IS THE AUTOMOTIVE INDUSTRY READY FOR THE NEW TECHNOLOGIES?

www.theimi.org.uk

Foreword Executive SummaryIntroduction ApproachBackground The Automotive Retail Sector Education and Training The Skills GapRegulation Current Regulation Regulatory Gaps Regulation Under a Licence to Practise Driver and Vehicle Standards AgencyConclusions

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CONTENTS

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FOREWORDBY STEVE NASHThe Institute of the Motor Industry (IMI), the professional body for the automotive sector, has an ambition to see regulation put in place to protect vehicle technicians working on the high-voltage systems of Electric, Hybrid and plug-in Hybrid vehicles.

Whilst the IMI is representing the case for regulation, we have a large support network from across the industry and can also offer a ready-made framework for regulation in the form of existing voluntary accreditation standards and the IMI Professional Register. This would not be seen as a profit opportunity for ourselves, or any other body, as we are a not-for-profit organisation and our existing income streams are sufficient to support us.

This report answers the question surrounding the need for wider regulation on the automotive sector, addressing the present and immediate risks to untrained people working on the high-voltage systems powering Electric and Hybrid vehicles, which are not explicitly covered in the Health and Safety regulations. It also addresses the rapid advancements in safety-critical vehicle technologies and the potential risks these bring to businesses, individuals and consumers if the skills required to maintain and repair the new technologies remain unregulated.

STEVE NASH FIMIChief Executive - Institute of the Motor Industry (IMI)

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The Institute of the Motor Industry (IMI) is the Professional Body for people working in the automotive sector. The sector as a whole—supply chain, manufacturing and retail— generates £160 billion in turnover every year. The IMI certificates 100,000 people per year from its range of over 300 regulated and non-regulated qualifications and skills accreditations, which include apprenticeships and the new MOT tester assessments that businesses rely on. The motor industry remains largely unregulated, so literally anyone can set up in business to repair and service motor vehicles. In this environment the IMI attempts to protect the safety of individuals working in the sector and to defend the interests of consumers. It does this by running a voluntary licence to practise based on skills accreditation, qualifications and continuous professional development (CPD). The IMI Professional Register is a publicly searchable database that allows the public to find appropriately skilled and qualified industry professionals in their locality, who are also bound by an ethical code of conduct.

1. In the last five years the number of Hybrid and Electric car registrations has grown from 20,000 to over 100,000. The rate of growth in this technology indicates consumers' appetite for lower emission vehicles. The proliferation of these vehicles, however, increases the risks associated with maintenance and repair, particularly as Hybrid and Electric vehicles enter the aftermarket and used segments of the industry. As the vehicles age it will be increasingly likely that independent technicians will take on the repair work, and we note from our research that independent garages are unlikely to have the necessary training and understanding to repair these vehicles safely - potentially risking lives.

2. The IMI works with businesses to identify skills gaps across the sector and in doing so are able to form national occupational standards (NOS) so that awarding organisations can build qualifications which meet the needs of the industry. As such, the IMI and others have been able to design and deliver qualifications that provide candidates with the necessary skills and knowledge to work safely on Hybrid and Electric vehicles. The IMI's qualifications and accreditation schemes have had some success, most particularly with manufacturers’ franchised dealers and larger

EXECUTIVE SUMMARY

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independent organisations, such as Halfords. But the smaller independent operators who make up more than 80% of the service and repair sector are in many cases notoriously difficult to engage in training. As such, it is calculated that approximately 1% of all the technicians engaged across the entire sector are suitably qualified to work safely on the high voltage systems of Electric and Hybrid vehicles.

3. Directives from the EU have seen the implementation of environmentally based regulation surrounding Refrigerant Gas and Liquid Petroleum Gases (LPG), outlining the training and qualifications needed for an individual to be able to work on these systems in vehicles. Yet, possibly due to of the lack of any recorded incidents to date, there has been a lack of appetite to apply safety related standards to electrified vehicles. Interestingly, electricians working in the building trade have had regulations imposed because of the potential risk to life or serious injury from working on 240v mains voltage systems, whereas cars and trucks operating on much higher voltages can be worked on by anyone. The Health and Safety Executive has published some guidance material on what it deems as safe working practices for Hybrid and Electric vehicles, and interestingly refer readers either to the relevant manufactures or to the IMI for further technical information on safe working practices.

4. Whilst it is appreciated that the Government do not, in general, favour regulation, it does have the same responsibility to ensure the safety of individuals working on high voltage motor vehicles as it had to ensure the safety of electricians working in the building trade. It would be highly inconsistent to ignore that link. The risks to an untrained, unqualified and potentially ill-equipped individual working on an Electric or Hybrid vehicle are certainly no less than for an unaccredited electrician working with mains voltage.

