|Contradictions and confusion |
Craig Ross, a Eurofit Training Manager, has written a letter to us about the contradictions and confusing situations which arise when trying to make sense of DVSA’s advice on Testing electric vehicles. As we ourselves had already done, he has found a Government (DVSA) piece on the Internet which goes into much more detail about how such vehicles should be inspected, but also notes that much of the advice is open ended, not very helpful, and sometimes contradictory.
Even so, it was better than the scant information in the Manual, but is buried in a “.gov” website and not easy to find – and there’s no link from the online Manual or Guide to find it.
Here are the main issues which arise regarding DVSA’s advice on the MOT inspection of electrically powered vehicles both from the Manual, and that hidden DVSA document.
The number of electrically powered vehicles on UK roads has increased from 3,500 vehicles in 2013 to 227,000 by the end of August 2019 and growing fast. Although still relatively rare, soon MOT Testing of these vehicles will be commonplace.
But has Tester safety been ignored by DVSA and the Health and Safety Executive (HSE), who have so far supplied very little – and sometimes contradictory – guidance for Testers, who will be putting their hands on or near potentially life-threatening high voltage components?
Inspecting electrically powered vehicles during an MOT Test is different from the conventional vehicles Testers are used to. Their battery voltages of up to 600 volts can deliver fatal electric shocks and their operation differs significantly from conventional cars, so given the serious safety risks which apply, special precautions are needed when Testers inspect electrically powered vehicles. There are also differences within various types of vehicles adding further complexity.
Yet MOT Testers, while expected to be familiar enough with detailed technical aspects of these vehicles to safely carry out an MOT Test on them, are being given very little guidance with regard to the dangers, or proper safety procedures, and may be unable (as advised by DVSA/HSE) to access vital safety information from vehicle manufacturers.
A new generation of vehicles
Broadly the different types of electrically powered vehicles are:
- Pure electric battery powered vehicles
- Hybrids (with an internal combustion engine charging the main battery)
- Plug in hybrids which can be recharged from an external power source.
- Fuel cell powered vehicles with hydrogen and oxygen stored at very high pressure – an added hazard in addition to that of high voltage electrical systems – although currently these are very rare.
The electrical stored energy in these vehicles provides an entirely different safety hazard to those faced by Testers inspecting conventional petrol or diesel fuelled vehicles. It should also be noted that there’s no convention as to the colour of high voltage cabling, although orange seems to be the predominant choice. So how do the DVSA and the Health and Safety Executive provide clear and comprehensive guidance to ensure Testers can safely inspect such vehicles, and AEs can provide a safe environment for them to do so? Well – in fact, they don’t!
Inspecting electric vehicles and Health & Safety
Testers as employees have a responsibility for their own ‘health and safety’, as well as that of their fellow employees when inspecting vehicles for the MOT. Their bosses, Authorised Examiners (AEs), are directly responsible for providing a safe work-place, and for conducting a ‘risk assessment’ of all the tasks employees carry out whilst at work, including MOT Testing; a responsibility regulated by the Government’s Health and Safety Executive (HSE).
Yet at the same time AEs must ensure that Testers inspect cars for MOT purposes in accordance with DVSA’s requirements in the Testers’ Manual and the Guide to the MOT, as are Testers themselves.
So what are Testers and AEs to do when these two sets of responsibilities are in conflict? Unfortunately, that’s exactly what’s happening regarding the situation when Testers inspect electrically powered vehicles for MOT purposes.
HSE and DVSA conflicting regulations
First let’s look at what the HSE have to say about electrically powered vehicles being ‘worked on’, which must be assumed to include MOT inspections:
“There are substantial differences in the designs of Electric and Hybrid Vehicles from different manufacturers. Having information specific to the manufacturer and the vehicle being worked on is important in identifying what actions are necessary to work safely”.
