Request ID: FOI-3600-2223 Date published: 14 April 2023
TFL introduced a safety ban of e-scooters on its network due to privately-owned e-scooters and e-unicycles catching fire whilst on TfL services or infrastructure.
In a previous FOI request, the stated reasons electric scooters were banned from TFL services whilst electric bikes weren’t, are:
1. “E-bikes are legal to use on public roads and are subject to the regulations set out in the Electrically Assisted Pedal Cycles Regulations 1983 and the Electrically Assisted Pedal Cycles (Amendment) Regulations 2015”
2. “Manufacturers are required to equip Electrically Assisted Pedal Cycles with battery management systems / master control devices that prevent tampering or modification” and “Other e-vehicles - including e-scooters and e-unicycles - are not subject to the same manufacturing requirements”
3. “[e-scooters] are not currently legal to use on public roads”
Since it is legal to use e-scooters on private property could you please state:
1. What parts of the Electrically Assisted Pedal Cycles Regulations 1983 and the Electrically Assisted Pedal Cycles (Amendment) Regulations 2015 are related to electric or lithium battery fire safety?
2. In regard to electric or lithium battery fire safety, what standards are ebikes required to conform to and escooters aren't?*
**An example of a standard is BS EN 15194:2017
TfL Ref: 3600-2223 Thank you for your request received by Transport for London (TfL) on 30 March 2023 asking for information about e-Scooters. Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. We confirm that we hold some of the information you have requested: You asked: Since it is legal to use e-scooters on private property could you please state: 1. What parts of the Electrically Assisted Pedal Cycles Regulations 1983 and the Electrically Assisted Pedal Cycles (Amendment) Regulations 2015 are related to electric or lithium battery fire safety? 2. In regard to electric or lithium battery fire safety, what standards are ebikes required to conform to and escooters aren't? **An example of a standard is BS EN 15194:2017
It has been nearly 18 months since TfL introduced its ban on e-scooters and e-unicycles. Since the ban was introduced, the landscape of e-vehicles and knowledge around the inherent safety risks associated with them has developed rapidly. We have seen an increase in the use of e-bikes and e-bike conversion kits on our roads and we are working closely with the London Fire Brigade (LFB) to ensure that we take an appropriate and proportionate response to the specific risk profile that e-bikes present. However, we would not rely solely on the regulations to inform our decision around the safety or our approach to e-bikes. As such these remain able to be used (aside from other bicycle-based restrictions) across the TfL network. This decision has been based on a number of factors, including:
E-scooters are not legally allowed on England’s roads or footpaths. E-Bikes are legal, this means that any decision around prohibition of these across the TfL network is very different to that of illegal e-scooters.
E-scooters are not subjected to declarations of conformity (and UKCA approval) when built. Therefore, TfL cannot make general principled decisions on the safety of them whilst transported on the network. Again this is not the case for e-Bikes which in general have a higher build quality and lower risk profile (when taken as a whole).
As e-scooters are illegal on the roads there are likely to be significantly fewer recorded fires involving them compared to other forms of transport, like e-Bikes, so need to treat data on these instances, in terms of incidence of incidents, carefully.
It is important to note that TfL’s current decision is in line with other train operating companies (including Eurostar); in fact TfL has taken a lead in these decisions and have been at the forefront of reducing risk on our network by prohibiting the transport and use of e-scooters on the network.
As always, the above position will be reviewed when new information is brought to light and through liaison with the London Fire Brigade as our fire regulator and our train operating company colleagues.
There are no escooter regulations that exist which govern their manufacture or build/quality and safety.
As a result we cannot compare what exists in the above ebike guidance, standards and regulations against an absence of these documents for escooters. The EU Standard that you have referred to above in your request - BS EN 15194:2017: “Cycles. Electrically power assisted cycles. EPAC Bicycles” - covers an even wider range of ebike controls as below : This European Standard is intended to cover all common significant hazards, hazardous situations and events of electrically power assisted bicycles, when used as intended and under condition of misuse that are reasonably foreseeable by the manufacturer. This European Standard is intended to cover electrically power assisted bicycles of a type which have a maximum continuous rated power of 0,25 kW, of which the output is progressively reduced and finally cut off as the EPAC reaches a speed of 25 km/h, or sooner, if the cyclist stops pedalling. This European Standard specifies requirements and test methods for engine power management systems, electrical circuits including the charging system for the design and assembly of electrically power assisted bicycles and sub-assemblies for systems having a rated voltage up to and including 48 V d.c. or integrated battery charger with a nominal 230 V a.c. input. This European Standard specifies safety and safety related performance requirements for the design, assembly, and testing of EPAC bicycles and subassemblies intended for use on public roads, and lays down guidelines for instructions on the use and care of such bicycles. If this is not the information you are looking for, or if you are unable to access it for any reason, please do not hesitate to contact me. Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed. Yours sincerely Sara Thomas FOI Case Management Team General Counsel Transport for London