5. The IMI Accreditation programme has set the precedent for a voluntary licensing scheme, which many in the industry welcome and continue to utilise as a mechanism for measuring skill and capability. Operationally, the IMI believes that it can provide a similar service to that of Capita Gas Registration and Ancillary Services Ltd (CGRAS) and the Gas Safe register, using the IMI’s current infrastructure and Professional Register to enlist competent and trained individuals who can work safely on Hybrid and Electric vehicles and next generation interconnected and autonomous vehicles. The IMI’s Professional Register is already the industry standard for demonstrating competency, skills and professionalism. Using this existing infrastructure, the IMI can assure employee and public safety with no additional cost or administrative burden on Government.

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The title of this report - Is the automotive industry ready for the new technologies? - may seem rhetorical, after all it is the automotive industry that is pursuing and developing these technological changes. But there is no recent precedent for the scale of change that the industry is presently embarking upon. Motor vehicles have evolved over the past 100 years based largely on familiar technology, which has enabled those working on the products – whether formally qualified or not – to evolve their knowledge and abilities accordingly. But the new technologies, including electrification, connected and autonomous vehicles, represent a quantum change which simply cannot be assimilated by the untrained and unqualified.

Manufacturers are slowly recognising the need and investing in training their franchised dealer staff and, in most cases, use IMI Accreditation as their benchmark. Larger independent organisations like Halfords are doing the same, but the sizeable independent sector, consisting of an estimated 40,000 businesses and representing more than 80% of all the businesses engaged in servicing and repairing motor vehicles, includes many that invest sparingly in training, if at all.

As things stand, approximately only 1% of all accredited technicians working in the service and repair industry are properly trained and qualified to work safely on the high voltage systems found

in Electric and Hybrid vehicles, and the vast majority of these are employed in manufacturers’ franchised dealers. The result is that we will see either a considerable reduction in the competition to service and repair these vehicles (already reflected in their higher insurance rates) or, as they proliferate, increasing numbers of unqualified operatives risking injury or death by working on unfamiliar technology for which they neither have the appropriate knowledge, skills or equipment.

This paper explores the impact of the new technologies in the aftermarket sector, with particular reference to small-to-medium sized businesses and the self-employed. We examine current regulations that are designed to protect workers who work with hazardous materials and establish if these regulations could be regarded as sufficient or appropriate to deal with the issues outlined in the foregoing text.

1.1 APPROACH

The IMI undertook this literature review to identify and analyse the effectiveness of regulations, which are currently adhered to by the automotive sector. It also explores the changing nature of the automotive industry from a technological perspective and what the impacts of these changes mean for the independent and self-employed segments of the sector.

1.0 INTRODUCTION

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2.0 BACKGROUND2.1 THE AUTOMOTIVE RETAIL SECTOR

This section provides an overview of the automotive retail market to set the scene for further analysis. General industry information is discussed including growth rates, employment rates, and the average General Value Add (aGVA) to the UK economy, as well as information relating to Hybrid and Electric Qualifications and Accreditations. The IMI differentiates itself from other professional and trade bodies in that membership is accessible to any persons across the sector who meet the qualifying criteria. The IMI currently has a membership profile of 34,000 people, working for manufacturers, independent garages, insurers, public services, education and other industry related fields. This footprint makes the IMI a prominent voice for individuals in the sector.

Here we report on the downstream element of the sector (see figure1) which comprises of New Car Sales, Used Car Sales, After Sales Services - such as Maintenance and Repair (which will form the bulk of analysis further on), and Parts.

Small and micro-businesses account for 83% of the automotive retail sector; however, manufacturers and their franchises comprise the majority of employees in the sector. The sector, defined under the sector industry classification as wholesale and retail trade and repair of motor vehicles and motorcycles (Classification 45), has 552,060 jobs across Great Britain. The figure excludes data from the Rental and Leasing industry, which when included increases the figure to just over 591,000 jobs.

1 2 3 4What interventions

currently regulate the sector?

What are the gaps in current regulation and

why are these important?

THE PAPER IS STRUCTURED AROUND THESE KEY QUESTIONS:

To what extent does regulation protect the

industry and individuals?

How much regulatory effort would be required to introduce an effective licence to practise?

DOWNSTREAMUPSTREAM

MANUFACTURER OFMOTOR VEHICLES

NEW CARSALES

FINANCIALSERVICES

USED CARSALES

ENDOFLIFERECYCLE

AFTERMARKETSERVICES

PARTS ACCESSORIES LUBRICANTS AND TYRES MAINTENANCE AND REPAIR

LOGISTICS

PARTS SERVICES

Figure 1. Automotive sector segmentation

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The breadth of the sector is however, far broader than the numbers above suggest. There are a number of roles that are linked to the industry through supplementary industries, such as education and insurance, which bolster these figures. The automotive sector, therefore, has the potential to impact on over 1 million jobs, if these are also factored in. Narrowing the sector data to just the automotive retail sector, we see that there are significant job levels through the industry.

The industry’s economic impact is a significant one. The SMMT, together with Frost & Sullivan, reveal that the automotive aftermarket segment alone has a total retail revenue of £21.6bn and an aGVA of £12.5bn (Frost & Sullivan, 2017). Furthermore, as a sector, automotive retail had a turnover of £53bn in Q2 of 2017 with an aGVA of £18.9bn (see Figure 2).

