Electric Vehicle Maintenance Standards
Electric Vehicle Maintenance Standards
Electric Vehicle Maintenance Standards
MAINTENANCE STANDARDS
CONTENTS
SECTION 1
Next Steps...................................................................................................................................................... 3
SECTION 2
Regulation Recommendations.................................................................................................................. 5
SECTION 3
Supplementary Evidence............................................................................................................................ 10
ELECTRIC VEHICLE
MAINTENANCE STANDARDS
DISCUSSION
WITH THE MINISTER JOHN HAYES
Former minister John Hayes indicated that he understands and supports the IMI’s call for an accreditation or licensing
of technicians:
“…As the professional body for the automotive industries, the Institute of the Motor Industry is well placed to help the
Government understand the challenge of ensuring that vehicle maintenance and repair is carried out in a professional
and safe manner for both technicians and drivers.”
I agree with the hon. Member for Kingston upon Hull East. Furthermore, I agree that we need to codify and accredit
such skills. The argument becomes, therefore, not about intent, but about method. It is probable that we are at too
early a stage to be certain about what that kind of accreditation might look like. Nevertheless, I am happy to agree
to have further discussions with the Institute of the Motor Industry and others to help the Government to understand
the challenge of ensuring that vehicle maintenance and repair is carried out in a professional and safe manner for
technicians and drivers.
“Skills are critical to the success of this industry. I recommend to my hon. Friend the report by the Institute of the Motor
Industry that addresses exactly those points. It highlights the accreditation system that it has put in place and recognises
that, so far, only a small proportion of the technicians and people who service cars more widely have achieved the
necessary competences to work on electric vehicles—of course, autonomous vehicles are yet to come”.
As per the request of the Minister the IMI and the Office for Low Emission Vehicles designed three recommendations of
how accrediting and certifying technician skills should be applied.
Recommendation 1: Reforming the Electricity at Work Regulatory Framework to ensure that all technicians working on
electrically propelled vehicles are competent to do so.
Under this proposal, government would support a licensing register that proves individuals are competent, skilled and
identifiable through a mandatory instrument, such as an industry supported professional register.
Government would mandate a comprehensive and robust electrically propelled vehicle Competency-Based Standard,
which clearly defines the technical details required to achieve safe working activities on Hybrid and Electric and Fuel Cell
Vehicles and achieves compliance with the legal requirements of the EWR 1989 and the Safety at Work Act 1979. Government
mandation signals that anyone who wishes to work on Electric Vehicles must satisfy the standards set, which would be
implemented by the industry professional body.
A Competency-Based standard would be designed with the objective of ensuring that technicians are competent to prevent
electrical danger and injury and therefore possess the relevant technical knowledge or experience demanded when working
on such vehicles.
A primary example of completing a mandatory qualification relevant to the automotive sector is seen through the ‘F-Gas’
(EU No 517/2014) qualification that must be completed in the End-Point Assessment for all automotive technical routes. The
qualification assesses installation, commissioning, service, maintenance and testing of refrigeration, air conditioning and heat
pump equipment containing or designed to contain refrigerants.
The industry favours the first recommendation offered in this presentation, for reforming the Electricity at Work Regulatory
Framework to ensure that all technicians working on electrically propelled vehicles are competent.
The IMI have worked closely with the industry for decades and throughout this time has ensured that its views on licensing are
guided by those who would work within the parameters set by such legislation.
The IMI would like to request that the Minister considers the views of his esteemed colleague the Rt Hon John Hayes MP
and the views of the sector and work with the IMI to ensure that the industry is skilled, competent and remains resilient to the
challenges it faces in the next five to ten years.
INTRODUCTION
The Institute of the Motor Industry (IMI) is the Professional safety of individuals working in the sector and to defend the
Body for people working in the automotive sector. The interests of consumers. It does this by running a voluntary
sector as a whole—supply chain, manufacturing and retail— licence to practise based on skills accreditation, qualifications
generates £160 billion in turnover every year. The IMI and Continuous Professional Development (CPD). The
certificates 100,000 people per year from its range of over Professional Register is a publicly searchable database that
300 regulated and non-regulated qualifications and skills allows the public to find appropriately skilled and qualified
accreditations. These include apprenticeships and DVSA industry professionals. The Professional Register is the
MOT tester assessments which supports business across the British Standards Institute’s preferred register for auditing
sector. The motor industry remains largely unregulated, so for BS10125 – the specification for vehicle damage repair
anyone can set up in business to repair and service motor processes applying to body-shops and garages.
vehicles. In this environment the IMI attempts to protect the
The IMI urges the Government to consider one of the three recommendations made in this paper as a means of regulating
motor vehicle technicians who will endanger themselves or others by working on Electric and Hybrid Vehicles. Current
regulation does not adequately extend to Electric and Hybrid vehicles as outlined by the Health and Safety Executive1.
There are four principles that the IMI’s recommendations seek to underpin:
1. Ensure a skilled workforce. New technologies provide the UK automotive industry with an unparalleled
opportunity to lead the global skills race.
2. Guarantee a mobile and agile workforce. Standardising skills ensures that the UK has an automotive workforce
that is mobile and adaptable to change.
