• Steve H
    43
    For the last 10 or so years, I've run a mobile test and tag business in Christchurch, as first under Jim's Test and Tag, lately under our own business name Port Appliance Test and Tag, over the years I've developed a fair amount of expertise the standards and regulations that swirl around TnT, some time ago Safeguard did a feature piece which I helped fill in some of the gaps ( A Live Issue ) since that was printed, what's changed?

    From my perspective, not a lot, things are still getting "pass tags" put on them that shouldn't pass (see my little shop of test and tag horrors) the scary thing is, the folk getting this wrong aren't all from a tick and flick "competent person" course, they're a mixture of CPs and "qualified folk", who seem to barely understand what it is that they are there to do. Some of the "CP's" are part of franchise groups, none from Jim's TT that I've seen, probably due to the extensive in house training course that JTT run for their Franchisees and the in group support that is part of the deal- but the rest,hmm.....

    I think that in part this is down to Test and Tag training companies not having a Code Of Practice that they have to adhere to, I spend two days per month running test and tag training courses in Christchurch.I know we do a reasonable job in the time we have available, and a common comment from anyone who has done a TnT Competent Person Course with another provider, is that we cover way more than other ones do, we try to cover what the test and tag standard AS/NZS 3760 states is the body of knowledge required to test and tag competently and safely,it would be nice to have a little more time to do that, but we have to follow the market on length.

    Another part of the issue is a lack of NZQA Standards that could be used to ensure that all are operating from the same page, I envisage a generic "Test and Tag to 3760 requirements" paper, and a "Test and Tag to 3102" extension paper for building site test and tag, along with pulling in a standard electrical NZQA paper covering basic safety while working with electricity. I see this evolving into a "test and tag" qualification in its own right, able to be completed by anyone, but subject to some external scrutiny (maybe from the EWRB) that would put a stop to the tick and flick brigade by either having to prepare their trainees for an externally assessed competency test, or at least having some external oversight on their training activities. Having two test and tag unit standards that could be pulled into various classes of electrical registration would help lift the qualified folks game.

    Anyway, that's my two cents worth- what are your thoughts? Do you have any questions about test and tag?
  • Steve H
    43
    AS/NZS 3012:2019 Electrical Installations- Construction and Demolition Sites
    Over year ago, the joint standard for electrical work on construction and demolition sites went into review, I hope everyone who has some interest in this standard put in a submission on changes they'd like to see, hope they got their wish, Standards New Zealand released AS/NZS 3012:2019 last week.
    A quick look through,shows there have been some tweaks around PSOAs (RCD protected Portable Socket Outlet Assemblies). The standard has caught up with the requirement laid out in AS/NZS3000 that all Residual Current Devices used for personal protection in New Zealand shall be Type A. (we cover why in the C&D testing appendix that I add to the Test & Tag Courses that I run).
    A small title change, Table 3 Periodic Verification Intervals in the 2010 becomes Table 6 in the 2019 version- but there is no change in the retest intervals portable equipment of three months for (wish I had a dollar for everyone who told me they were going to six months).
    There isn't any change in the requirement (in order to comply with this standard) of the requirement to keep a register of all equipment, a record of all inspections and tests, a repair register and a record of all faulty equipment- Clause 3.10 in 2010 goes to 3.9 in the 2019 version. So just buying the cheapest PAT on the market, and putting stickers on items, isn't necessarily going to get you to "deemed safe" under Electrical Safety regulation 25 D,unless you've taken the time to record those details.
  • Steve H
    43
    I've had a bit of skim through the new version of AS/NZS3012, and covered what changes I've noted so far in the blog I maintain on our website, you can read those here
    l1173zaf2oqu1e7t.jpg
    Buy a copy of the new standard from Standards New Zealand
  • Steve H
    43
    Haven't updated this for a while, thought it was time now that I've pulled the pin on working for a living :smile:

    Visual Inspections When Test and Tagging (Extension Leads, IEC Leads)

    First disconnect and remove the plug end from the socket outlet (if it's plugged into one), if you do the visual checks in the order I've listed them, you'll find any issues and get through a pile of leads really quickly- if a lead "Fails" any of these, Danger Do Not Use tag and next please. Don't assume that the person who put a pass tag on a previously tagged lead, actually knew what they were doing- frequently taggers both of the electrically qualified or The Competent Person persuasion don't know this stuff

    (1) Check that the safety features fitted to the plug and socket are present and unmodified (yes
    Gladys, it's a Fail if the shroud is missing/damaged on the socket, or the insulation on the shank of
    the Active and Neutral pins of the plug is damaged missing, any signs of overheating/over loading.
    Are the grommet/strain relief devices fitted to plug and connector ok, shake the plug and connector, are there any sounds that indicate conductor terminations may be loose?)