According to the projections from the SMMT for 2022, if vehicle technology continues on its

current trajectory, there is a potential for a further 320,000 new jobs across the sector (Securing the Strength of the UK Automotive Industry / 2017–2022, www.smmt.co.uk, 2017). Importantly though, at present there are only 184,7311

vehicle technicians, mechanics and electricians working across the UK, 124,000 of which work directly in the automotive retail sector. It is therefore vital that, in the respect of growing technology, the proportion of skilled technical employees grows at the same pace as the projected outlook provided by the SMMT. Otherwise, the industry faces the very real possibility of a skills gap becoming a chasm, which will inevitably reduce the UK’s skills rating further.

2.2 EDUCATION AND TRAININGAs an Awarding Organisation, the IMI ensures that its qualifications and professional Accreditations are at the forefront of technology. Through rigorous sector employer engagement, the IMI developed the UK’s only automotive

AUTOMOTIVE RETAIL SECTOR JOBS

Maintenance and repair of motor

vehicles

242,868 Jobs

37,591 Jobs

179,617 Jobs

10,152 Jobs

12,704 Jobs

30,981 Jobs

69,130 Jobs

8,036 Jobs

Retail trade of motor vehicle parts and

accessories

Sale of cars And light

motor vehicles

Sale, maintenance and repair of motorcycles

and related parts

Sale of other motor

vehicles

Renting and leasing of cars and light motor vehicles

Wholesale trade of motor vehicle parts

and accessories

Renting and leasing of trucksparts and

accessories

1 EMP04: Employment by occupation (https://www.ons.gov.uk/employmentandlabourmarket/peopleinwork/employmentandemployeetypes/datasets/employmentbyoccupationemp04 Number of people working in the UK as Vehicle technicians, mechanics and electricians.

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Accreditation scheme, which is incidentally utilised by manufacturers, independent garages and the self-employed.

The IMI has developed several qualifications, one full route Accreditation, and modules for vehicle manufactures for people working with Hybrid and Electric vehicles. These have predominantly aimed to provide the learner with skills necessary to work safely in this hazardous environment (see Table 1). Over the last two years there have been 8,668 registrations and 7,823 certifications. 72% of these

certified people would have adequately met the standard to work on and around the Electric and Hybrid system. Crucially, this only accounts for 3% of all vehicle technicians in the sector and is likely to have been completed by those who are just starting their careers. The IMI Accreditation in Electric Vehicle Safe Working Practices, which is designed for those currently in employment, has far lower registration with certification figures of 218 and 204 respectively, meaning there are approximately 1% of technicians who have accredited their skills at this level.

Turnover in UK production and Great Britain services industries SIC 45 (TOPSI) 2000 to 2017

50,000

55,000

60,000

(£,000’s)

45,000

40,000

35,000

30,000

25,000

20,000 2011 2012 2013 2014 2015 2016 2017

Award Level Number of Registrations

Number of Certifications

Level 1 Award in Electric Vehicle Awareness 966 855

Level 2 Award in Electrically Propelled Hazard Management 121 196

Level 2 Award in Hybrid Electric Vehicle Operation and Maintenance 1,261 1143

Level 2 Award in Routine Maintenance Activities on Electrically Propelled Vehicles

2,611 2,451

Level 3 Award in Electrically Propelled Vehicle Repair and Replacement 2,023 1,873

Level 3 Award in Hybrid Electric Vehicle Repair and Replacement 1,010 874

Level 4 Award in the Diagnosis, Testing and Repair of Electric/Hybrid Vehicles and Components

676 431

Total 8,668 7,823

Figure 2. Turnover in UK production and Great Britain services industries data analysed from the ONS https://www.ons.gov.uk/businessin-dustryandtrade/manufacturingandproductionindustry/datasets/turnoverandordersintheproductionandservicesindustriesdataset

Table 1. Hybrid & Electric Vehicle qualification rates from 2015 -2017

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The IMI continues to work with employers at every level in the automotive industry to raise awareness of the skills gap and demonstrate the return on investment of training to the business. The development of the Level 3 and Level 4 qualification in Hybrid and Electric Vehicles Maintenance and Repair is a testament to the Institute's commitment to maintaining the highest possible standards.

2.3 THE SKILLS GAPDespite these efforts, IMI research suggests that the message for continuous skills development is not filtering down. Table 1 indicates that only 1% of 22,573 people who hold an accreditation have chosen a Hybrid and Electric vehicle route, which is a growing concern for the Institute.

Research commissioned last year by the IMI demonstrated that there was a clear lack of urgency from garages across the UK when it came to addressing the skills gap. Around two-thirds (63%) of the garages reported some skill gaps relating to specialist technical areas – most commonly Hybrid or Electric vehicle technology (46%). A further 31% of garages reported a skills

gap relating to ancillary electrical/electronic systems/fault diagnosis.

In not undertaking the relevant training, the independent segment of the sector increases the risk of injury or death to employees who will be responsible for working on these vehicles. The IMI know that, within the franchised network, employees are expected to work to set standards that keep the individual well trained and, above all, aware of the risks involved with working with high voltage machines.

Garage owners who are reluctant to provide training, or do not yet see the necessity to up-skill staff, under estimate the rate at which Hybrid and Electric vehicles will proliferate into the vehicle markets.

In fact, the number of Hybrid and Electric vehicles on the road have rapidly increased faster than anticipated (see Figure 3). The IMI believe that these registration rates will continue to grow exponentially, especially as industry and Governments have begun to support these Ultra Low Emission Vehicle (ULEV) alternatives publically.

Cumulative year-on-year Electric Vehicle registrations (UK) 2012-2017

Non Plug-in Grant Eligible Vans

Sources: SMMT, DfT, OLEV Statistics Analysis: Next Green Car, July 2017

Non Plug-in Grant Eligible Cars

Plug-in Grant Eligible Vans

Plug-in Grant Eligible Cars

120,000

110,000

80,000

60,000

40,000

20,000

0 2012 2013 2014 2015 2016 2017

Figure 3. Cumulative Year-on-Year EV Registrations UK

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With the increased number of vehicles entering the market and the rate of technological change, it is evident that regulation needs to keep pace to protect the health and safety of the trade and the public. Within the next decade the automotive industry is set to see further technological advancements with the advent of autonomous cars and hydrogen fuel cell cars. These vehicles are set to bring a whole host of opportunities for mobility and transport systems across the UK but also some challenges for the industry.

There are two key aims of this report. Firstly, to understand the interplay between regulation and industry. Here it will identify how regulation in other sectors have impacted industry and whether growth or competition have been adversely affected by implementation. Second, it will look at the changing landscape of the automotive sector and what challenges these changes bring government, focusing particularly on transport and mobility.

3.0 REGULATIONThe IMI’s use of the term regulation can be construed in various ways. In the narrowest sense it can refer to a set of authoritative rules set and monitored by Government for promoting compliance in the sector. A broader interpretation includes a range of industry based instruments, which act as mechanisms of social control, including non-state processes (Baldwin R.,1998). With this interpretation, the role and responsibility for that regulation can be carried out by non-governmental entities, i.e. professional institutes, that ensure there is a uniformed and agreed standard set across the industry. A mechanism of this nature reduces the risk of harm to the individual and their customer and promotes the professionalism of the sector. The IMI began a voluntary licence to practise after the Office of Fair Trading (OFT) super complaint of 2006. Its industry-backed approach

was to develop the Professional Register which is supported by an accreditation scheme. This accreditation scheme has had a significant impact on the sector (see table 2). However, as Williamson (2006) suggests, SMEs will only act when there is a specific requirement to do so. The IMI’s pursuit of a licence to practise will bridge the gap between manufactures and the independent sector, providing a standardisation of skills across the industry. As the industry's professional body, we recognise that regulation, to some degree, exists within the sector. For instance, Autogas, who work in the Liquid Petroleum Gas sector, license individuals through their accreditation scheme to certify that installations and services adhere to strict standards. Also the EU introduced regulation on the use of fluorinated greenhouse gases (F-gases), such as hydro-fluorocarbons (HFCs), perfluorocarbons (PFCs) and sulphur hexafluoride (SF6), which are gasses used in air conditioning and refrigeration (gov.co.uk), the regulation aiming to limit the escape of these gases to the atmosphere (DEFRA, 2017).

This next section will discuss the regulators and regulations in further detail, and outline why we believe current regulation does not adequately protect professionals and the consumers from harm in the context of Hybrid and Electric vehicles. It further discusses how the IMI's work with the Driver and Vehicle Standards Agency (DVSA) has created an environment of professionalism and continued professional development among UK MOT testers.

3.1 CURRENT REGULATION

3.1.1 Health and Safety ExecutiveThe Health and Safety at Work Act 1974 is the primary piece of legislation regulating occupational health and safety in the UK. The act outlines the best practices for working across UK industry. However, over the years technological advancements and growth in the industry have

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meant that there have had to be revisions of the act or additional acts to support these changes. One such additional instruction is the Electricity at Work Regulation 1989 (HSR25). HSR25 sets out criteria for the minimum standard of safety for anyone working in the Electrical industry.

Within the HSR25 responsibilities are placed with

the employer to ensure that employees engaged in activities on or near electrical equipment implement safe systems of work and have the technical knowledge and training to do so. There are two regulations mentioned within the HSR25 guidelines that can be construed as providing adequate context for working on/with Hybrid and Electric Vehicles (See Table 2).

The Electricity at Work Regulations do indeed set out a defined set of rules for electricians working with low and high voltage systems. The way that these systems are made safe in a Hybrid or Electric vehicle differs significantly. It is therefore not feasible for an electrician who has met the BS 7671 standard of competence to know how to make an Electric or Hybrid vehicle safe to work on.

Further to the Electricity at Work regulation 1989, the Health and Safety in motor vehicle repair and associated industries regulation 2009 (HSG261) is the other instruction that would presumably cover the safe working practices of working with Hybrid and Electric vehicles.

