Wiring rules, ok
The electricians’ bible is all about safety, function and protecting your back. Peter Vandenheuvel explains the Standards development process from go to whoa.
Do the Wiring Rules watch out for users and off er protection, or ‘have their back’ in modern parlance?
Your first response may be that it’s not needed because, after all, they are rules. But think again.
As a member of the Wiring Rules Committee my answer is an unequivocal “yes”, and I believe other committee members would echo that sentiment.
The Wiring Rules have a very wide reach. They are mandated as the minimum requirement, in some form or other, across all jurisdictions throughout Australia and New Zealand.
This means the consequences of not following them can be wide ranging and extremely serious, or even catastrophic. At the lower end of the scale, they can include being prosecuted, being fined, having to re-do work, losing your licence, harming your reputation, causing a fire, etc.
The more critical consequences can be injury or death – for you, your employees or others in the community at large.
Your non-compliance (unintentional or otherwise) can change your life and that of others forever.
And, as often noted with serious or catastrophic incidents, not a stone will be left unturned to find and prosecute those responsible. When this happens, reference to compliance with the Wiring Rules (and any other Standards that are referenced as ‘Normative’ in its appendix A) will figure very prominently in those investigations.
So how the rules are written is crucial from a technical and comprehension viewpoint. It is extremely important for all users to have clear, non-ambiguous information and guidance. This will minimise any dispute about the installation or any consequences arising from a misunderstanding.
However, this is not an easy task. Members of the various Wiring Rules drafting committees are typically nominated by their organisations because of their expertise. They are dedicated, aware of the responsibility, diligent and extremely well intentioned.
Yet they can never be the font of all knowledge or across every issue in minute detail. Also, they have their careers, which must be the primary focus.
There are also other issues at play affecting the difficult task of ensuring clear and unambiguous communication to avoid unwanted consequences. Some of the key issues are:
- constrained areas of expertise among committee members;
- ongoing changes in regulatory and metering practices;
- technological advances affecting selection and installation of equipment;
- advances in design practices and project complexity;
- new developments in photovoltaic generation and installation practices;
- emerging technologies (eg: electric vehicles, WiFi + power, DC distribution, etc);
- increasing emphasis on workplace safety for electrical industry personnel; and
- increasing emphasis on the safety of users and the community at large.
All this is further complicated, for whenever we string a few words together in a phrase, that can have a number of different possible interpretations. It can lead to misunderstandings, non-complying work and hazardous situations arising.
Then further consider the lot of contractors and electricians. They are the group most affected by any changes but have only a limited Wiring Rules Committee representation (mainly contractor industry bodies, training organisations, unions and the like), and you get an idea of the degree of difficulty in trying to ensure protection of their interests.
What adds even more to this concern is that contractors and electricians are probably the least indemnified and the most reliant on their own interpretation of the Standards. Also, it is they who will suffer the financial loss and most of the aforementioned negative consequences if they get it wrong.
None of this is in any way intended to imply that other committee members don’t take the needs of contractors and electricians seriously. Quite the opposite, all concerns raised are properly dealt with.
However, other committee members have their own needs to consider, so those of contractors and electricians (and designers and engineers) would not necessarily be at the top of their lists. This certainly underlines that vigilance must be maintained at all times.
User input welcome
There is often lively committee debate as those representing contractors and electricians put in their two bobs’ worth when we need the Standard to ‘have their back’.
However, users also have certain responsibilities, including:
- ensuring you understand or find out exactly what is required by the Standard;
- investigation of all cross references;
- taking extra care when working on an installation or in a place that is
- getting an expert second opinion if in
- fulfilling all requirements to the letter,
or exceeding them.
Further, if readers want to know how they can have some input, the best time is at the public comment stage of any amendment or revision of the Standard. This is when the draft is completed but before the final pre-publication discussions.
As all such comments must be dealt with by the drafting committee, contributors can be confident their submission will be considered and the outcome placed on record.
Issues considering include
Priorities – Any new overriding matters directly involving the protection of people, livestock and property from electric shock, fire and physical injury that may arise as in AS/NZS3000 Clause 1.1 are expected to take precedence over other issues.