Here’s a problem. The MOT Scheme requires that all vehicles presented for MOT must be inspected unless they fall into specific categories where a Tester can refuse to carry out the test. Yet in a DVSA’s document entitled Hybrid, electric and hydrogen fuel cell systems: guidance for MOT testers, they specifically say about electrically powered vehicles:
“You can’t refuse to carry out an MOT test on one of these vehicles because you’re not familiar with them”. Adding, “Always check the vehicle’s handbook or speak to the owner if you’re in any doubt.”
And the Testers’ Manual also says…
“You must inspect all visible electrical wiring, other than on Class 3 vehicles.
You must inspect the battery(ies) on all vehicles including electric and hybrid vehicles (our emphasis).”
Surely it is unlikely that the handbook (or the owner) would be able to provide the detailed information Testers need to make a proper risk assessment as to which cables are high voltage or not, or how to inspect both those cables and the battery safely? Yet, the HSE requirement of ‘information specific to the manufacturer and the vehicle being worked on’ is a much more specific and stringent criteria.
So how are Testers and AEs supposed to safely execute their responsibilities to both the HSE and DVSA when inspecting electrically powered vehicles? It seems like they can’t!
Informed decisions and experience
For Testers to work safely, and for AEs to ensure a safe, risk managed environment to inspect electrically powered vehicles, they both need to make informed decisions – which requires vital specific information on every type of electrically powered vehicles in use on the roads and in some circumstances (eg high voltage cable colouring) specific models. DVSA used to provide Vehicle Specific Information (VSI) on the MOT computer for conventional vehicles’ quirks and foibles but that’s now stopped. If available, VSIs would provide perfect guidance for Testers inspecting electric vehicles.
Familiarity and experience
This is also an issue. To become a Tester DVSA require not only appropriate training, but also that candidates must have been working as technicians for at least four years on the vehicles of the Class they will be inspecting. DVSA insist that such familiarity with vehicle systems is essential to properly and safely inspect vehicles presented for Test. Yet how many current Testers will have the same wide experience of servicing and repairing electrically powered vehicles, with their diverse power train designs, and different risks regarding their high voltage batteries and associated cabling.
Well, OK, there’s been a rapid growth in the use of electric vehicles in recent years and DVSA haven’t caught up – but the pace is quickening. At the very least DVSA should by now have set up a separate section within the current training syllabus on the appropriate procedures for safely inspecting the different types of electrically powered vehicles Testers are likely to encounter. But it hasn’t happened… So what advice does DVSA provide?
When it comes to the Testers’ Manual, apart from the section we have quoted above about inspecting ‘wiring’, and the ‘battery’ on such vehicles, the only direct reference to the safety aspect of testing electric vehicles is to be found under ‘Health and Safety’ in the ‘Introduction’ section which says:
“You should take care when testing electric and hybrid vehicles as:
there may be high voltage present at any one of several points around the vehicle, including storage capacitors and batteries on hybrid vehicles, the engine may start without warning when electrical equipment is operated or if the battery voltage drops.”
And, as regards the Manual, that’s it! But let’s look at that ‘hidden’ DVSA document entitled “Hybrid, electric and hydrogen fuel cell systems: guidance for MOT testers”
This is more comprehensive, especially in describing the different types of electrically powered vehicles, and it does offer advice on inspecting electrically powered vehicles, but it’s not as helpful as it could (or should?) be. The practical advice section starts by saying, “…the biggest danger with hybrids and electric vehicles is that the vehicle may start or move off and cause injury or damage”, and goes on to say that Testers need to know how to drive and immobilise the vehicle, explaining how that might be achieved, and to ensure an assistant also knows what to do. All well and good, but is that really the “biggest danger”….
The next section however, entitled, “Risk from high-voltage systems” is somewhat imprecise. Initially it says there’s a “theoretical risk” due to the “very high voltage used in these vehicles” and goes on to note that “these are lethal levels”. It also says, “The cables and some components are coloured orange. This can extend to other components, for example, air conditioning and power steering”. This clearly highlights the uncertainty as to which cables are live and which are not.