HSG261 includes 90 rules for working in a garage on motor vehicles. Again, these regulations adequately protect employers and trained individuals against accidents in the work place. Therefore, it is not necessary to cover all of these regulations in detail. Rule 72 though is of interest. In this section, the provision covers electricity in the work place. Paragraphs 317, 318, 319 all refer to HSR25 and BS 60079 for electrical equipment for use in potentially explosive atmospheres and any requirements to have fixed installations should be fitted by someone who is compliant with BS761. There are further mentions of working safely with electrical equipment that is either portable or fixed, which are also covered by the HSR25 regulations.

Article No. Relevance Appropriate for Hybrid and Electric Vehicles

Regulation 12: Means for cutting off the supply and for isolation

In effect this would mean shutting off the supply as well as disconnecting and separation of the electrical equipment from every electrical source i.e. ‘Safe isolation procedures'

Yes and No - The premise that all electrical components should be switched off prior to any work being conducted on the vehicles electrical system holds true.

However, as there are two types of battery in a hybrid, the system remains live even after one battery has been disconnected. Second, each electric and hybrid car has its own electrical dissipation time. This can determine when the car is safe to work on

Regulation 16: Persons to be competent to prevent danger and injury

No person shall be engaged in any work activity where technical knowledge or experience is necessary to prevent danger or, where appropriate, injury, unless he possesses such knowledge or experience, or is under such degree of supervision as may be appropriate having regard to the nature of the work

Yes - However, unlike the electrical industry there are no common standards of competency. The technicians in the automotive industry do not have the same knowledge base as electricians. It is therefore impossible for employers to deem employees competent to the aforementioned standards

Table 2. HSR25 Regulations that cross sector and cover individuals working on HV & EV vehicles

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Article No. Relevance Appropriate for Hybrid and Electric Vehicles

Regulation 12: Means for cutting off the supply and for isolation

In effect this would mean shutting off the supply as well as disconnecting and separation of the electrical equipment from every electrical source i.e. ‘Safe isolation procedures'

Yes and No - The premise that all electrical components should be switched off prior to any work being conducted on the vehicles electrical system holds true.

However, as there are two types of battery in a hybrid, the system remains live even after one battery has been disconnected. Second, each electric and hybrid car has its own electrical dissipation time. This can determine when the car is safe to work on

Regulation 16: Persons to be competent to prevent danger and injury

No person shall be engaged in any work activity where technical knowledge or experience is necessary to prevent danger or, where appropriate, injury, unless he possesses such knowledge or experience, or is under such degree of supervision as may be appropriate having regard to the nature of the work

Yes - However, unlike the electrical industry there are no common standards of competency. The technicians in the automotive industry do not have the same knowledge base as electricians. It is therefore impossible for employers to deem employees competent to the aforementioned standards

However, there is little to no guidance for working on these vehicles except to refer 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).

3.1.2 The Implementation and use of Autogas licensingThe UKLPG trade association for the Liquid Petroleum Gas (LPG) industry regulates individual installation technicians to ensure that they meet the BS EN 1949:2002 standards. The standards apply to installation and maintenance of LPG on Road vehicles, Mobile Homes and Caravans. The Department for Transport (DfT) set out that, although there is no statutory regulation regarding the installation and use of these systems on Great Britain’s roads, the vehicle must comply with internationally agreed safety standards (UNECE Regulation 67.01). The regulation includes specific provisions to ensure the safety of LPG fuel systems and requirements for the tank.

Interestingly, the training and quality assured programmes are conducted within the Health and Safety Executive (HSE) Safe installation and use of F-Gas systems and appliances framework within Gas Safety Regulations (HSE Safe installation and use of gas systems and appliances, 2013). Some of the criteria covered by training are:

• To prevent fire from the leakage of LPG after installation and during use

• To minimise the risk of asphyxiation should a leak or accumulation of gas occur in an enclosed space particularly in spaces where occupants sleep (for caravan or mobile home installations)

• To ensure correct installation, exchange, disconnect, service, repair, breakdown and commission closed flued LPG fires

• To test and direct purge of pressure systems up to 7 bar.

Many of the other aspects of the regulation refer to the loss of LPG to the atmosphere and the contribution to greenhouse emissions. Although the LPG regulation is not in any way connected to the Hybrid and Electric vehicle regulation

…employees don’t try to handle any hazardous substances, or do spe-cialist work, unless they have received appropriate training and have access to the necessary equipment (including protective clothing). For ex-ample, vehicles with significant structural damage may create additional risks, from escape of fuel or exposure to high-voltage or stored electrical energy in electric hybrid vehicles.

Electric/hybrid vehicles can have parts of the electrical system operating at 650 volts dc with batteries operating at around 280 volts. Most of these parts of the vehicle will tend not to be serviceable (i.e. they are replaced rather than repaired). Special precautions may be required for road res-cue/recovery and electric/hybrid vehicle manufacturers have produced information for non-dealership personnel and have dealt directly with the emergency services to discuss different rescue scenarios.

“

“

“

“

The HSG261 mentions on page 41 under roadside repairs and recovery that,

(The Health and Safety Executive, 2009) pg. 41 paragraph 174.

