Electrical Certification and registration of manufactured and imported Electric Vehicle Charing Stations can be a little confusing, and like most legislation, can be open to wide and varied interpretations. Here is a summary of the facts, to assist you to manage risk:
All electrical equipment imported, and sold in, Australia must be proven to be electrically safe. All electrical products, regardless of use, must comply with AS/NZS 3820, which is the general electrical safety standard. Specifically:
A person conducting a business or undertaking has the primary duty under the WHS Act to ensure, so far as is reasonably practicable, that workers and other persons at the workplace are not exposed to electrical risks arising from the business or undertaking. This duty requires eliminating electrical risks or, if that is not reasonably practicable, minimising the risks so far as is reasonably practicable.
If the item is for use in a house, or is to be sold over the internet to individuals without a registered ABN, then the product must comply with the requirements of the RCM, as detailed in AS/NZS 4417.2 and on www.eess.gov.au.
In-Scope Electrical Equipment:
The term “in-scope” is defined in law and means electrical equipment that is:
It is immaterial whether the equipment is designed or marketed for commercial or industrial purposes as well as for household use. If Regulatory Authorities (RAs) claim that an item is in-scope , it will be taken that way unless the Responsible Supplier can prove otherwise.
Note: Electric Vehicle Charging Stations (at this time) have not been classified as in or out of scope, by a Regulating Authority. AC Stations do however meet the criteria of 'in-scope'. If argued that they are out-of-scope, then the applicable Regulations dictate that they must still at least meet AS/NZS 3820 above.
Risk Levels – Definition:
EESS provides for in-scope electrical equipment to be classified into three levels:
Note: At this time, Electric Vehicle Charging Stations themselves are not classified by the Authority as either Level 3 or Level 2. Therefore, are deemed to be Level 1. Although, portions of the Electric Vehicle Charging Stations could be deemed as Risk Level 3, via definitions of:
Since almost all Electric Vehicle Charging Stations have built-in Radio transmitters, with an integral antenna, for 3G, 4G or 5G; Bluetooth; Wi-Fi; and RFID, then they need to meet and comply with the ACMA requirements of the RCM, as detailed in AS/NZS 4417.2 and on www.eess.gov.au. Including:
Appendix P: Page 568
Appendix P: Page 568
Good Practise: Clause 184.108.40.206.1
P1.3 - Testing:
Appendix P: Page 568
Regular inspecting and testing of electrical equipment can save lives. It helps identify damage, wear and electrical faults. Click here.
You can detect many electrical defects such as damaged cords just by examining them, but regular inspection and testing will make sure you detect electrical faults and deterioration you can’t see.
A PCBU must ensure electrical equipment is regularly inspected and tested if it is supplied with electricity through an electrical socket outlet and used in a ‘hostile operating environment’. A ‘hostile operating environment’ is an environment in which the normal use of electrical equipment exposes the equipment to operating conditions that are likely to result in damage to the equipment or a reduction in its expected life span, including conditions that involve exposure to moisture, heat, vibration, mechanical damage, corrosive chemicals or dust.
Inspections and testing must be carried out by a competent person, which depending on your jurisdiction might be a licensed or registered electrician or a licensed electrical inspector. The nature and frequency of inspection and testing depends on factors such as the nature of the electrical equipment, how it is used, and its operating environment. For advice on inspection and testing for your workplace, seek the advice of a competent person.
As a general rule, electrical equipment used in ‘hostile operating environments’ should be tested at least once every 12 months. Further guidance may be found in manufacturer’s recommendations and Australian Standards, for example: