Testing and tagging of electrical gear is now the norm for businesses, but is it really necessary? Chris Halliday of PowerLogic investigates.

 The owner of a small business that had moved into new premises a couple of years ago was keen to reduce electricity consumption.

I was asked to carry out an energy audit, during which I always look for obvious safety issues or non-compliance with electrical requirements. This distinguishes me from energy consultants that have little idea about electricity, and it adds value for the client.

One constant issue is the testing and tagging of electrical equipment, and most of the gear at this business had none. A couple of items had old tags from when they were at the previous address, and only one new appliance had a new tag – from the supplier.

I always advise clients on Australian Standards and legal requirements to help them adopt safe practices for testing and tagging. This time the client analysed what I said instead of just accepting it.

The response was: “If we are not deemed a hostile operating environment, why do we do need to carry out testing and tagging?”

What a great question! Let’s investigate.

Legal requirements

The recently harmonised Work Health and Safety Regulation covers all workplaces in Australia.

Section 150 states that electrical equipment supplied by a socket outlet and exposed to operating conditions likely to result in damage or reduced life span must be regularly inspected and tested.

Section 151 states that untested equipment should not be used at a workplace if it requires testing under Section 150.

Failure to comply attracts penalties of $3,600 for individuals and $18,000 for corporations.

Further, Section 165 requires that all reasonable steps be taken to ensure regular testing of residual current devices (RCDs) for correct operation.

Keep in mind that RCDs do fail. Some that we have tested lately don’t trip, or are too slow to trip, and may not save a life.

Looking at these sections in isolation, one could conclude that testing and tagging of electrical equipment is needed only in hostile environments (perhaps other than RCDs).

But how does a business demonstrate its primary duty of care to workers and other people? This duty is encapsulated in Section 19 of the harmonised Work Health and Safety Act.

If testing and tagging of electrical equipment is not done or – as stipulated at Section 21 that fixtures, fittings and plant be without risk to personal health and safety – the business cannot possibly fulfil that duty.

Relevant Standards

AS/NZS3760 is our normal ‘test and tag’ Standard, but there are others likely to impose additional requirements.

AS/NZS3551 covers patient areas and medical equipment, and AS/NZS 3012 deals with construction and demolition sites, etc.

Codes of practice

The Harmonised Code of Practice for Managing Electrical Risks in the Workplace 2015, requires a safe system of work for the management of electrical equipment (see Sections 3.1 and 3.2).

Section 3.2 does go on to say “not all electrical items need to be inspected and tagged under Regulation 150” and “electrical equipment used in lower-risk operating environments does not require inspection and testing or tagging”.

However, it then goes on to discuss the testing and tagging requirements of AS/NZS3760 for lower-risk environments. Confused?

State authorities

The WorkCover NSW website states that businesses and employers should eliminate any risks of injury from electrical equipment, electrical work or electrical installations.

If this is not reasonably practicable, the risks must be “minimised”.

The text goes on to include inspection and testing of electrical equipment as a requirement. Other state authorities will be expecting similar management of electrical hazards.

Of course, it’s when something goes wrong that some explaining will be needed. This could be the result of a WorkCover inspection or an incident.

Prosecution and fines are likely consequences when something goes wrong. Lose of reputation and damage to branding will be particularly important for schools, patient areas, safety businesses, corporations, etc.

Conclusion

Specific legal requirements for testing and tagging are included in the harmonised Work Health and Safety Regulation.

However, they are focused on electrical equipment in more hostile environments where damage is more likely.

General legal responsibilities for managing workplace hazards are included in the harmonised Work Health and Safety Act under a primary duty of care. Businesses will need to demonstrate a safe system of work, and this will be difficult without a test and tag regime.

AS/NZS3760 is the primary standard in Australia and New Zealand for the testing and tagging of electrical equipment. It covers inspection intervals, testing methods, test result limits, records for inspection and tests, and resultant actions.

Table 4 in AS/NZS3760 provides ‘indicative’ inspection intervals, but they can be varied using a risk management approach, generally for shorter inspection intervals.

The inspection, testing and tagging of electrical equipment will add expense. However, it is crucial for safety – and avoiding prosecution, fines, loss of reputation and damage to branding.

www.powerlogic.com.au