(The Health and Safety Executive, 2009) Page 76, Paragraph 351.

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discussion of this paper, it does prescribe to a regulation which has no impact on businesses that it is imposed on. Moreover, having the standards made available to companies and individuals outside of the manufacturing gates has actually created opportunity for new businesses to form and thrive while maintaining competency.

3.1.3 F-Gas StandardisationIn a similar vein to that of the regulation of the LPG sector, F-Gas is regulated by broader regulations set by the EU and the wider international community (gov.uk F-Gas guidance, 2014). As before, the link to the electrification of the car is not direct but the impact of the regulation is important to understand in its context. In 2010 it became mandatory, through European Union regulation EC842-2006, that all technicians working with cars and vans which had air conditioning systems fulfil minimum qualification standards outlined by regulation EC842-2006 and subsequent annex (EC307-2008), which expands on the qualification requirements.

The regulation approved by DEFRA creates controls on the use and emissions of fluorinated greenhouse gases (fluorinated gases), including HFCs, PFCs and SF6. The EU Greenhouse Gas Regulation 2014 replaces the 2006 regulation. Training and certification are an important feature of the Greenhouse Gas Regulations

because it ensures that technicians understand how to minimise emissions during installation, maintenance and end-of-life of equipment containing F-Gases.

The regulation sets out the minimum requirement of training for personnel working on mobile air-conditioned (MAC) units, for example, the MAC qualifications under EC/307/2008 must cover the following areas:• Operation of MAC systems containing F-Gas

refrigerants• Environmental impact of F-Gas refrigerants• Environmental regulations• Refrigerant recovery

All Mobile Air Conditioning (MAC) technicians working with cars and car derived vans must have achieved as a minimum requirement a refrigerant handling qualification which fulfils the European Union F-Gas Regulation (EC842/2006 and Annex to Regulation EC307/2008). As a result, the IMI and other awarding organisations developed qualifications and accreditations to permit technicians across the automotive sector to meet the minimum standard. Further, the IMI updated its products to include the new refrigerant R1234yf, which has a significantly lower carbon footprint than its predecessor R134a, thereby giving technicians the required skills for the next generation of cooling gasses. Overall, the industry

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has responded positively, reflected by the number of qualifications and accreditations certificated over the last five years (see figure 5).

The implementation of the F-Gas directive further indicates that regulation can work for business providing a mechanism to lever continued professional development (CPD), which, if not mandated, would dissipate, hence why all IMI members must participate in CPD to maintain their membership.

3.2 REGULATORY GAPSTo 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.2 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 that they wish. 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].

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 that, as a group, 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

7,000

6,000

5,000

4,000

3,000

2,000

1,000

02012/13 2013/14 2014/15 2015/16 2016/17

AIR CONDITIONING AND REFRIGERANT HANDLING (EC842/2006)

4,95

9

4,19

6 5,10

1

4,34

1 5,62

3

5,90

4

5,65

7

5,10

75,87

3

4,73

3

Registrations Certifications

Figure 5. Accreditation Qualifications for F-Gas EC842:2006

2Key word identifiers for lexical analysis: Hybrid, Electric vehicle, death, electric shock, arching, fatal injuries, non-fatal injuries, Electric vehicle regulation, Health and safety at work, Motor vehicle safety, Death in service.

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Article Death and injury

Severe injury or burns

Electric Shock Total

Electricity at Work Act 0 0 0 0

26th Meeting of the MVR HSE forum 090414 3 2 2 7

Introduction to Motor Vehicle Repair 5 0 1 6

The Electricity at work act hsr25 13 9 34 56

HSE safety in motor vehicle repair and associated vehicles HSG26

16 9 14 39

Total 38 20 51 108

Table 3. Lexical Analysis

real indication throughout the material as to what competency individuals should have. A lexical analysis (see Table 3) of the text highlighted some of the risks associated with Hybrid and Electric Vehicles. It shows that the HSE identifies a number of severe and potentially fatal risks associated with these vehicle types. But, above all else, the analysis indicates that the skill level required to work on these vehicles is above and beyond the current skills needed to work on combustion powered vehicles (commercial and passenger).

However, unlike the BS761 standards which exist for electricians to legally install electrical wiring into a commercial or private property, no such standards exist for technicians to 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.

3.3 REGULATION UNDER A LICENCE TO PRACTISEA licence to practise would suggest that an individual who met the standard guidelines set by the issuing authority will have sufficient knowledge and expertise to work safely on Hybrid and Electric vehicles. The IMI’s licensing scheme will protect both technician and consumer health and safety. In this instance, the IMI is looking to establish a licensing system around skills and knowledge for those working in the industry, with the flexibility to incorporate newer technology as they arise and enter the consumer market, such as Fuel Cell Hybrid vehicles, semi-autonomous, and fully autonomous vehicles. The automotive industry is changing at such a pace that the only

way the independent sector (which is 80% of the automotive sector) can keep pace is to have a set of standards that offer updated qualifications and training for the individuals.

