Jim Wallace of Seaward looks at the implications of the new IET Code of Practice for maintaining the safety of electrical equipment in the workplace.
The new fourth edition of the IET Code of Practice for In Service Inspection and Testing of Electrical Equipment provides a timely reminder to all those with a responsibility for workplace safety under the Electricity At Work Regulations 1989.
The revised and updated Code of Practice is essentially the third step in a process that started with the publication of the Lfstedt review and continued with the HSE’s revised guidance on maintaining portable electrical equipment in low risk environments.
The IET’s document follows this theme by highlighting the importance of taking a structured approach to risk assessment to determine equipment inspection and testing intervals.
The clear message from the new IET Code is that electrical equipment maintenance regimes should be based on a more focused and robust approach to assessing the risks posed by appliances. The implication is that only when the risk of using electrical equipment has been assessed and understood can it be managed through a programme of inspection and testing.
Of course, the Code has always emphasised that the frequency of inspections and testing should be reviewed on a regular basis after an assessing the risks associated with the use of a particular appliance.
However, new prominence is given to this approach in the latest document which also reiterates that risk based assessments are the responsibility of the duty holder, but that a duty holder may enlist the services of a competent person to assist in this process.
Importantly, the new emphasis on risk assessment of the CoP also is completely consistent with the existing legal requirements of the Management of Health and Safety at Work Regulations 1999. Regulation 3 requires all employers and self employed persons to assess the risks to workers and others who may be affected by their undertaking. Where the employer employs five or more employees, the significant findings of the assessment must be recorded.
Risk encompasses many factors that can eventually influence a final decision and, for example, should include a full consideration of the environment in which the equipment is being used, the level of user awareness, the equipment construction and type, frequency of use, previous records and type of installation for fixed appliances.
All of the factors used in the risk assessment should culminate in an informed decision being made on the frequency of any inspections and tests required.
To further reflect the new emphasis on assessment of risk, the IET’s also stresses that its own widely used table on test intervals should be used only as guide to the initial frequencies of inspection and testing. Future inspection and test intervals should depend on ongoing risk based assessments, with periods being increased, decreased or kept the same, as appropriate.
Importantly, in a significant change, and to further emphasise the link between the dutyholder, risk assessment and inspection and testing intervals, the new CoP also recommends that the date for re-testing should not be marked on the pass label.
Instead it advises that ‘the duty holder should determine the date for the next inspection and/or tests on a risk assessment basis...and record this on their ‘Equipment formal visual and combined inspection test record.’
Clearly, without a visual reminder of any next test due dates, there is likely to be increased reliance on the effective use of electrical equipment asset records and historical inspection and test data.
Although there is no requirement in the Electricity at Work Regulations 1989 to keep records of equipment and of inspections and tests, the HSE Memorandum of Guidance (HSR25) on these regulations advises that records of maintenance including test results should be kept throughout the working life of equipment.
The future of PAT
Although the new guidance reiterates that electrical safety is the responsibility of dutyholders, it also says that they can seek the advice of external contractors involved in testing to aid them with their risk assessments.
Set against the principles of these new risk-based maintenance programmes, effective test record keeping systems are therefore likely to take on even greater importance as a valuable management tool for reviewing the frequency of inspection and testing - and without records duty holders cannot be certain that the inspection and testing have actually been carried out.
While changes for PAT firms are inevitable, overall the new landscape therefore provides an opportunity for contractors to extend their offering to customers. This will mean moving away from a simple ‘cost per test’ driven service to a more thorough service based on a value added, professional test and record keeping service.
Understanding risk assessment will be the key to this and extending this approach to other areas of non-electrical workplace safety matters is also a realistic possibility for added work.
To help in this transition, and introduced in response to the new IET Code, the latest generation Apollo 600 PAT tester is equipped with an on-board risk assessment tool to help determine re-test intervals. The universal nature of this feature, and the inclusion of other safety certification capabilities, effectively converts the tester into a much more versatile safety management tool for the assessment of other workplace safety aids such as fire detection systems, alarms and emergency lighting.
As a result, PAT personnel also have the potential to conduct a range of additional risk assessments and inspections, providing more opportunities for new revenue raising services.