Define desired outcome – Focus on issues that will make a real difference. For all proposed changes, the desired outcome must be clearly defined at the outset to see whether change is warranted. Cosmetic changes with no real payback will only add to the industry’s already chaotic and continually changing environment.
Cost benefit – Recognise the difference between a need and a want. Every change involves extra costs for materials, labour, system change, training, implementation, etc. The industry, its customers and community at large should only bear the extra cost where there is a real benefit.
Minimise misunderstanding – Reduce or eliminate different interpretations by parties involved in designing, installing and verifying installations. This can be a major challenge, given that Standards have to be set out in a particular format.
The test could be: “Is a typical reasonably skilled contractor or electrician with a reasonable command of English and limited exposure to the Standard able to understand the requirements in a way that will mean compliance?”
As this is a key area of potential conflict (think electrician versus inspector), the wording must be unambiguous so that all parties agree on how the requirements can be met.
Special installations – Electricians are not detectives. A contractor or electrician responsible for an entire electrical installation may be aware of site-specific requirements (hazardous areas, medical treatment areas, etc). However, it is unreasonable to expect anyone with limited site-specific access or knowledge to conduct an investigation or make any determination, especially if it is not obvious.
Therefore, regarding particular requirements, it must be clearly stated that the installation owner or occupier is responsible for the relevant advice.
Extra work arising from changes – As most changes to Standards are not retrospective, it is unusual for this to arise.
However, there are occasions when ‘trigger points’ require additional work if new tasks are carried out on existing installations. Where this occurs, the owner or occupier of the installation may be faced with additional unexpected costs. Hence the wording in the Standard should help in presenting a case for such extra works.
Costing – Avoid vagueness, if you can’t measure it you can’t cost it. Owners or occupiers want at least an indication of costs (if not a quotation). The requirements in the Standard must be clear enough to allow the contractor or electrician to quantify what is needed and how it will be applied when it comes to costing the proposed works.
Practicality and buildability – The requirements in the Standard must be based on their being practically, safely and economically implemented, then inspected and/or tested. Any particular requirements that can’t be so implemented should as a minimum have a warning note. This is also of particular importance when discussing whether testing is to be carried out live.
Negative consequences – It is always important to ensure there are no unintended or negative consequences, or alternatively include information on mitigating them.
Defensibility at law – There should be no ‘could have’, ‘should have’, ‘would have’, ‘may’ or similar vague words potentially implying that a particular requirement in the Standard is optional (even if it is). These lead to higher expectations for the occupier or owner.
Even more important, there should be no such implied ‘optional’ requirements of any kind that could lead to a contractor or electrician being prosecuted over an incident when lawyers start to talk about best practice and negligence. Remember, hindsight will always have 20/20 vision so when a financial benefit becomes the objective any ambiguity is likely to be explored or even exploited to the possible detriment of the contractor or electrician.
Such requirements (either entirely or subject to qualifications) must be mandated using the term ‘shall’ to remove any doubt. Likewise, any guidance must be clarified so that there is no implication of the guidance being a ‘shall’.
Identifying changes – Make the changes obvious to the user. Most users know, whenever there was an amendment to a standard, a marker was included in the margin in the next print. But for some obscure reason the same practice was never adopted for revisions. So the user had to identify each and every change by comparing the old and new version page by page. This practice was also going to be carried forward for the 2018 edition of AS/NZS3000. Imagine the needless cost to the industry for the 100,000+ users to do that!
Well, it was somewhat of an uphill battle but with considerable debate it did result in having the red margin markers included to alert the user to the change, not only saving substantial cost in users not having to do their own comparison but also saving rework that may have resulted. A clear example of The Wiring Rules having your back and making sure user interest is not being overlooked.
Cross referencing – Wherever a change or new requirement needs to refer to other requirements, reference to these must be included to ensure it is not overlooked.
Perhaps the above gives some insight on how much effort is required to help make the lot of a contractor or electrician less unhappy.