, a new, second edition will very soon be available from the IET bookshop.

So, what does this updated second edition take into account? Primarily, of course, the review considered the appropriate parts of all other applicable standards that have been updated since 2020, the amendments to the appropriate parts of BS 7671 and the changes to the Code of Practice for Electric Vehicle Charging Equipment Installation, 5th Edition. The updated supplement has also taken into account the appropriate parts of the fuel filling station technical guidance document and code of practice that practitioners really know as the “Blue Book”, or to give it its full title, Guidance for Design, Construction, Modification, Maintenance and Decommissioning of Filling Stations, 5th Edition. This industry publication is jointly published between the APEA and the Energy Institute (EI), and was announced and published to the industry in November 2024.

Running in parallel to that, the APEA and the IET formed a technical committee, with myself representing the APEA and chairing the group, and Graham Kenyon as lead technical author. We had all the interested stakeholders involved, including the Health and Safety Executive (HSE), Petroleum Enforcement Authorities (PEAs), and EVSE installers and providers, to review and update the supplement.

In some ways, this technical work was simpler than the first edition as we were not sitting down with a blank sheet of paper and starting from scratch. We already had a document that we simply needed to refresh and update, taking into account the points and documents already mentioned.

Firstly, for those readers of Wiring Matters that design, install and maintain EVSE, is the EVSE and/or charging bays actually on a filling station? Just because the equipment or charging bay isn’t in the known hazardous areas of the filling station, doesn’t mean you are not installing on a filling station and you can install as per any other industrial or commercial installation. You certainly can’t.

In the UK, a filling station is the curtilage of land detailed and noted on the site plans (likely the land title deeds), with the local PEA then granting a storage certificate for the safe delivery, storage and dispensing of petroleum spirit to the site duty holder under the Petroleum (Consolidation) Regulations 2014.

If your EVSE sits within that curtilage, then you are installing on a filling station, so installation needs to comply with the details in Electric Vehicle Charging Installations at Filling Stations, 2nd Edition and with the appropriate parts of the 5th Edition of the “Blue Book”. Disappointingly, many don’t understand that until too late, which can be costly, but if energized, also down right potentially dangerous.

Under the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR), activities and equipment outside a known hazardous area that can have a detrimental effect on the safety of those flammable atmospheres, must also be subject to the DSEAR risk assessment and that’s important on a fuel filling station.

Are electrical contractors, engineers and practitioners confident their professional insurances cover them for such installations?

If something goes wrong, does the designer, installer, verifier and maintenance companies/individuals have professional insurances and competencies for working in such environments? As I mentioned, although the EVSE will not be in a hazardous area, the work is still on a filling station.

Installation of a secondary substation, excavations for foundations and cable duct routes, and installation of DC voltage cables, are not for the inexperienced on a fuel filling station with all the infrastructure and below ground services and fuel systems.

I would also suggest, if the EVSE is being considered on a plot of land adjacent to an existing filling station that is owned by another party, the designer still needs to consider the proximity of the EVSE and charging bays to the filling station with regard to detrimental effects. A quick call to the local petroleum officer will assist in that suitability.

So, what’s new, and what’s been added and changed?

From the “Blue Book”, we have a new requirement and example figure that designers and installers must consider regarding any likely extent of liquid fuel spills, dependent upon paving, drainage and degree of containment.

For example, if there is a gradient sloping towards an EV charging area from the fuel filling area, such that fuel from a spill may run into the charging area, consideration should be given to the installation of a suitable drainage channel to divert any spilt fuel to the site oil/water separator.

Figure 1 Consideration of site gradients and possible need for a drainage channel, copyright © APEA.

Also, from the updated “Blue Book”, clauses 9.5.11 “Electric Vehicle Supply Equipment (EVSE)” and 9.10.1.3 “Verification of electrical installation and equipment in non-hazardous areas”, are both cross-referenced in the Electric Vehicle Charging Installations at Filling Stations, 2nd Edition supplement.

The new supplement has re-enforced the differences between a “normal” EVSE installation and one on a fuel filling station. The model survey and electrical risk assessment forms have been reviewed and updated. A very important part of the supplement, like the first edition, is a full two-page flowchart that considers every single scenario with regards to electrical loads, earthing system type, availability of a sufficient electricity supply connection, and earthing and simultaneous contact assessment. Flowcharts are simple – the outcome is either “yes” or “no”. There is no middle ground. A huge amount of work went into that flowchart that allows the reader of the supplement to make a sound judgement on whether EVSE can be installed or not.

It is a requirement, and stated in the publications, that the EVSE must be interlocked with the fuel filling station emergency shutdown system. That is, if a site emergency occurs on the fuel filling station, activation of any of those emergency shutdown devices will automatically operate the primary protection device for the EVSE to the “open” position. Ideally, this is carried out by a fibre optic link.

It’s also a requirement that if the fuel filling station needs to be closed for any reason, the method of that closure automatically prevents the EVSE from charging an EV. We know that’s a contentious item for the EVSE charging company or operator, but something they need to understand is that it is different from any other commercial or industrial operation.

One area where we see issues, and is perhaps a critical item that’s not been carried out appropriately and is mentioned in the Code of Practice for Electric Vehicle Charging Equipment Installation, 5th Edition, is the appropriate fire risk assessment.

It goes without saying that a fire within an EVSE or car being charged is not a good thing in general, but on a filling station, the consequences could be so much greater! It certainly isn’t “normal”.

For myself, as someone who has designed and been involved with fuel filling stations for all of my career, I see these facilities as being “normal”.

For those contractors and engineers that may be competent, and who design, install, verify and maintain EVSE in domestic, commercial and industrial settings, being asked to do the same type of install on a fuel filling station is certainly far from being “normal”.

Obtaining, reading and understanding the peculiar requirements, and executing them, will be essential for a safe installation.

This new and updated supplement will be invaluable in allowing persons to meet their obligations.

Electric Vehicle Charging Installations at Filling Stations, 2nd Edition will be available to purchase in April 2025 from the IET bookshop.