3. Improved Health and Safety standards- untrained “have-a-go” individuals, are putting their lives at risk by
attempting to repair and maintain Electric and Hybrid Vehicles.
4. The UK leading the global skills agenda. Regulating the repair of vehicles with automated and electrically
propelled technology will ensure that the UK’s workforce is safe and well trained, underpinning a global presence
that sets precedence in the international community.
RECOMMENDATIONS
I. LICENSING COMPETENCY:
The IMI believes that the most efficient way to ensure that The Health and Safety Executive (HSE) takes a ‘catch-all’
the automotive retail sector lives up to the core principles broad approach, stating that regulation covers almost
outlined is for the Government to support a licensing every conceivable electrical danger, that ‘systems in
register which proves individuals are competent, skilled, and vehicles’ are covered and embraces all work which could
identifiable through a mandatory instrument, such as, the lead to electrical danger. The open-ended wording of the
industry endorsed Professional Register. regulations in the EWR 1989 is sufficient to catch the activity
of technicians working on ‘vehicles’. But it is precisely the
The IMI recommends that to ensure Electric Vehicle broad interpretation of the regulation which creates difficulty
Competency-Based Standards meet the requirements of by failing to establish the technical details and procedures
business and protect technicians from the danger posed by required and subsequently upheld in helping to keep
working on Hybrid and Electric Vehicles, government will technicians safe from the danger of electricity when working
need to bring about significant changes to consolidate and on such complex vehicles.
extend the provisions of the Electricity at Work Regulations
(EWR) 1989. The EWR 1989 is the statutory framework that Consequently, reform is needed to fill the regulatory void
outlines precautions against the risk of death or personal created by the EWR 1989 and to help keep the existing
injury from electricity in work activities. These regulations regulations modern and in line with rapid changes to
extend from the primary source of legislation governing technology within the automotive sector.
occupational health and safety in the United Kingdom, the
Health and Safety at Work Act 1974. As the industry’s professional body the IMI would assist
the Government in revising the statutory framework so
Whilst the IMI acknowledge the purpose of the regulations that it is fit for purpose, future-proofed, and transparent for
in upholding safety for those encountering electricity industry audit.
during work activities, the IMI consider the language of the
regulations to be lacking when applied to the skilled, yet
potentially dangerous, practice of maintenance and repair of
Hybrid and Electric Vehicles.
The IMI proposes that if statutory reform is not on the agenda, The IMI would work with industry auditing authorities such as
then as a minimum, the Electricity at Work Regulation 1989 the Health and Safety Executive and British Standards Institute
(EWR) must be supported by a comprehensive and robust among others, to access the Professional Register to randomly
Electric Vehicle Competency-Based Standard. The standard audit professionals who have met the mandated Electric Vehicle
adequately defines the technical details required to achieve Competency-Based Standard.
safe working activities concerning Hybrid and Electric Vehicles
and to achieve compliance with the legal requirements of the The proposed model does not differentiate from other regulatory
EWR 1989. By implementing this change, a proposed standard standards and will positively impact business in the sector by
would complement other provisions of the EWR 1989, such as minimising transactional costs, mitigating risk, and minimising
Regulation 16 and its objective to ensure that technicians are reputational costs. The IMI identifies that improved training and
competent to prevent danger and injury and therefore, possess recognition of skill and competency has led businesses in the
the relevant technical knowledge or experience of electricity sector to realise more extensive economic opportunities, and
demanded when working on such vehicles. improve public confidence that repairs and maintenance are
completed correctly and safely.
The IMI recommends that the Government mandate that
any individual or business that wants to work on Electric The IMI strongly recommends that the Government mandate
Vehicles must satisfy the standards set by the Electric vehicle an Electric Vehicle Competency-Based Standard that sets
Competency-Based approach implemented and monitored guidelines for technicians, proves skills and knowledge, and
by the industry’s professional body, i.e. the IMI, that have the importantly ensures that Vehicle Technicians adhere to the
proven skills and industry endorsed model to do so. regulations established by the Electricity at Work Regulations
1989 and the Health and Safety at Work act 1974.
The IMI aim to work with the Health and Safety Executive to
create a regulatory best practice framework that will detail
the operational safety requirements needed to work on
Electric Vehicles. Employers will determine the Electric Vehicle
Competency-Based Standard drafted by the IMI. The standard
will broadly set out that anyone working on and around electric
and hybrid vehicles should be able to demonstrate competency
to do so safely. Currently, the industry indicates this equates to a
Level 3 qualification.
