Working safely around electrical hazards

With the release of the refreshed Australian Standard AS/NZS 4836:2023 Safe working on or near low voltage and extra-low voltage electrical installations and equipment earlier this year, it is worth reviewing the content and its application to businesses in our industry.

In particular:

• Is compliance with this standard compulsory in workplace health and safety (WHS) law?
• Are there new/additional elements that you need to consider?

Is compliance with the refreshed standard compulsory in WHS law?

There is no short answer to this question.

However, failure to assess risk and implement controls for electrical work in a way that is consistent with this standard could place businesses, and potentially directors of those businesses, at risk of prosecution from the relevant safety regulator if the worst should happen.

Although AS/NZS 4836 is not mandated by WHS regulations and is barely mentioned in the model Code of Practice for Managing Electrical Risk, it is routinely referred to by regulators, and may be introduced by prosecutors at trial, to articulate how a business has/has not adequately attempted to protect its workers with respect to specific hazards or situations.

This is perfectly valid for workplace incidents as the determination of guilt contemplates how the person conducting a business or undertaking (PCBU) has managed the risks involved in their activities against available knowledge, standards, and controls for that industry.

In such instances, there is necessarily the question of ‘what material represents an adequate risk assessment and controls for such work?’ and the authoritative document for work on or near low voltage electrical installations is invariably AS/NZS 4836:2023.

Are there new/additional elements to consider?

The new standard extends its scope to include work on extra-low voltage installations and equipment and non-electrical workers.

It includes additional information specific to:

• Principles of risk management, assessment of risk and risk treatment.
• Working with asbestos and polychlorinated biphenyls.
• Working below ground level.
• Cutting cables and wiring enclosures.
• Selection and use of test equipment.
• Selection and use of personal protective equipment.
• Preservation of an incident scene.

With this knowledge, PCBUs involved in electrical work may need to review and/or update their safe work method statements (SWMS) and procedures in consultation with their workforce.

When are workers exposed to energised equipment?

The model WHS regulations do not provide a definition of when exposure to energised equipment occurs; however, AS/NZS 4836:2023 (section 2.3.7) indicates:

• risk treatments (controls) are required if any work is to take place within 3m of energised exposed conductors/parts; and
• any work within 0.5m of energised exposed conductors/parts is deemed to be ‘working on’ those parts.

Importantly, the basic test for de-energised qualifies as ‘energised electrical work’ both under this part of AS/NZS 4836 and the WHS regulations in each jurisdiction.

This then invokes those specific WHS duties on the PCBU to:

• document the risk assessment;
• have a SWMS for the electrical work;
• ensure the work is performed by a competent (generally licensed) person with tools, test equipment, and personal protective equipment (PPE) that are suitable, properly tested, and in good condition; and
• ensure that the worker(s) cannot inadvertently make contact with adjacent energised equipment,

which is consistent with AS/NZS 4836.

Work on energised electrical equipment

Work on energised electrical equipment is prohibited in every jurisdiction, unless the work legitimately meets the following criteria:

• testing to verify de-energisation;
• necessary in the interests of health and safety; or
• necessary that the equipment be energised for the work to be carried out properly; or
• there is no reasonable alternative means of carrying out the work.

Other testing and/or fault finding under energised conditions can only be justified if it meets one or more of the last three criteria above and requires a trained safety observer.

Convenience, for either the customer or the work of the electrical contractor, is not a valid basis for a decision to work on energised equipment.

The point of this commentary, for the benefit of NECA members, is to demonstrate that AS/NZS 4836:2023 is not new or vague guidance material, it is as central to the competent practice of the trade as the Wiring Rules and associated installation standards.

It is especially important that your risk assessments and SWMS for electrical work tasks are constructed consistent with AS/NZS 4836:2023 and that your workers are informed of, equipped and work to those SWMS.

Specific hazard – residential roof spaces and under floor areas

This year has seen several fatalities of electrical workers in these locations, in more than one jurisdiction. There is also long history before that which has led to bans on any workers entering roof spaces whilst the installation is energised (WA), and alerts direct mailed to licence holders (NSW) advising that isolation at the installation main switch is critical to avoiding potentially serious shocks in those locations. Many NECA members will also have seen communication a few weeks ago in response to recent fatalities in NSW.

Three aspects of work in these areas appear to contribute to the seriousness of the outcome.

1. Potential for illegal, exposed, damaged or deteriorated wiring (lacking basic protection) or other energised extraneous conductive material.
2. Presence of an earthed situation – pipes, uninsulated earth wires, earthed metal frames, soil.
3. The ability to effect a rescue from the restricted space and/or working one-out/out of sight.

NECA strongly recommends that member organisations that send workers into these areas, review their policies and SWMS, in consultation with their workforce, to ensure that the risk controls are in place to avoid further preventable deaths.

This article was published in Issue 1 of Electrical Connection 2024.