The Electric Vehicle Council (EVC) provides feedback on the Queensland Electrical Safety Act 2002 review report, highlighting several key concerns and positions:
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Core Concerns: The EVC notes significant factual errors in the report regarding the history and prevalence of electric vehicles in Australia, suggesting a lack of industry engagement. The report's focus on electrical safety risks, particularly fatality rates, is criticized for ignoring the much higher fatality rate associated with air pollution from vehicles (11,000 premature deaths annually), which electric vehicles aim to reduce.
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Recommendation Responses:
- Recommendation 2: The EVC argues against expanding the Act's scope to include electric vehicles, emphasizing the adequacy of existing regulatory arrangements and the presence of relevant Australian standards (AS5732) and training programs (AURETH101) for safe electric vehicle maintenance.
- Recommendation 7: Requiring licensed electrical workers for mechanical protection installations is deemed unnecessary and costly, potentially delaying EV adoption.
- Recommendation 8: Mandating licensed electrical workers for EV maintenance is unsupported by evidence of inadequate current arrangements and would increase costs. The EVC suggests a "restricted electrical license" as a more practical alternative.
- Recommendation 12: The EVC supports legislation enabling regulation of new technologies but calls for an oversight framework, such as Queensland Treasury’s Office of Best Practice Regulation, to ensure economic appropriateness.
- Recommendation 20: Clarifying terms in the Act should align with existing Australian Standards (AS/NZS60079) to avoid confusion.
- Recommendations 21-23: Strengthening regulations for electrical equipment supply chains should be addressed at the national level to avoid fragmentation and increased costs for manufacturers and consumers.
- Recommendations 24-26: Introducing Qualified Technical Persons (QTP) requirements for vehicle maintenance and manufacturing is unnecessary and costly, given existing WHSA regulations.
- Recommendation 29: Mimicking Work Health and Safety Act provisions for electrically qualified HSRs is unnecessary and impractical.
- Recommendation 34: The EVC supports CPD requirements but advocates for alignment with other states.
- Recommendation 48: Electrical installation audits for recreational vehicles should not apply to road-registered EVs.
- Recommendation 49: Enhancing the regulator's information-gathering powers should be limited to avoid overreach.
- Recommendation 60: Industry safety and health representatives modeled after coal mining should not be applied to vehicle maintenance/manufacturing due to differing risk profiles.
- Recommendation 61: New financial contributions for the Electrical Safety Office should not be levied on electrical contractors; state government funding is sufficient.
- Recommendation 64(a): Inspectors should not have automatic access to residential premises.
- Recommendation 70: Phased electrical safety inspections and asbestos-related switchboard upgrades are costly and unnecessary for many homes.
- Recommendation 72: Record-keeping requirements at point of sale for electrical equipment are disproportionate and should be revisited with stakeholder consultation.
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Additional Comment: The EVC agrees with AS5732's recommendation for immediate availability of AEDs in workshops with EVs, emphasizing their importance in electric shock incidents.
