Outside the paritair comité, and the 1 November deadline

Sectoral HEV certification works well for the employers it was built for. EDUCAM's HEV levels, funding and recognised operators are tied to the joint committees of the automotive sector and related trades.

But electric vehicles are not confined to those joint committees.

Who falls into the gap

• Fleet and leasing companies with their own technical or logistics staff.
• Public services, utilities and municipal depots maintaining their own vehicles.
• Transport, distribution and last-mile operators with in-house workshops.
• Bodyshops, glass and tyre specialists under a different joint committee.
• Roadside assistance, towing, salvage, dismantling and recycling.
• Machine builders, coachbuilders and converters working on M, N or L vehicles.
• Temporary workers, contractors and self-employed technicians on your site.

These people face the same high-voltage risk. They just have no obvious sectoral route to a certificate, no sectoral funding and often no external benchmark for what “enough training” means.

The good news: the legal duty does not depend on your joint committee

Whatever committee you sit in, the employer duty is identical: analyse the risk, organise the work, train and instruct people, and assign competence and authorisation for the tasks they actually perform. The sectoral certificate is one way to produce evidence. It is not the only one.

For everyone in the gap, the practical answer is a competence file per role: a documented risk analysis, a training programme matched to the tasks, a recorded assessment, a written authorisation signed by the employer, and a refresh interval. That file does the same job a certificate does, and it is often more precise, because it describes your vehicles, your tools and your procedures.

"No joint committee scheme? Then you build the evidence yourself. It is more work, and it is entirely doable."

Two more points worth planning for. Contractors and temporary workers need the same clarity in writing before they start work on your site. And where certification is available, it is often still worth taking, because it gives your people a portable, externally recognised credential.

Your annual action plan is due before 1 November

Every Belgian employer has to submit an annual action plan, the JAP, before 1 November for the following calendar year. It is the moment where electrification either enters your prevention policy or quietly does not.

Concrete items worth including:

1. Update the risk analysis for EV and hybrid interventions, including damaged vehicles and battery storage.
2. Map every role that comes into contact with high voltage, including reception, movers, cleaners, contractors and temporary staff.
3. Set the target competence level per role, and name who is authorised for which intervention.
4. Plan training and re-certification dates, including the people outside the sectoral scheme.
5. Budget and schedule PPE, insulated tools and their periodic inspection.
6. Write or revise the procedures: making safe, lock-out and tag-out, handover between technicians, escalation on thermal events.
7. Define the storage and quarantine zone for damaged EVs, with access control and signage.
8. Fix an evaluation moment: who checks, in the workplace, that the procedures are actually followed?

If those eight lines are in your plan, electrification is genuinely part of your prevention policy. If they are not, the certificates in your files are describing a system that does not exist yet.

Where IAS fits

We build technical safety programmes around the work itself: risk, role, procedure, practice and competence. That includes organisations with no sectoral route to HEV certification, and it includes helping you turn the outcome into action-plan lines you can defend.

Start from the standard, not from the certificate. Then make the plan say so.

Sources

• Codex on well-being at work, Book I - dynamic risk management system, global prevention plan and annual action plan (submission before 1 November).
• Belgian Federal Public Service Employment, Labour and Social Dialogue - employer risk assessment, training and instructions, BA4/BA5 competence assignment.
• NBN R 03-001:2021 - Electrically propelled road vehicles - Controlling risks during interventions.