written evidence submitted by the institute of the motor industry; … · 2017-11-16 · centres...

© Institute of the Motor Industry, Fanshaws, Brickendon, Hertford SG13 8PQ, UK

Written evidence submitted by The Institute of the Motor Industry; In support

of for the ‘Licence and Accreditation of Technicians working with Automated,

Hybrid, and Electric vehicles’

Executive Summary

The Institute of the Motor Industry (IMI) is the professional association for the automotive sector

representing all individuals that are training to work in, and who currently work in the sector. The UK

currently has 184,000 automotive technicians but only 1,305 (1%) trained to work competently and safely

on the high-voltage systems of Hybrid (including Plug-In Hybrid) and Electric vehicles.

The IMI believes that to ensure safe working conditions for individuals in the automotive service and

repair sector, and to drive consumer confidence in the use and ownership of Hybrid and Electric vehicles,

a licence for competent people who have their skills assessed against appropriate professional standards

needs to be implemented. The Licence should be publically visible and help consumers to easily identify

appropriately skilled individuals.

Recent research conducted by the IMI – ‘Is the automotive industry ready for new technologies?’ -

indicated that current regulation, i.e. ‘Electricity at Work Act’ and the ‘Health and Safety in the motor

vehicle industry’, fails to adequately provide safe working practices to anyone working on Hybrid or

Electric vehicles. This paper submitted to members of the Automated and Electric Vehicles Bill also

demonstrates that the automotive industry currently operates within a number of regulatory frameworks

with little apparent negative impact to business operation.


1. The IMI, as well as being the Professional Association for individuals working in the automotive sector, is

also the automotive retail sector’s principal Awarding Body and licensed Sector Skills Council. The

Institute, since its incorporation in 1920, established a Code of Conduct which made it compulsory for

members to keep their skills up to date through continuous professional development (CPD) and a

requirement for members to treat their customers ethically and fairly. The IMI has continued this ethos

ever since and believes that raising standards across the industry is critical to achieving consumer

confidence in the automotive sector. Through IMI services and products it interacts annually with 630

Centres (organisations which include FE Colleges, independent training companies, manufacturer

Training Academies), over 170,000 students, and over 200,000 skilled employees and employers from

right across the automotive sector. As such, the IMI has a heightened understanding of the challenges

that face businesses across the sector in keeping up with the ever quickening pace of technological

advancement. This submission seeks to support the amendments to the Automated Vehicle and Electric

Vehicles Bill previously submitted by Karl Turner MP in support of the IMI Licence to Practise and

Accreditation. As the industry’s Professional Association, the IMI is committed to assisting the

Government in the achievement of its aims to make the UK a World leader in the seamless introduction

of the new vehicle technologies.

2. The Automated and Electric Vehicles Bill is a welcomed instrument to enable consumers in the UK to reap

the rewards that improved transport technology and lower emissions can bring. The Bill sets the

preliminary framework to ensure the fourth industrial revolution of Automated and Electric vehicles fits

the legal and regulatory frameworks for seamless consumer transition to these new technologies. The

IMI supports the inclusion of amendment NC 17 (section 6 and 7) for the licensing and accreditation

scheme of technicians who will have access to and work on high voltage interconnected electric vehicles.

“This new clause would ensure that insurers should not have to bear liability to the insured

person for accidents caused by the vehicle being inspected, repaired or maintained by

unauthorised technicians in breach of the insurance policy. This would apply subject to

various conditions regarding the level of knowledge of the insured person or policyholder

about the insurance policy requirements. This clause would give the Secretary of State power

to make regulations on a scheme for authorised inspection, repair and maintenance of

automated vehicles by licensed and accredited technicians.” - (Karl Turner MP, Vicky Foxcroft

MP)”


3. The IMI suggests, that the current regulation, which operates within automotive sector businesses

provides insufficient legal protection for employers and technicians working with automated, Hybrid,

and Electric vehicles. Particularly, when considering business legal and liability obligations to employees

and consumers. The IMI believes that untrained technicians could potentially put themselves and

consumers in harm’s way raising the risk of injury and death through in correct maintenance and repair

procedures. The impact of which raises the cost of insurance to a business through increased liabilities

and the cost to the consumer. The Government must consider a Licensing and Accreditation scheme for

the independent sector as well consumers.