Apprenticeships represent one of the best routes to End-Point Assessment. 2.The addition of further technical
employment. The automotive retail sector benefits from training may affect the current funding bands that apply to
approximately 12,000 apprenticeship starts each year, each of the pathways. For instance, Heavy Vehicle attracts
boosting the economy and productivity of the sector. £18,000 of funding today - this could increase to the highest
Mandating a qualification or a Competency Standard within funding band which the IfA would have to assess. 3. Finally,
the Apprenticeship is not radically different to today’s including the Electric Vehicle Competency/qualification in
structure. The F-Gas qualification (EU) No 517/2014), for an apprenticeship will only ensure that candidates, three
example, is a mandatory requirement for completion of the years after implementation of the mandate, are skilled to
End-Point Assessment for all automotive technical routes, work on electric vehicles, which does nothing to address the
in line with EU legislation. The regulation specifies that current concerns outlined by the IMI and the sector. In fact, it
everyone involved in the installation, commissioning, service, creates a broader skills gap between current technicians and
maintenance and testing of refrigeration, air conditioning apprentices.
and heat pump equipment containing or designed to contain
refrigerants needs to hold this qualification – the industry While including a Competency-Based Standard or
has accepted the requirement across the board. In a similar qualification within the current Apprenticeship Standards
vein, the IMI and the industry believe that introducing an may cause some disruption. Apprentices will benefit
Electric Vehicle Competency-Based Standard, which in its greatly by having early exposure to advanced vehicle
first iteration would focus on the electrification of vehicles, technology in their training.
but evolve to include automated technology, would benefit
the sector at large (See Figure 2.). By including the mandated
Electric Vehicle Competency-Based Standards into the
current Apprenticeship Standards the Minister will future
proof skills and by proxy the health and safety of future
technicians.
CONCLUSIONS
In this paper, we have outlined three recommendations for supporting the automotive retail sector’s transition from internal
combustion engines to advanced Hybrid and Electric powered vehicles. The risk to health and safety is real and needs to be
addressed with urgency. However, it is also an imperative that the regulatory mechanisms are in place to support micro and
SME businesses that will come into contact with these vehicles and will have to defer business because of a lack of skills.
The automotive sector is “coin-operated” and independents are guilty of being complacent and not investing in training
unless a regulatory instrument suggests otherwise. The IMI is seeking government support in mandating a requirement for
Competency-Based Standards to support the industry in technologically disruptive times.
SUPPLEMENTARY
EVIDENCE
This supplement provides the Office for Low Emission Vehicles (OLEV) additional evidence in support of the IMI’s
recommendations for a mandatory competency based standard for Technicians working on Hybrid and Electric Vehicles.
percentage gap had remained constant at 43.4% (www. and Electric vehicles. The IMI believe fervently that further
motoreasy.com). Therefore, by reducing consumer choice for clarity is needed surrounding issues such as battery
car repairs, consumers could be penalised, having to pay, on isolation, using the right equipment, including personal
average, 44% more for repairs or servicing by manufacturer protection equipment, and ensuring that the environment
franchise dealers. is safe for work to commence, etc. Although it is not
appropriate to detail a step-by-step procedural approach,
the HSE documentation does make reference to a need
3. Will repairs and maintenance continue to be carried
for individuals to have “Additional skills and training…
out through independent garages? The warranty for
necessary to allow people to work safely with E&HVs…”
batteries from most manufacturers (lasting 8 years or
alluding to ”Specific training with qualifications awarded
100,000 miles on average) dictates that work should
by organisations such as IMI Awards” (HSE common repair
be done through franchised dealerships.
topics: MVR).
11. As the Electric Vehicle market is still in its 13. Have you gauged any interest in this
infancy, if competency-based standard is applied proposal in industry?
to apprenticeships, can this be seen as a proactive
approach to addressing future skills issues at an
The IMI has been calling for a licence to practise for those
early stage?
working on electrified vehicles since 2012 when Steve
Nash was appointed CEO. As a professional body, the IMI
The SMMT estimate that 47,000 new plug-in cars had been strives to voice the concerns of the sector it represents,
registered over the course of the year in 2017, an average from which there is resounding support for licensing. In fact,
3,916 vehicles per month. Data from the Department of in December 2017 the IMI asked the sector (34,000 people
Transport suggests, that from 2010 to 2017 (Q3), 272,970 from independents and manufacture franchise groups)
Hybrid and Electric Vehicles were registered for the first whether they still thought a licence to practise was right for
time. These figures of course do not include the number the industry and a resounding 98% agreed that government
of vehicles registered since 1998 when the first Hybrid, the should regulate the industry to maintain standards and safety.
Honda Insight, was sold in the UK. The estimates indicate a In addition, the IMI also contacted several employers for
dramatic growth in the number of vehicles with an Electric or direct support. Employers including Halfords, BMW, Scottish
Hybrid engine. In addition, Autotrader one of the UK’s largest Motor Trade Association, Marshal Motor Group, The London
used car selling platforms currently has 7,285 Hybrid and EV Company, Kwik-fit, and others all support a licence to
714 Electric cars for sale, demonstrating that the used car practise. Why? Because the standards recommended by the
segment will grow as fast as the new car segment. Therefore, IMI are already in place across the manufacturer network’s
the proliferation of the Hybrid and Electric Vehicles entering and standardisation of skills has improved productivity and
the independent sector for maintenance and repair will social mobility of technicians across the country.
inevitably increase. Supporting an approach that mandates
qualification competency standards to apprenticeships is
proactive. However, it is also necessary to consider the
242,868 technicians who are already engaged in the service
and repair of vehicles. A solution for this group as proposed
by the IMI is equally important.