The IMI is aware that manufacturers like Volvo have publically announced a transition to Hybrid or Electric Vehicles by 2020 - a strategy that will also incorporates their commercial vehicle business. The IMI's research shows that, to prepare for this, Volvo is training 1,000 heavy vehicle technicians for the electrified powertrain alone. The impetus to adapt to the changing technologies and meet consumer demand is evident from a manufacturing perspective. The independent sector is not adapting at the same pace, as it has been shown.

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The Regulating Futures Review sets the precedence for current and future regulating bodies. It is clear that the Government are keen to reduce the administrative and financial burden that regulation could place on employers and the Exchequer (Cabinet Office, 2017). To this end, the IMI seeks to demonstrate in the forthcoming paper, ‘Regulating the Automotive Sector: A Return on Investment on Training and Safety’, that regulation can be delivered in a cost efficient and beneficial manner for the sector, as well as reducing the burden on Government.

The regulation sought by the IMI aims not to impose unrealistic or over complicated administrative burden on SME’s or micro businesses that will cause a business to reduce its efficiency. On the contrary, the IMI believes that by providing a business with access to the latest training, guidance, and continued professional development, a business and its employees can thrive in changing technological climates.

Using the Regulating Futures matrix, an IMI licence to practise would regulate individuals (see table 4) and businesses in the sector. However, unlike some of the regulations listed below, the IMI propose to work closely with businesses to ensure

that the approach is cost effective and beneficial for all stakeholders involved.

Operationally, the IMI believes that it can provide a similar service to that of Capita Gas Registration and Ancillary Services Ltd (CGRAS) and the Gas Safe register, using the IMI’s current infrastructure and Professional Register to enlist competent and trained individuals who can work safely on Hybrid and Electric vehicles and next generation interconnected vehicles. The IMI’s Professional Register is already fast becoming the industry's go to service to demonstrate competency, skills and professionalism. Using this infrastructure, we can assure employee and public safety.

3.4 DRIVER AND VEHICLE STANDARDS AGENCY (DVSA) Outside of the Health and Safety directive and the other pieces of regulation mentioned, the automotive industry adheres to the regulation set by the DVSA, as consumers and employees (e.g. MOT testers). In 2015, the DVSA announced that it will be seeking to change the way it assesses MOT testers from a five year test to an annual review of competences. The IMI, in corporation with the DVSA and in consultation with the sector,

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Who is regulated?

Name Economic Regulators Businesses Not for Profit Providers of

public servicesMachinery of Government

Individuals - Professionals

Animal and Plant Health Agency

Care Quality Commission

Charity Commission for England and Wales

Civil Aviation Authority

Driver and Vehicle Standards Agency (DVSA)

Education Funding Agency

Employment Agency Standards Inspectorate

Environment Agency

Financial Reporting Council (FRC)

Food Standards Agency

Gambling Commission

Gangmasters Licensing Authority

Health and Safety Executive

Higher Education Funding Council for England (HEFCE)

HM Inspectorate of Probation

Homes and Communities Agency

Information Commissioner’s Office

Insolvency Service

Legal Services Board

Medicines and Healthcare Products Regulatory Agency

National Measurement and Regulation Office

NHS Improvement

Office of Nuclear Regulation

Office of Rail and Road

Ofqual

Ofstead

Pensions Regulator

Professional Standards Authority for Health & Social Care

Rural Payments Agency

Security Industry Authority

Veterinary Medicines Dirctorate

Figure 6. Regulating Futures’ Review, regulation matrix

developed the National Occupational Standards (NOS) on which MOT qualifications were built. As a result, three awarding organisations, including the IMI, have developed Level 1 & 2 qualifica-tions for MOT classes 1 & 2 and classes 4 & 7, and a further Level 3 qualification for MOT Man-agers. The regulation requires MOT testers obtain

and train through continued professional develop-ment. This a persistent example of initial resistance and reluctance from the sector – many of whom would not have undertaken qualifications in recent memory, if at all - a regulatory scheme can be a great success, with participants accepting that it can bring a much needed rise in standards.

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In this report the landscape of the automotive sector and the potential implications of a lack of preparedness has been confirmed. It is evident from Health and Safety publications that the dangers to technicians from Hybrid and Electric vehicle powertrains are very real. However, despite these dangers and risks, very few professionals are prepared for the proliferation of this low emission technology. As the global automotive market makes this technological transition, the next is on the horizon. Recent announcements from manufacturers show they believe that electrification of vehicles will become the norm. The next phase in the technological race will be the type of battery and charge-discharge cycle that these vehicles will use and, of course, the level of autonomous functionality available.

In the short term, the technological changes bring an array of health and safety hazards that could potentially cause serious harm or death to technicians and consumers. The vehicle repair

sector is one of seven sectors where over a quarter of fatalities occur to the self-employed in 2016/2017 (HSE, 2016). Moreover, the HSE safety related electrical incidents report indicates that there were six fatal incidents relating to electrocution, 422 non-fatal electrocutions, and 14,869 other incidents (ESQCR - Health and Safety Executive, 2016). There are approximately 32 million vehicles on UK roads today, a small proportion of which are Hybrid or Electric. With International Governments’ global emission targets high on the policy agenda, this ratio will change dramatically and quickly.

