Specific Safety requirements for Works, Installations, and Appliances
As outlined, it is proposed to provide for a general safety requirement stating that electrical fittings must be designed, constructed, maintained, installed, supplied, assembled, connected, tested, repaired and used in a manner that is electrically safe.
In addition to this general requirement, there will still need to be specific safety requirements for works, installations and appliances. Each area has safety requirements unique to its needs. This section discusses how these specific requirements are achieved.
Protection Against Direct and Indirect Electrical Contact
Regulation 94 (Protection against direct and indirect electrical contact) is proposed to be retained in the new regulations as a general requirement covering works, installations and appliances.
Works
Works is defined in the Electricity Act 1992 as any fittings that are used, or designed or intended for use, in or in connection with the generation, conversion, transformation, or conveyance of electricity; but excludes any fittings that are used, or designed or intended for use, by any person, in or in connection with the generation of electricity for that person's use and not for supply to any other person; and any part of any electrical installation.
For the most part, Safety Management Systems (SMS) will address safety associated with works. However, not all works will be covered by an SMS. Therefore it is proposed to include in the new regulations safety provisions for works that are not the subject of a SMS.
With respect to construction of works, it is proposed to carry forward an equivalent to Regulation 87(2) and (3). Regulation 87 at the present covers requirements for works and installations. The proposal is to separate the requirements for works from the requirements for installations. This separation will improve the clarity of the regulations around the different requirements for works and installations. It is proposed that 87(4) will not be carried over as its substance can be adequately captured under the general safety requirements.
Regulation 65 (Isolation fittings for works), Regulation 70 (Cables and conductors) and Regulation 93A (Interference with, or movement of, works) are proposed to be carried over to the new regulations unchanged.
It is proposed to also carry forward Regulation 92 (Conductor insulation for overhead electric lines) but to remove the words "other than neutral" as there should be no bare wires on overhead electric lines. This requirement is not intended to be retrospective, but in the future there should be no bare wires.
Installations
Electrical installation is defined in the Electricity Act 1992 as all fittings that form part of a system for conveying electricity and that form part of such a system at any point from the point of supply to a consumer to any point from which electricity conveyed through that system may be consumed. This also includes any fittings that are used, or designed or intended for use, by any person, in or in connection with the generation of electricity for that person's use and not for supply to any other person; but does not include any electrical appliance.
It is proposed to amend the regulatory provisions concerning installations, mainly due to the recent completion of a revised version of the AS/NZS 3000 Wiring Rules.
AS/NZS 3000:2007
Two current regulations reference AS/NZS 3000. Those regulations that have 3000 as a mandatory requirement are Regulation 37 (3) (Testing of prescribed work) where only part of 3000 is referenced, and Regulation 69A (1) and (3) (Electrical installations). Regulation 69A (2) refers to AS/NZS 3000 as a means of compliance.
It is proposed to carry forward Regulation 69A and the references to AS/NZS 3000.
AS/NZS3000:2007 has moved more towards a performance-based approach. This means that a system of alternative approaches (chosen by the electrical worker) rather than the present system of meeting fundamental requirements supported by "deemed to comply" solutions is the preferred method of achieving compliance. The reference to Standards is still proposed to be retained in the regulations but with amended provisions on how the implementation of the Standards can be achieved.
It is proposed to provide that if an installer chooses not to apply prescriptive requirements, the installer will be required to comply with the additional performance-based requirements set out in AS/NZS 3000:2007 and the installation will be subject to third party inspection/verification.
It is proposed that current third party verification, special competencies and periodic re-verification will be carried forward to the new regulations.
Other Amendments
Consistent with the proposal to split the carry forward of Regulation 87, it is proposed to introduce a new regulation for construction of installations. It is proposed, however, that any aspects of Regulation 87 for installations that are contained in AS/NZS 3000 will not be carried forward. Additionally, some of the references to Electrical Codes of Practice are out of date and need to be updated or removed.
Regulation 72 (Position of switches and protective fittings) is mainly covered by AS/NZS 3000, although some is relevant to works. It is proposed that any part of this regulation that can be found in AS/NZS 3000 will not be carried forward and that the part relevant to works will be moved to a new regulation under the Works section.
Plugs, Connectors and Socket outlets
Plugs, connectors and socket outlets need to be able to be used in a safe manner. One way of achieving this is to ensure that they are appropriate for New Zealand conditions and are of a consistent form. Regulation 74, which controls the properties of plugs, connectors and sockets, is a mandatory requirement in the existing Electricity Regulations. It is proposed to carry forward the intent of this regulation but with amendments to recognise that extra amperes are now available and the new AS/NZS 3000:2007.
