Electric vehicles (EVs) include battery-powered electric vehicles (BEV), hybrid electric vehicles (HEV), plug-in hybrid electric vehicles (PHEV), and diesel-electric vehicles.
A comprehensive review of Queensland's Electrical Safety Act 2002 (the Review) was completed in 2021.
While the recommendations of the Review are being considered, licensing requirements for work on the propulsion parts of electric vehicles will not be enforced (under section 73 of the Electrical Safety Regulation 2013).
EVs may also include passenger cars, motorbikes, recreational vehicles, buses, or heavy vehicles (electric trucks) for use on the public road network, or specific vehicles for industrial use, such as mining vehicles. The following information does not consider electric trains, light rail, boats or planes.
EVs and other renewable energy technology is constantly changing and being improved. As technology changes, the risks and hazards can also change, making it important to consider if any new or existing technology impacts the risk profile of hazards and if additional steps are required to reduce risks (such as procedures, training or education).
Risks associated when working on EVs
EVs create unique safety hazards, typically operating at much higher voltages than other battery-powered industrial equipment such as golf carts, forklifts, sweepers and elevating work platforms.
This is particularly the case with electric heavy vehicles such as electric freight trucks, buses, and mining vehicles, which may operate at higher voltages than electric cars or motorcycles.
Working on EVs can expose workers and the community to the risk of serious injury or death through fire, explosion, toxic gases, electric shocks, arc flashes or exposure to battery electrolytes.
The following outlines the risks and potential impacts:
|Fire||Faults in electrical parts or short circuits occurring from damaged parts or unsafe work practices (especially related to battery circuitry of EVs) can cause fires and subsequent release of toxic gases, contaminants or explosion of battery cells which can cause injury or illness.|
|Explosion||When a battery is damaged or heats up uncontrollably, this may lead to thermal runaway resulting in an uncontrolled explosion.|
|Toxic gases||When a battery heats up uncontrollably and leads to an explosion (or violent deflagration) there is risk of toxic gases being released. These toxic gases are also highly flammable.|
|Electric shocks||Workers and others may receive an electric shock if they come into contact with components of the electrical system. Work on other parts of the vehicle (not involving the electrical system) may also involve the risk of shock if the isolation between the electrical system and the vehicle chassis has been compromised.|
|Arc flashes||Arc flashes may cause burns directly to the worker or through ignition of other materials.|
|Exposure to battery electrolytes||Battery electrolytes in liquid form are highly flammable and can lead to fire risks that can cause injury or illness.|
Safety requirements for work on EVs
Work on EVs must be performed in a way that achieves safe outcomes for everyone – the worker, the business, the end user and the wider community.
All persons conducting a business or undertaking (PCBUs) must meet the duties required under the Electrical Safety Act 2002 (ES Act) and theWork Health and Safety Act 2011 (WHS Act). This includes PCBUs that work on EVs.
Section 30 of the ES Act requires PCBUs to ensure the business or undertaking is conducted in a way that is electrically safe. This includes ensuring:
- all electrical equipment used in the conduct of the business or undertaking is electrically safe
- if the business or undertaking includes work which involves contact with, or being near exposed parts, the person performing the work is electrically safe.
Section 19 of the WHS Act outlines the primary duty of care for a PCBU. This requires a PCBU to ensure the health and safety of workers. This includes ensuring that the health and safety of other persons is not put at risk from the work being carried out as part of the conduct of the business or undertaking, so far as is reasonably practicable.
The WHS Act also requires a PCBU to provide and maintain a safe system of work and any information, training, instruction or supervision that is necessary to protect all persons from risks to their health and safety arising from work be completed as part of the business or undertaking, so far as is reasonably practicable.
Work on electrical parts of EVs must be performed by suitably qualified persons who are trained and competent in identifying and addressing:
- any relevant electrical safety risk (which could be informed by suitable industry work practices or procedures)
- any electrical and workplace risks associated with the task to be undertaken
- the relevant manufacturer’s requirements relating to the electrical parts and work activity.
General safety requirements for work on EVs
Safety requirements that the ESO will consider regarding EVs includes whether PCBUs have:
- adequate hazard identification, risk management and safe systems of work in place
- adequate training on any related electrical safety issues on the tasks to be performed.