The IMI believe the level of risk associated with this change is unprecedented for the sector. Current Health and Safety regulations, such as those imposed by the Electricity in Work with the standards BS7671 and the BS60079, have indeed saved lives. However, as we have learnt, their application is limited to the electricity industry and those it employs, namely registered

CONCLUSIONS

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electricians. Although the power levels mentioned are comparable, the system of delivery is certainly not. Specific training and a standardisation of skills is needed to protect individual employees and consumers in the short to medium term.

Looking forward, the IMI understands the need for the whole automotive service and repair sector, fully embracing the independent operators, to have the relevant training and skills to continue to thrive in a competitive market. Autonomous vehicles introduce a new opportunity for the sector but also an increased risk. The IMI's view of licensing the sector is not limited to electrification, although this is the most immediate risk. The IMI vision for licensing is one which can be adapted to new technology and will certainly need, in the near future, to embrace such issues as data security in highly connected vehicles and the safe

repair and calibration of autonomous vehicle systems.

The days of the untrained, unqualified practitioner and the gifted amateur must surely be numbered. For the protection of the individuals working on motor vehicles and the assurance of public security and safety, there is a need to know that those engaged in undertaking the service, maintenance and repair of the new vehicle technologies are competent, trustworthy and accountable. That can only be achieved through some form of licence to practise, and what the IMI has set out in this paper is an effective, cost neutral solution for government which will ensure that businesses remain competitive, employees are skilled, and consumers are protected.

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Baldwin R., S. L. a. H. C., 1998. A Reader on Regulations. Oxford: Oxford University Press.

BBC Five Star Cars, 2012. www.bbc.co.uk/blogs/watchdog/2011/05/rogue_mechanic.html. [Accessed 2017]

Cabinet Office, 2017. Regulatory Futures Review: www.gov.uk/government/publications/regulatory-futures-review.

ESQCR - Health and Safety Executive, 2016. Electricity Safety, Quality and Continuity Regulations 2002. www.hse.gov.uk/statistics/tables/index.htm#riddor [Accessed 2017].

Frost & Sullivan, 2017. The Importance of the UK Aftermarket to the UK Economy. Volume 1, pp. 1-22.

GOV.UK F-GAS guidance, 2014. www.gov.uk/government/collections/eu-f-gas-regulation-guidance-for-users-producers-and-traders

HSE Safe installation and use of gas systems and appliances, 2013. Health and Safety Executive. www.hse.gov.uk/aboutus/meetings/hseboard/2013/250913/psepb1389-b.pdf[Accessed 2017].

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HSE, 2016. Fatal injuries arising from accidents at work in Great Britain 2017: www.hse.gov.uk/statistics/pdf/fatalinjuries.pdf.

HSE, T., 2017. Common MVR Topics - Electric and Hybrid Vehicles. www.hse.gov.uk/mvr/topics/electric-hybrid.htm [2017].

MVR, H., 2014. Motor Repair Forum. www.hse.gov.uk/aboutus/meetings/commit-tees/mvr/090414.pdf[Accessed 2017].

Santos, B. W. D., 2011. Watchdog Mike Dos Santos. www.bbc.co.uk/blogs/watchdog/2011/05/rogue_mechanic.html[Accessed 2017].

The Health and Safety Executive, 2009. Health and safety in motor Vehicle re-pair and associated industries (HSG261). www.hse.gov.uk/pubns/priced/hsg261.pdf ed. s.l.:ISBN 978 0 7176 6308 8.

UNECE Regulation, 1995. Agreement concerning the Adoption of Uniform Technical Prescriptions (Rev.2). www.unece.org/trans/main/wp29/wp29regs.html [Accessed 2017].

Williamson, D. L.-W. G. &. R. J., 2006. Drivers of Environmental Behaviour in Manufacturing SMEs and the Implications for CSR. Business Ethics, Volume 67, pp. 317-330.

REFERENCES

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Prepared By Demetri Vlachos The Institute of the Motor IndustryFanshawsBrickendonHertfordSG13 8PQ

HOW YOU CAN CONTACT USTel +44 (0) 1992 511521Email: research@theimi.org.uk

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The Institute of the Motor IndustryFanshaws, BrickendonHertford, SG13 8PQ

A company limited by guarantee. Registered in England No:225180.

research@theimi.org.ukwww.theimi.org.uk+44 (0) 1992 511 521

Disclaimer: This publication contains general information and data available from free to use resources, although the IMI endeavours to ensure that the content is accurate and up-to-date at the date of publication, no representation or warranty, express or implied, is made as to its accuracy or completeness and therefore the in-formation in this publication should not be relied upon. Readers should always seek appropriate advice from a suitably qualified expert before taking, or refraining from taking, any action. The contents of this publication should not be construed as advice or guidance and the IMI disclaims liability for any loss, howsoever caused, arising directly or indirectly from reliance on the information in this publication.