Connectable installations
Connectable installations4 such as caravans and recreational vehicles are recognised as posing a higher risk from both electric shock and fire, and as a consequence these installations are subject to additional safety provisions, such as ongoing safety re-verification.5
There is concern that some imported connectable installations contain wiring systems and appliances not designed to the New Zealand electricity system. For instance, fittings may be designed to operate at 110 volts, 60 Hz for the American or Japanese markets. This therefore creates a safety risk and the nature of connectable installations, such as confined conditions, expanses of conductive materials, use of the vehicle as sleeping accommodation, means that the electrical hazard is more extreme.
An additional problem with these imported installations is that conversion to 230 volts may be deficient to ensure safety. Therefore, it is proposed the regulations provide that to be acceptable as a safe installation, the caravan or recreational vehicle must demonstrate (by way of third party inspection) that it is designed, constructed, and installed in accordance with the new general electrical safety regulation, AS/NZS 3000 and AS/NZS 3001. It is also proposed that all the appliances that form part of the connectable installation must comply with AS/NZS 3820 and the declared article and supplier declaration regulations.
Appliances
The safety of electrical appliances is important due to their common use in everyday life. The Electricity Regulations currently require high risk appliances (declared articles) to obtain approval from the Chief Executive before their placement on the New Zealand market.
The Ministry has become aware that there are increasing problems with compliance, due in part to difficulties suppliers have in understanding the regulatory requirements for appliances. Accordingly, it is proposed that the regulatory requirements for appliances be enhanced to reflect industry and regulator concerns regarding clarity and enforcement capability.
It is proposed that the regulations provide for a performance based regime but be underpinned by a more analytical application of risk management techniques and the adoption of international Standards. The proposals reflect New Zealand's World Trade Organisation Technical Barriers to Trade (WTO-TBT) commitments.
The following table outlines the proposed regime. It is based on two mechanisms for indicating safety of appliances:
- Compliance with recognised Standards; or
- Compliance with general safety requirements. This includes using non-standard practices or alternative Standards. This route will require a higher level of evidence of compliance than the recognised Standard route.
The proposed base document for the regime is the Supplier Declaration of Compliance (SDoC). It is proposed that the SDoC is a statement by the supplier that the product they are supplying into New Zealand is safe and that the supplier accepts responsibility for the safety of that product. It is proposed that the SDoC must be in accordance with ISO/IEC 17050 and must include a statement of the quality control system applied
Risk Level
|
SDoC to Applicable Recognised Standard (including mandatory technical requirements) |
SDoC to General Safety Regulation
(including mandatory technical requirements) |
| High |
Module 3 |
Module 4 |
| Medium |
Module 2 |
Module 3 |
| Low |
Module 1 |
Module 2 |
Module 1
- SDoC with applicable recognised standard
Module 2
- SDoC; and
- Test Report (Conformity Assessment Body (CAB) accreditation not mandatory).
Module 3
- SDoC; and
- approval by regulator; or
- certification from JAS-ANZ accredited CAB; or
- certification pursuant to Government MRA (mutual recognition arrangement).
Module 4
- SDoC; and
- documented quality assurance of manufacture by surveillance (market, factory inspection, production process etc); and
- certification from JAS-ANZ accredited CAB; or
- certification pursuant to Government MRA (mutual recognition arrangement).
It is proposed that documentation to support the SDoC must be made available on the demand of the regulator within 10 working days.
It is proposed that categorisation of products to risk categories will be made by Gazette Notice.
Additionally, it is proposed that the Chief Executive may, by notice in the Gazette:
- prescribe the requirements to be met for labelling or marking of appliances;
- prescribe the requirements to be met for the security and availability of declarations of compliance, test reports, certificates and other associated documentation;
- require that documentation be submitted to the Chief Executive through a website;
- recognise an organisation, agency, or regime of compliance (such as JAS-ANZ or IANZ);
- prescribe the form of declaration of compliance.
Currently, the Chief Executive may, in regard to any approval impose conditions on the approval, revoke the approval within 7 days in writing or vary, revoke or add conditions to the approval within 7 days in writing. In some circumstances, it is desirable for the imposition of conditions or revocation of an approval to take immediate effect. It is proposed that the Chief Executive is required to Gazette any variation to the approval but that these can have immediate effect.
Question
Do you agree with the proposed new structure for appliance regulation?
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