4. The Automated and Electric Vehicles Bill defines two key parts for legislation, the Automated Vehicles:

Liability of Insurers; and the Electric Vehicles: Charging. Although the IMI agree that these parts of the Bill

are vital for successful proliferation of new vehicle technologies into a naive consumer market, they

crucially fall short for infrastructural sustainability. The committee will have heard evidence from a

number of industry experts and understood their position on the wording of the Bill. However, the IMI

believes that the costs to insurers and to consumers –which has in part been referenced - is in part driven

by the cost of repair. Thus, by having a skilled licensed independent repair sector the insurance market

can and will remain competitive. In removing the capabilities of the independent sector to compete with

manufacturers there will be limited choice for the insurance market to seek competitive pricing for the

repair of Autonomous, Hybrid and Electric Vehicles. This action will undoubtedly result in a decline of the

size of the independent sector resulting in increased job losses.

5. Though this may seem somewhat future gazing, the IMI urges the committee to ensure that the new

clause (NC17 section 6 and 7), “Licensing and accreditation scheme for technicians working on automated

and electric vehicles”, is considered part of the legislation for the immediate and long term health and

safety of vehicle technicians exposed to high voltage systems. Currently, there are no regulations in place

that adequately protect the health and safety of vehicle technicians who may come in contact with

Hybrid, Plug-in Hybrid, or Electric powered vehicles which range typically between 650 volts at 6.5 amp-

hours to 1000 volts at 230 amp-hours, which are lethal combinations of voltage and direct currents. The

IMI’s research indicates that there are two regulations which from the outset would presumably cover

health and safety of technicians – but do not. The first, the Electricity at Work Regulations 1989, sets out

a defined set of rules for electricians working with low and high voltage systems making them safe to

work on. However, the way that these systems are made safe in a Hybrid or Electric vehicle differs

significantly from household or business property. It is therefore not feasible for an electrician who has


met the BS 7671 standard of competence (the Electricians Licence to Practise) to know how to make an

Electric or Hybrid vehicle safe to work on.

6. The second regulation is the Health and Safety in motor vehicle repair and associated industries regulation

2009 (HSG261) which again one would presume covers the safe working practices of working with Hybrid

and Electric vehicles. Although HSG261 includes 90 rules for working in a garage and adequately protects

employers and trained individuals against accidents in the work place based on working on the internal

combustion engine, the regulation falls short in describing best practise for those working on Hybrid or

Electric vehicles. HSG261 regulation ensures the provision and maintenance of plant and electrical

systems in work that are safe and without risk in the work place. The assertion of the HSG261 regulation

is that employees are able to work safely with fixed and portable electrical equipment but not inclusive

of motor vehicles. There is in fact little to no guidance for working on Hybrid and Electric vehicles in the

regulation except to refer individuals to manufacturer guidelines. Paragraph 353 outlines “repairs

following an accident, fault finding or work on the electrical system may involve access to potentially

dangerous electrical systems. As with all electrical work, the person undertaking the work must be

competent to do so” (The Health and Safety Executive, 2009).