PCBUs should consider the following when undertaking hazard identification, risk management and ensuring safe systems of work:
- hazard identification processes are conducted by trained staff (for both general hazards and electrical hazards)
- risk assessments of identified hazards are conducted by trained staff
- any processes, procedures, specifications, manuals or identified risks from the original equipment manufacturer are followed
- consideration is given to:
- legislative requirements and codes of practice
- relevant Australian Standards (such as AS 5732:2022 Electric vehicle operations — Maintenance and repair)
- suitable industry standards
- original equipment manufacturer work practices
- relevant safe work practice/procedure.
- consideration is given to any associated tasks that may impact on electrical parts (such as welding or grinding)
- access permit processes (such as establishing exclusion zones), tag and lock out processes
- work location and environment (e.g., wet weather, access and evacuation in an emergency)
- isolating, de-powering and testing the electrical system to ensure the system is de-powered prior to undertaking work, and re-testing as necessary (e.g., after leaving and returning to the area)
- discharging components that may hold an electric charge before working on or near them
- tools and equipment are adequate for the work, including using non-conductive tools where possible (or electrically insulated for the voltages present as required), and that tools are properly checked and maintained (e.g., test and tag processes and inspection regime, and unsafe label processes for damaged or defective equipment)
- processes are in place to ensure electrical safety if work is left uncompleted for any period
- testing of work once completed to ensure the outcome of the work is electrically safe
- adequate documentation and records are kept and signed by appropriately authorised persons.
If work is performed while parts are energised (e.g., some commissioning, fault finding or testing activities), adequate risk mitigation processes should be in place, such as:
- authorisation for the work
- ensuring only persons who are appropriately trained perform the work (including being trained in access permit process)
- reduction of voltages or separation of energised parts occurs as much as possible
- ensuring access to the work area is limited by using signage and barriers and is clear of obstacles or obstructions (but with identified access for emergency rescue or evacuation if required)
- safety observers
- suitable personal protective equipment (PPE)
- the prohibition of metallic personal items (e.g., metal watchband or jewellery)
- consideration of physical working conditions (e.g., limited space, need to reach over other parts, awkward positions to perform the work, risks if tools slip or are dropped).
A PCBU must ensure workers are provided with information, training, instruction, or supervision that is necessary for them to safely perform their role.
Training can be provided in a variety of ways but needs to be relevant to the worker and structured in a way to assists them to learn and understand complex electrical theory and related risks. Training may be obtained from various sources such as relevant national units of competency, registered training organisation training courses, professional association training, in-house training, and original equipment manufacturer training.
For electrical safety, training needs to ensure the worker obtains a good understanding of:
- electrical theory
- electrical circuits and electrical components
- extra low voltage
- low voltage and high voltage electrical risks and hazards
- fault currents and shock paths
- electrical insulation methodology and electrical protective devices
- actions to prevent electrical risk and hazards occurring
- understanding and use of electrical instruments
- understanding how to check for and identify defective or unsafe equipment (the equipment being worked on or electrical instruments used to perform the work)
- safe processes for fault finding, testing and verification processes.
PCBUs must ensure workers have the knowledge and skills required to work safely.
Workers must take reasonable care for their own safety and the safety of others in the workplace. Workers must also follow reasonable safety instructions and procedures.
Inexperienced workers may have limited knowledge of a PCBU’s practices and procedures. PCBUs should address a worker’s knowledge and skills during recruitment or as a part of their safety induction. Workers must be trained in the PCBU’s practices and procedures and should be mentored by more experienced workers if required.
When assessing competency, PCBUs should consider whether workers:
- perform tasks that are undertaken infrequently
- return from working in other roles within the business or from extended periods of leave.
As a minimum, PCBUs should consider a worker’s competency when:
- new technology or equipment is introduced that may require additional training
- new work practices or procedures are introduced
- new legislative requirements or standards are introduced.
Competency can be maintained through:
- regular refresher training for key safety tasks
- internal auditing programs
- accredited training to learn skills for new work or as a skills refresher
- training provided by original equipment manufacturers.
PCBUs need to make sure their workers follow safe work processes and procedures by ensuring there is adequate supervision, procedures are audited to ensure they are complied with, and procedures are regularly reviewed to identify if workers have the required skillsets to safely perform work.