    (2) Does the current rating of the plug match or exceed the current rating of the socket connector ? (sorry Bob,fitting a 15A Socket to a 10A plug is also a Fail- unless there is a 10A MCB
    limiting the load carried by the plug to 10 Amps, filing down the Earth pin on a 15 Amp Plug so
    it's fits a 10 Amp outlet is also a cause for celebrating by sticking a Fail Tag on the item)

    (3) Is the lead rated for use at 230V? (Give a ways that it isn't are weird plugs/sockets Doris)

    (4) Are the plug and socket fitted to the lead compliant with AS/NZS3112? (Insulated pins, a
    safety skirt on the socket connector are clues to look for here Fred, if the lead exits from the top
    side, it's a domestic Chinese plug and N/C for NZ Use, we also want confirm that if the lead has a
    3 pin plug and a 3 pin socket connector, that the lead has three cores, a 2 core lead would fail as
    would having a two pin plug supplying a 3 pin connector)

    (5) Ok, now we want want to visually examine the entire length of the lead from the plug to the socket connector (do one of Test & Tag Training's courses and you'll find out how to do this quickly and
    effectively-but we're looking for any exposed conductors, banding tape covering damaged
    insulation, or heat shrink tubing- HS isn't a compliant repair. The outer layer of insulation will
    frequently pull out of the plug top exposing the underlying conductors, if there is only one layer of continuous insulation, it's a Fail even if it's covered with tape or HS. Is ya head spinning yet
    Harry?)

    Having completed a thorough visual examination to the requirements of AS/NZS3760, we now perform the required electrical tests. It's important to note that your PAT machine DOES NOT DO VISUAL CHECKS That's up to the person doing the testing, are you getting the picture that there is actually quite a bit to this testing and tagging caper yet? Also important to note, where an appliance has a detachable lead, the lead gets tested as a lead and gets it's own tag, then the appliance gets tested as an appliance connected by that lead. Typically, this is where electricians go wrong, they'll test something, god knows what and how, and then stick a tag on the lead telling the world it's a "computer". Same deal with laptop chargers, lead first, then power supply connected to your PAT machine as an appliance, tag on lead, tag on power supply.

    fkg7jjbfa6tiezws.jpg

    2sdxuwv6xu1l7bgc.jpg

    ojaiufwab3z9cj1h.jpg

    n2qgbgteu6cbl6gz.jpg
  • Steve H
    43
    Guess you have a number of questions about the above, hopefully, you are coming to the conclusion that it's not (or at least shouldn't) be some random Tom, Dick or Harry, giving a lead a bit of a look and then, hooking it up to their PAT machine and slapping a pass tag on.

    (1) Safety Features- why do these have to be present, unmodified and undamaged to pass any
    item when testing and tagging to the requirements of AS/NZS 3760:2010? To gain deemed safe
    status the responsible person on the site we are testing items at, has decided to comply with the
    recommendation that Electrical (Safety) Regulation 26 provides. To pass a 3760 lead test,, we
    follow the guidance of clause 2.3.2 Inspection and perform the checks listed there (time to buy
    that copy of AS/NZS 3760:2010 from Standards NZ $82 +GST for a PDF license to print two copies,
    absolutely necessary for your Competent Person to have a copy with them at all times when
    testing ) FYI Insulated plug pins and skirts on socket connectors were required on new leads and
    appliances sold after March 2006.

    (2) Does the current rating of the plug match or exceed the current rating of the socket connector ? This is to comply with Electrical (Safety) Regulation 23
    An appliance is deemed to be electrically
    unsafe if the appliance is fitted with a plug of a
    rating less than the rating specified on the
    rating plate

    This means a lead with a 10 Amp plug and a 15 Amp socket connector is an illegal device as it
    has to be regarded as unsafe, likewise an item that draws more than 10Amps must have a plug
    of a suitable rating (15Amp, 20Amp 32Amp. It's scary the number of electrically "qualified"
    taggers who will happily put their name and PL number on a Pass tag. This is one of the
    regulations that Worksafe don't seem to be aware of, or prepared to enforce

    (3) Is the lead rated for use at 230V?Nominal Voltage:Electricity throughout New Zealand is
    supplied at a nominal voltage of 230 volts and frequency of 50 hertz.
    Electrical (Safety) Regulations- Interpretations:
    standard low voltage means,—
    (a) in respect of electricity supplied by either a single-phase MEN system or a multiple-phase
    MEN system, a nominal voltage of 230 volts AC between phase and neutral;

    4) Are the plug and socket fitted to the lead compliant with AS/NZS3112? Wiring installations in
    New Zealand have to comply with AS/NZS 3000:2007 Clause 4.4 specifies that socket outlets
    shall comply (mandatory statement from a Standard cited in legislation. with either AS/NZS3112,
    AS/NZS3123, IEC 60309, or AS/NZS3131, in practice most outlets taggers encounter will be ones
    that comply with AS/NZS3112 for single phase leads and appliances.

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    wzb2uk4il3o3p1hs.jpg

    3wp62urthk72p3kq.jpg
    Attachment
    IMG20181113104152 (187K)
  • Steve H
    43
    Essential PPE For Test & Taggers

    If you,or anyone whose life you are responsible for tests and tags electrical appliances and leads, do yourself (and them) and obtain one of these.
    2pv1zaenoz49hp8b.jpg

    It's a 10mA Type1 Inline RCD, plug this into the nearest outlet to the spot you/they are testing at, and plug your PAT into it. In the event that you,or the test probe on the PAT into exposed live metal on the item under test, it will trip when 10 mA of current inbalance is detected, as opposed to the more usual Type 2 RCD which trips when it detects 30mA of current inbalance. Unlike a lot of things in this life, where electrical current flowing through you is concerned- less is best

    gl3ak5km8peyf4m0.jpg

    Can't buy these off the shelf, you'll need to get your friendly "qualified electrical worker" to make one up for you.

    Thin gloves are also good precaution when handling items that punters have sneezed and wheezed over, or in the case of plumbers, drainage contractors and civil engineering workers may have been in contact with ...................????
  • Steve H
    43
    Competent Person Requirements

    Under AS/NZS3760, the onus is on the person responsible for a site and it's electrical installation/appliances to ensure the Competent Person has the skills, experience and knowledge listed in Clause 1.4.4 correctly, safely and to the jurisdictional requirements that apply in the location items are being tested at.

    Appendix B is provided to give the Responsible Person guidance on the body of knowledge that the Competent Person is required to have.

    It's fairly extensive, and more than can be covered in a course lasting a day or less, if you are using either an in house CP,, a test & tag service provider or a Registered Electrical Worker, you still could carry the can if they get it wrong.

    So what should an RP do?
    Get a copy of AS/NZS 3760 (and 3012 for building sites)
    Ask to see evidence that they have had some training (duration, on line or in person)
    Ask to see their copy of AS/NZS 3760
    Ask for a copy of their Public Liability Insurance
    Ask what test gear they will be using and evidence that it's calibration has be checked within the last 12
    months.
    Ask for evidence of their experience performing Test & Tag to AS/NZS 3760 requirements
    Ask to see what reports they will provide post testing (the RP's problem for DIY TnT)
  • Steve H
    43
    If I Have A Portable Appliance Tester, Do I Need A 230v AC Power Supply?

    Like so much in this life, it all depends. Some electrical items can be safely tested using the internal power supply (battery) of a PAT, these are items such as extension leads, EPODs/PSOAs, and appliances with mechanical switches that when turned on, expose all internal circuits to the 500V test voltage that a PAT uses to check the item under test Insulation Resistance. However, if an item has some form of electronic switching, or a stop/start button that energizes a contactor, then a Leakage Current test must be performed, which will require the PAT to be connected to an earthed 230v supply, so a "Run" test can be performed and the PAT can measure any current leakage the device under test has and from that, infer the Insulation Resistance of that item.

    Note, to test an item with such switching, a Current Leakage Test is mandatory to test in compliance with AS/NZS 3760:2010.

    I have used a degree of techno speak above, if you don't understand it, you are not competent to test electrical appliances
  • Peter Bateman
    188
    I have used a degree of techno speak above, if you don't understand it, you are not competent to test electrical appliancesSteve H

    OK I admit it. I don't fully understand it. I promise never to attempt to test an electrical appliance. But I always switch the toaster off at the wall before attempting to extricate jammed toast with wooden tongs.
  • Michael Parker
    1
    Some horrors there alright
  • John CW
    1
    Do phone chargers i.e. the little (typically white) blocks that transform 240v ac to 5v dc (USB lead) need to be tested/tagged?
  • Steve H
    43
    OK I admit it. I don't fully understand itPeter Bateman

    That is the view of the opponents to test & tag Peter, and they'll proclaim that frequently, folk performing test and tag, don't fully understand what what's required, how appliances are constructed, how fuses etc operate and why they are there to protect the installation, not appliances connected to that installation, and that because of those short comings, TnT is a waste of time and money ,

    AS/NZS 3760 lays out the body of knowledge "anyone" conducting testing to that standard should possess, it's quite extensive and impossible to adequately cover in a few hours as a part of a TnT Course. Even Electrical workers only briefly cover what's required, but they do have the advantage of a more in depth knowledge of the installation side of things.

    So does this mean the view that Test & Tag should be dumped is correct? I don't believe so, I think that there are three essential components to any businesses electrical safety regime.
      [(1)] Test & Tag to AS/NZS 3760 by a "competent", fully trained person using appropriate test
      equipment that records tests conducted and the values/results of those tests that are retained.

