Supervision, Testing, Inspection and Certification
Supervision
The Electricity Act provides for work, within the limits prescribed in regulations, to be done under supervision. This exemption allows prescribed work to be undertaken by a trainee provided the certification is by a licensed electrical worker or a person automatically licensed. It is consistent with the approach taken in the Building Act. In line with the new definition of prescribed electrical work under the Electricity Act, supervision is now prescribed electrical work.
It is accordingly proposed to carry forward to the new regulations a regulation equivalent to existing Regulation 23.
As noted, it is proposed to extend the definition of prescribed electrical work to cover testing, certification, inspection or supervision where specifically required by the regulations. This proposed supervision regulation will fall into this category.
Testing
Testing is necessary to ensure that electrical work has been completed safely and that the work will be left in a safe condition.
It is proposed that the regulations continue to require periodic testing of high voltage electrical installations, construction sites, and connectable installations (equivalent to Regulations 46 and 97) and testing after an electrician has completed work on wiring or appliances (equivalent to Regulation 37).
As noted, it is proposed to extend the definition of prescribed electrical work to cover testing, certification, inspection or supervision where specifically required by the regulations. These proposed testing regulations will fall into this category.
It is proposed not to include in the new regulations the periodic testing for equipment that is hired, used in schools, and where the connection is plug and socket. Currently, persons testing such equipment are expected to be competent and undertake a half-day course in using special testing equipment. Whilst these people need a certain level of competence, the skill needed is not extensive or complex. This arrangement has been developed through the consensus Standards process and is widely followed within industry. Those who currently do this work will still be able to do so as long as they meet these competency requirements.
Inspection
Higher risk electrical work must be inspected by a third party, particularly work on the main switchboard, the main cable and the main earth. Inspection should be carried out by an inspector. Any such inspections need to be done by persons who are competent to do inspections. Such inspections require a degree of competence beyond that necessary for most electrical work.
It is proposed the new regulations continue the provision that a worker cannot inspect their own work and carry forward provisions equivalent to Regulations 41 and 42.
As noted, it is proposed to extend the definition of prescribed electrical work to cover testing, certification, inspection or supervision where specifically required by the regulations. These proposed inspection regulations will fall into this category.
There is some confusion over whether inspectors should be required to test certain work by licensed electrical workers according to Section 4 (testing) of NZS 3019 as well as Section 3. It is the intention of the inspection regime that inspectors only verify the high risk components of prescribed electrical work, not for inspectors to test self-certified work by licensed workers.
Certification
Certification is a means of verifying safety. Note that certification is not periodic inspection.
Currently, only certain prescribed electrical work requires a Certificate of Compliance (CoC) to be completed to detail that certain safety checks have been carried out. A CoC achieves safety outcomes, accountability and is a statutory requirement. There are two forms of certification: a CoC can be issued by the electrician who did the work (self-certification) or, for more hazardous work, such as high voltage electrical installations, only an electrical inspector must also certify the work.
Existing Regulations 39-43, which outline this distinction, are very difficult to follow. It is proposed to carry forward the equivalent of these regulations but to clarify this process. It is proposed that no additions be made to these regulations, and amendments will only be for clarification.
Major Prescribed Electrical Work and Self-Certification
Regulation 43A outlines the steps to be taken when a person connects or reconnects an electrical installation to a supply of electricity when either prescribed electrical work has been carried out or which has been disconnected for 6 months or more. These steps are verifying the:
- safety of mains (if overhead);
- polarity of mains;
- adequacy of rating of protection; and
- presence of MEN earth.
However, persons doing major prescribed electrical work for a CoC which doesn't require inspection are not currently required to verify general safety of the installation.
A recent survey on wiring by Energy Safety revealed that although installation prescribed electrical work had been carried out, there was in fact no MEN earth on the installation. To ensure that verification is done and for consistency of required work, it is proposed to add to Regulation 43A that people who undertake major prescribed electrical work and self-certify should be required to verify that the main earthing systems and the mains protection system is correctly rated. This verification could be achieved by including a statement of verification on the CoC.
Periodic Inspection
The Electricity Regulations at Regulation 46 provide for periodic inspection of installations and appliances where the risk of public harm is greater than normal. All owners of electrical fittings must ensure that those fittings have a warrant of electrical fitness certificate resulting from a periodic inspection. The inspections are carried out only by inspectors. The warrant of electrical fitness certificate is issued to indicate compliance with the general safety requirement and any mandatory technical requirements.
It is proposed that the existing group of electrical fittings subject to periodic inspection, such as caravans, animal stunning and hazardous areas continues.
It is also proposed that the periodic inspection regime covers other areas where the risk of public harm is higher than normal, such as schools, rest homes and public swimming pools with respect to appliances in common spaces. The proposed additional inspection requirements, however, would not apply to appliances owned by rest home residents.
At present, the interval for periodic inspection can range from 1 year for carnivals, fair grounds and animal stunning appliances to 5 years for caravan parks. We have been unable to identify a clear reason for the range of intervals, and therefore invite feedback on whether intervals should be standardised and if so, what would an appropriate interval period be?
Questions
Do you agree with the proposed additional inclusions for periodic inspection?
Do you agree with the current intervals for periodic inspection?
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