Written evidence from Zurich UK (ELV0131)

Zurich UK’s Response to EFRA Committee Inquiry into Electric Vehicles

Zurich UK welcomes the opportunity to input into this Call for Evidence regarding electric vehicles.

Zurich UK provides a suite of general insurance and life insurance products to retail and corporate customers. We supply personal, commercial, and local authority insurance through a number of distribution channels and offer a range of protection policies available online and through financial intermediaries for the retail market and via employee benefit consultants for the corporate market. Based in a number of locations across the UK - with large sites in Birmingham, Farnborough, Glasgow, London, Swindon, and Whitely - Zurich employs approximately 5,000 people in the UK. 

Before addressing the specific questions in the call for evidence, it is important to note that Zurich fully supports the drive towards sustainability and net zero carbon emissions. We have a long-stated ambition to become one of the most responsible and impactful businesses on the planet. As the Climate Change Committee has shown, surface transport makes up a significant proportion (23%) of UK emissions and rapid transition to zero-emission vehicles through electrification remains paramount if the UK is to reach net zero by 2050. This is why Zurich has become members of the EV100 initiative, which means that we are committed to transitioning our global car fleet to 100 percent electric vehicles by 2029 (with an interim target to transition to 100% Electric Vehicle (EV) or Hybrid by 2025). We are expanding our EV charging points at our UK office locations and have also provided interest-free loans to our employees wishing to install an electric charging point at home.

However, our insight as one of the largest commercial and municipal insurers in the UK means that we also have significant concerns that regulations are not keeping pace with the realities of the increased fire risk of Electric Vehicles. Of particular concern are the regulations governing multistorey carparks and parking facilities with buildings attached or above them. Therefore, the below submission focuses on responding to Question 24 in the Call for Evidence:

Question 24. In terms of charging infrastructure, are there unique barriers facing consumers in areas of low affluence and/or multi-occupancy buildings, such as shared housing or high-rise flats? Do you consider public EV charging points to be accessible and equitable compared to home-charging points? What can be done to improve accessibility and equitability?

Across the world, fires in parking facilities are becoming more frequent and costly, therefore presenting more of a challenge to fire fighters. This is due to a number of factors across vehicle types, for example, the increased use of plastics in cars making them more combustible. However, there are a number of risk factors specific to electric vehicles. This is due to the presence of high voltage lithium-ion battery packs and charging stations, which significantly increases the number of ignition sources in parking facilities.

Defective lithium-ion batteries in electrical vehicles can also cause thermal runaway reactions. These thermal runaway reactions release extreme heat, as well as toxic gasses like hydrofluoric acid. Due to their extreme heat release and the duration of the reaction, significant fire spread to adjacent vehicles can often occur.

These ignition sources, combined with the sheer number of combustible materials applied in vehicles, increases the potential of a fire to develop and grow rapidly. Parking facilities often consist of horizontally large open floor areas and have open connections between floors i.e. ramps, staircases, and elevator shafts. These open structures, if not suitably protected, often lead to horizontal and vertical spread of both thermal and non-thermal fire elements.

Such fires can often severely damage both the building elements and the supporting structure of the building above. Therefore, if a fire is not effectively contained and controlled at its source, insurers are increasingly having to consider the likelihood that fires in such parking facilities may well result in a large – or even a total – loss, not only of the vehicles inside but also the building (s) above.

Unfortunately, current building regulations do not mandate the installation of sprinklers which would help suppress the fire quickly at source. This has not always been the case. Regional acts, such as Section 20 of the London Building Acts (Amendment) Act 1939, required sprinkler protection in underground car parks and 4 hours of fire resistance for buildings that met the required definition. Yet these were withdrawn in 2012/3, following moves to reduce the regulatory burden on developers. Indeed, the current section 18.11 of Approved Document B actually states, “Car parks are not normally expected to be fitted with sprinklers.”

This must be urgently revisited, particularly in light of the increased combustibility and ferocity of lithium-ion battery fires. Indeed, it is Zurich’s view that it should not be possible to construct basement car parks for either mid- or high-rise buildings without adequate sprinkler protection in accordance with the latest LPC Rules for Automatic Sprinkler Installations incorporating BS EN 12845. We also advocate that building regulations should be amended to increase the required fire resistance in underground carparks from the current 60 - 90 minutes to 4 hours, as was previously the case.

The additional intensity of fires involving Electric Vehicles means they have an impact beyond their immediate surroundings. Especially with underground carparks, consideration must be given as to how to ensure that the structure of the buildings above can cope with this intensity of fire. Current ventilation requirements should also be reviewed, to take into account the more intensive and longer duration fires associated with Electric Vehicles. It should be noted that the current ventilation requirements for underground carparks are less stringent than that for a non-car park basement storey, despite the fire risk associated with vehicles. 

An absence of appropriate regulation in this area will not only increase the prevalence of such large fires. Insurers price based on risk; therefore, the increased risk posed to these types of carparks and buildings is likely to impact both the appetite individual insurers have to underwrite these types of risks, as well as potentially increasing the likely premium charged.