It then advises caution, and to assume that the “battery and associated components are energised and fully charged” and, “Don’t interfere with the high-voltage system”, and repeating the adage that, “no dismantling is needed when carrying out an MOT Test” . Then lastly, it says, “abandon the test in the unlikely situation that any orange coloured cables or components are damaged or the wires are exposed – these are a potential shock hazard”.
The last point is important. DVSA acknowledge that potentially lethal high voltage cables could be damaged or exposed – clearly a fatal electric shock risk. So what if a Testers can’t see all of the cables, but may have to feel around some cables largely hidden from view to conduct a different part of the MOT inspection? A live exposed cable could easily be inadvertently touched. We’ve also heard that cables coloured other than orange (possibly blue) could also carry lethally high-voltage electricity – how would a Tester know when Testing a type of electric vehicle he or she is unfamiliar with or, hasn’t even seen before?
A serious Government failure?
What we see here is a contradiction between the HSE’s advice and DVSA’s regulatory rules. HSE insist that before ‘working’ on electric vehicles – and as Testers are inevitable feeling around all parts of a vehicle to properly inspect it for the MOT, that must be ‘working’ on such vehicles – Testers should have ‘specific’ information about the vehicle and its high voltage cabling to do the job safely. DVSA’s suggestion that the handbook, or owner’s advice is adequate, must be wrong.
Yet DVSA insisting that Testers’ not having adequate information about the electrically powered vehicle they’re inspecting doesn’t justify a ‘refusal to test’ the vehicle – must also be wrong.
On the other hand, whilst offering specific advice about working on electric vehicles regarding, cleaning and valeting, sales, and maintenance and repair, the HSE ignores MOT Testing – arguably a major oversight.
Whilst with their high voltage cabling, inspecting electrically powered vehicles for the MOT is potentially dangerous, with possibly fatal outcomes, currently the risks are probably low. There are few electric vehicles compared to the 29 million or so tested each year. But until work is done to closely look at older electric vehicles to discover how far the cabling has deteriorated – it’s impossible to know for sure.
Sooner or later though, these vehicles will have frayed and deteriorating electric cabling, and the issue then be much more serious. So currently, whilst Testers and AEs should discuss the risks faced when inspecting electric vehicles, the best way to minimise that risk is to be very wary of any heavy cabling whatever the colour – and if in doubt, do not feel around such cabling which is hidden from view, and make a note if that has inhibited the Tester’s ability to complete a full MOT inspection.
Meanwhile, both the DVSA and the HSE should up their game. For DVSA a key issue is to ensure there’s appropriate training on Testing electrically powered vehicles in the Tester Training syllabus, and links in the Manual to provide more comprehensive information about the risks and how to avoid them when inspecting electric vehicles.
They should also look into providing Vehicle Specific Information on electric vehicles regarding cabling and safe Testing procedures – or allowing Testers unfamiliar with such vehicles to be able to refuse to inspect the vehicle if appropriate information about such vehicles is not available.
The DVSA should also be working closely with the HSE to ensure their joint safety advice is co-ordinated, appropriate and consistent.
What DVSA say…
We contacted the DVSA, sending them a copy of Craig Ross’ letter together with our own comments as noted here. As we understand that this has prompted them to review their situation with regard to Testing such vehicles, and they have provided us with the following statement on the subject from Chris Price, Head of MOT Policy:
“DVSA’s priority is helping everyone keep their vehicle safe to drive.
MOT testers are well trained professionals and we appreciate that electric and hybrid vehicles may be new to some of them.
If testers are unsure on how to operate these vehicles safely then they need to consult the vehicle handbook or speak to the vehicle manufacturer for more details.
DVSA is committed to providing the best possible advice to testers and garages to ensure they are safe and know how to test vehicles. We are reviewing current guidelines and will update them if needed.
The MOT test does not involve the dismantling of vehicles in any way, therefore the testing of electric and hybrid vehicles is low risk.”
How willing the vehicle manufacturers would be to provide details of their products is uncertain – what is certain is that it probably won’t happen very quickly!
In the meantime, with no wish whatsoever to be alarmist, we’re dreading the first “MOT Tester seriously injured in electric vehicle accident” headine.