NBN R 03-001:2021: a certificate is not a safety system

Electric and hybrid vehicle safety in Belgium is usually discussed in terms of certificates. HEV1, HEV2, HEV3. Who has which level, and when does it expire?

Useful questions. Just not the first one. The first question is: how are we controlling the risks created by work on electrically propelled vehicles in our organisation?

That is what NBN R 03-001:2021 is for. The Belgian standard “Electrically propelled road vehicles - Controlling risks during interventions”, published in May 2021, covers technical interventions on vehicles in categories M, N and L, plus the safe storage of damaged or potentially damaged vehicles and components. It is about how work is organised, not only about what a technician knows.

A certificate belongs to a person. Safety belongs to the employer.

Belgian occupational-safety rules place the duty on the employer: analyse the risks, define preventive measures, provide training and instructions, and make sure people performing electrical work are competent for the tasks assigned to them.

This prevents a dangerous shortcut: “The technician has a certificate, therefore we are covered.” You are not. A certificate is evidence that supports a competence decision. It does not replace your risk analysis, procedures, equipment, authorisations or supervision.

"That is the difference between certification and risk management."

Two workshops

Workshop A has ten HEV2-certified technicians. But nobody has clearly defined who may make which vehicle safe, the isolation procedure differs by brand, damaged EVs have no designated storage process, PPE inspection is inconsistent and responsibilities are assumed rather than assigned.

Workshop B has fewer certificates. But the employer has completed a robust risk analysis, mapped tasks and responsibilities, defined who may perform which interventions, trained people accordingly, documented procedures, provided appropriate equipment and created clear escalation rules.

Which one has the stronger safety system? Certification without organisational implementation creates false confidence.

Competence has to be task-specific

A receptionist who moves a vehicle, a roadside technician, a body repairer, a diagnostic technician and someone working on live high-voltage components all face different risks. Even inside one technical role, a technician may be competent on one vehicle architecture and need extra instruction on another.

Competence therefore connects four things: the person, the task, the vehicle and the risk. That is far more useful than treating “HEV trained” as a binary status.

EV risk does not stop at the lift

• Who accepts a damaged vehicle, and who is allowed to move it?
• Where can it be parked, and how is an electrically hazardous vehicle identified?
• Who controls access to that area?
• What happens when a battery shows signs of thermal instability?
• How are contractors, bodyshops or roadside partners informed?
• Who confirms that an HV system has been made safe before another person begins work?

These are organisational questions. A technician certificate cannot answer them.

The practical order of work

1. Understand the legal requirements and the NBN R 03-001:2021 framework.
2. Analyse the risks created by EV-related activities in your organisation.
3. Map roles, tasks, responsibilities and required competence.
4. Define procedures, equipment, authorisations and escalation routes.
5. Select training and, where valuable, sectoral certification that supports those requirements.
6. Verify that people can perform the work safely in the real workplace.
7. Reassess when vehicles, tools, procedures or tasks change.

Starting with “Which certificate should everyone get?” feels simpler, but it produces both overtraining and dangerous gaps.

"The question is not “Are our people HEV certified?” but “Can we demonstrate that the right people are competent, authorised, equipped and organised to do the right work safely?”"

Two practical consequences follow from that: what to do with people who fall outside the sectoral certification scheme, and what to write into your annual action plan. Both are covered in the follow-up article, “Outside the paritair comité, and the 1 November deadline”.

Sources

• NBN, NBN R 03-001:2021 - Electrically propelled road vehicles - Controlling risks during interventions (active standard, published 26 May 2021).
• Belgian Federal Public Service Employment, Labour and Social Dialogue - Electrical installations and AREI: employer risk assessment, training and instructions, BA4/BA5 competence assignment.
• EDUCAM - HEV safety certification framework (HEV1, HEV2, HEV3), validity and recognised operators.