7. To ascertain any possible Health and Safety gaps, the IMI conducted a thorough search of the HSE

website. The search was based on the key-words relating to health and safety for Hybrid and Electric

vehicles. In total, six pieces of material were earmarked for Hybrid and Electric vehicles, the most

prominent of which was the web page ‘Common Motor Vehicle Repair topics (MVR)’. Here the HSE has

created a useful platform where users can select areas of motor repair. Electric and Hybrid vehicles

feature here (HSE, 2017) – the article outlines the risk of working with electrified powertrains as well as

describing what constitutes as safe working:

“Additional skills and training will be necessary to allow people to work safely with E&HVs. The levels

of competency required will vary greatly and are dependent on the type of work that people are expected

to do. For example, an awareness of the additional risks is likely to be all that is required for people who

undertake vehicle sales or valeting. People involved in vehicle repair and maintenance, however, are likely

to need a much greater level of competence in order to work on these types of vehicles safely. Specific

training with qualifications awarded by organisations such as IMI Awards is available.” (HSE, 2017)

[www.hse.gov.uk, Accessed 2017]


8. Additionally, the HSE MVR Forum composed of industry experts and HSE industry specialists expressed the

need for raising awareness of the risks of Hybrid and Electric vehicles among technicians – including bus

engineers, getting relevant information and guidance across to the industry, and introducing manufacturer

training schemes (MVR, 2014). The MVR Forum minutes demonstrate there was a collective agreement

that any technical staff working near or on Hybrid and Electric vehicles required a level of training, although,

there was no real indication throughout the material as to what competency individuals should have. The

BS761 standards which exist for electricians to legally install electrical wiring into a commercial or private

property, correctly identifies the risks and skills associated with the job. Yet, no such standards exist for

technicians who could, today, work on high voltage lethal machines. In fact, there is no legal minimum

standard of knowledge needed for an individual to operate a motor vehicle garage, which has ramifications

for the industry and ultimately the consumer.

9. The school of thought that suggests that Automated and Hybrid/Electric vehicles will not enter the used

car market misunderstands the structure and dynamics of the vehicle market. Data published by the

Society of Motor Manufacturers and Traders (SMMT) suggests that the financial discounting and

environmental awareness may have helped drive up UK Plug-in and Hybrid car registrations with YTD

figures indicating 102, 335 for 2017 up 34% from 2016. However, new car registrations are just one area

of growth for Hybrid and Electric vehicle ownership. The UK car market is diverse, the SMMT indicates

that new vehicle registrations for the first half of 2017 were 2.3 million units (a decline on 2016 of 4.6%);

4% of the total units were Hybrid or Electric vehicles variants. However, the number of used cars sold in

the first two quarters of 2017 were 4.2 million, 26.1% of these vehicles were Hybrid and Electric vehicles.

The ratio of new to used cars exchanging hands in the market suggests that Hybrid (of all variants) and

Electric vehicles are much more likely to change ownership in the used car segment than elsewhere.

10. Therefore, the used car market increases the opportunity for Hybrid and Electric vehicle ownership to

more people, depreciation being a key benefit making the cars more affordable. However, the

advantages of buying a used Hybrid or Electric car over a new vehicle end there. The cost to service and

maintain the vehicle remains comparable to new vehicles. The current lack of competition in the

aftermarket sector is a primary reason behind this. As previously outlined, relatively few technicians (1%

according to IMI research), have the necessary training to work on Hybrid and Electric vehicles in a safe

and competent manner, and those that do tend to work almost exclusively for main dealer workshops.

The consumer currently has little choice but to return to the main dealer network for maintenance and


repair who consequently charge for a premium service. In the medium to long term, however, the lack

of training surrounding this technology in the aftermarket sector has more far-reaching implications than

cost, namely the health and safety of technicians and consumers.

11. The technology in Hybrid and Electric vehicles is very different to the traditional combustion engine. The

battery pack on a Plug-in Hybrid Electric vehicle carries up to 650v direct current. Manufacturers have

taken the necessary precautions to ensure that the vehicles are safe in their day-to-day use. However,

the risk of untrained vehicle technicians attempting to repair Hybrid and Electric vehicles is high. Many of

the components, the high voltage capacitors for instance situated in the main power drive unit, are

capable of storing 500v and 100 amp-hours and are lethal to the untrained. Importantly, in most instances

these components are not identifiable at first glance so pose a real Health and Safety concern. Any

technician making assumption that they can repair these vehicles without adequate training or

knowledge puts their lives and the lives of others at risk.

