EV charger isolator location.

[ScouseSpark]

opinions sought on the whole Isolator for EV charger..
Now EV CHARGING SAFETY GUIDELINES May 2019 2ND EDITION... state re Isolator.....METHOD OF ISOLATION "All final sub-circuits supplying a charging station should include a lockable isolator that operates in all live conductors including the neutral". now there is no nailed down statement that gives the location of this
Asnzs 3000/2007 2.3.2.2.1 (f) says an Isolator should be "Readily Available"
EV chargers first Periodic assessments are due and heres what weve got..
Public car park with 5 x schneider two outlet chargers, 1x 3pole MCB in DB board feeding 2x 4pole control mcbs in enclosure, which in turn feed seperate 4 pole B type rcds which feed separate feeds across to the Charger station so 2 sources of supply to charger, the possible isolation devices (the RCDs or control MCBs) are in locked DB board and control panel which is in a locked service cupboard. took me an hour to track a key to get access to it..
this is where you can all shoot me down.. I would say the above installation doesnt comply because
I would prefer to see the Isolator local to the charger station which then meets the "readily Available"criteria..
or at least accessible without the need to access a live control panel with no lasking panel to lockout using the MCB or RCD which is in effect a live enclosure.
possibly suitable Isolators located below the Control panel would be an improvement but in a locked service cupboard??? would they really be classed as readily available
Also In view of this being a High Risk installation I would look to the Isolators being local to meet the Requirements of Asnzs 3000/2007 2.3.5 Emergency Switching... "Means shall be provided for Emergency switching of any part of an electrical installation where it may be necessary to control the supply to remove an unexpected danger"
......
feel free to comment and help out...
thanks.....

[ScouseSpark]

IMO, the most important word is "GUIDELINES" the is no compulsion to follow these (yet). But common sense and in the event of an issue they would be best practice to follow.

If it was me I would have an isolator in proximity to the charger or make a reccomendation that in order to comply with the guidelines a isolator is require to meet the Periodic Assessment.