12. The IMI’s Professional Register is an existing solution for the automotive sector. It establishes the

appropriate minimum competency standards for technical roles in the automotive retail sector. In

particular for those who are servicing and maintaining vehicles. The IMI, through the Professional

Register, governs and records the ongoing adherence to standards by registered individuals and binds all

those on the register to an Ethical Code of Conduct. This shows that technicians are not only competent

but that they apply their skills appropriately at all times. Currently, all those on the IMI Professional

Register (cira.34, 000) have voluntarily undertaken the necessary steps in completing, an accreditation

assessment, and/or a qualification to achieve registration as certified, competent individuals. Individuals

are also able to maintain their professional status through rigorous CPD and training much like the current

DVSA MOT assessments. The framework and processes are there and well understood across the sector.

It would therefore work equally well for individuals achieving standards under regulatory Licensing. The

IMI’s Licence to Practise model aims to minimise the burden on Government and provide employers with

the confidence that vehicle technicians they hire can work on Hybrid and Electric vehicles and are

competent and skilled to do so safely.

13. Apprentices and students who are qualifying to work in the automotive industry today cannot, and should

not be seen as the panacea to the long term skills gap or the immediate health and safety case that the

IMI is making. The IMI has long been involved in the development of National Occupational Standards


which have underpinned many of the Apprenticeship frameworks, and now Standards, for the automotive

retail sector.

14. Whilst the content of the new Apprenticeship Standards will undoubtedly evolve over time to embrace

newer technologies, including high voltage electrics, apprenticeships are intended to create work-ready

individuals and equip them with all the basic skills to commence a career in servicing and repairing

vehicles. This is not however an end point in itself and a newly qualified individual will still require ongoing

training and experience before they might reach the standards required to enable them to become

qualified or accredited to work directly on high-voltage vehicle systems. The Apprenticeship framework

for vehicle maintenance and repair, which underpins current apprenticeships for Light Vehicle

technicians, has no mandatory requirement to train candidates in Hybrid and Electric Vehicle

qualifications. Therefore, the FE College, Private training provider, or employer is only able to fund the

apprenticeship as is, with no additional qualifications attached. As the Minister will be aware the number

of Apprenticeship Framework registrations in Vehicle Maintenance and Repair have remained

approximately constant at 9,000 (+/-5%) per year. Candidates registering for an apprenticeships today

will not complete their apprenticeship for a minimum of 24 months to 36 months; and on completion will

not necessarily have the skills or knowledge to work on Hybrid and Electric vehicles. Therefore, the skills

gap will have not closed but been phased forward. A Licence to Practise will ensure that at least one

individual in a garage will be accredited and skilled to carry out work on these potentially dangerous

machines, which will inevitably reach the shop floor.

Conclusions

15. The evidence submitted here should have gone someway to demonstrate to the Minister and the

Automated and Electric Vehicles Committee of the importance of maintaining the amendment (NC 17

section 6 and 7) within the Automated and Electric Vehicles Bill. The IMI’s immediate concern is for the

Health and Safety of vehicle technicians in the independent sector who will come into contact with Hybrid

and Electric vehicles. The Automated and Electric Vehicles Bill raises the question on consumer (vehicle

owner) to consumer (road user) and to business (manufacturer) insurance liability, however, it does not

address the impact on business Public liability insurance or Employers liability insurance should one of

these new high voltage systems be “repaired” by the untrained technician who subsequently is injured or

killed. The IMI’s Licence to Practise is an industry supported mechanism (see Appendix) that will ensure

that individuals and the independent sector have impetus to have the necessary skills for future

technologies.


Appendices (Letters of support):

written evidence submitted by the institute of the motor industry; … · 2017-11-16 · centres...

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