      [(2)] Where possible RCDs are fitted to all circuits supplying socket outlets in any wiring installation.

      [(3)] Users of electrical appliances perform regular checks of the appliances they use, and
      document that this has been done and the result of these checks.
    This probably sounds a little OTT, but given there's a fire every week in a New Zealand business, it's justified from that point of view, and while deaths as a result of being zapped by a dodgy appliance are relatively few, as the vast majority of electric shocks that workers receive go unreported, it's likely that any caused as a consequence of getting a zap that isn't immediately fatal aren't either.

    So how do we sort this out? My first post in this thread gives you my take on what needs to happen. ..
  • Steve H
    43

    They are an electrical appliance John, frequently supplying items sourced from an overseas supplier and not fitted with plug pins that comply with Australian/New Zealand requirements. Or they've been damaged and may be unsafe, so I would say yes. But what gets tested, and under some circumstances the frequency of retests, is up to the Responsible Person

    Here's a link to how such chargers can be tested
  • MattD2
    152
    ...who seem to barely understand what it is that they are there to do.Steve H
    I think that there is the crux of the TnT issue.
    When the client sees it as a compliance requirement for their equipment to have tags, and the "CP" sees the purpose of their job as to make sure that electrical stuff has tags then there is always going to be a disconnect between the purpose of TnT and what gets done. After all if the client sees this as purely a compliance cost, why would they engage someone who is just going to increase that cost by making them service/replace some of their equipment?

    To be honest - Tag n Test is a good example where blind following of a blanket rule can actually cause more risk than it controls.
  • Steve H
    43
    After all if the client sees this as purely a compliance cost, why would they engage someone who is just going to increase that cost by making them service/replace some of their equipment?MattD2

    To ensure the electrical safety of appliances connected to their electrical installation as the Electrical Safety Regulations require Matt.

    15 Using works, installations, fittings, appliances, and associated equipment

    (1) A person who owns or operates works, installations, fittings,or appliances must not use, and must
    not allow any other person to use,
    the works, installations, fittings, or appliances if the works,
    installations, fittings, or appliances are electrically unsafe.

    There is no provision for mitigation in this regulation, such as supplying an item through a Residual Current Device (RCD).

    You are right about a possible disconnect where a company uses a staff member to blindly tag items, or they engage the services of a third party who doesn't know, or is trying to tag as many items as possible, as quickly as they can, or is concerned that if they fail too many things, or mission critical things, they won't be invited back to play.

    To try and address this disconnect, I have outlined right at the start of this thread how that might be done.
  • MattD2
    152
    5 Using works, installations, fittings, appliances, and associated equipment

    (1) A person who owns or operates works, installations, fittings,or appliances must not use, and must
    not allow any other person to use, the works, installations, fittings, or appliances if the works,
    installations, fittings, or appliances are electrically unsafe.
    Steve H

    Ahhhhh but the catch is that Reg26 about AS/NZS3760 tagging only states that an appliance with a current (legitimate) tag is electrically safe it does not say an appliance without one is is electrically unsafe. Given the gaps you have identified in the Test N Tag regime as it stands now, it is likely that if a person was electrocuted or received a serious electric shock from an appliance in a workplace the fact it was tagged would likely be of little significance to WorkSafe's prosecution.
    And so is it time to rethink what it means for something to be electrically safe/unsafe. I agree that Test n Tag can be a critical part of the management of electrical appliances, but it is only ever one part of wider electricity safety measures.

    In a recent post @Peter Bateman asked How to reduce 'safety clutter'? - getting ride of Regulation 26 of the Electricity (Safety) Regulations would be one of my nominations.
  • Craig Marriott
    180
    From Energy Safety https://www.worksafe.govt.nz/topic-and-industry/electricity/testing-and-tagging-electrical-appliances

    Testing and tagging electrical appliances is one useful way to check electrical equipment is safe.

    However, it's not mandatory. What is legally required is that equipment is electrically safe and maintained in a safe condition.

    Testing and tagging doesn't guarantee future electrical safety, what it does is provide a snapshot of how safe the appliance is at the time of testing.

    It is up to the person conducting the business or undertaking (PCBU) to decide whether to test and tag. They can either get the testing equipment and train up a worker, or hire a third-party to carry out the testing.
  • Steve H
    43
    it does not say an appliance without one is is electrically unsafe.MattD2

    It's interesting that Energy Safety's "advice" on Testing and Tagging, doesn't provide for any alternative way to get to "deemed safe" Matt, and discharge the obligation that Reg 15 imposes, and thus far no one else has either, but you are correct, the absence of a tag doesn't make the item "unsafe", but it does mean the "safety" of the item is unknown

    However, it's not mandatory. What is legally required is that equipment is electrically safe and maintained in a safe condition.Craig Marriott

    That's quite correct Craig, the same obligation on a PCBU is also put in place by The Health and Safety at Work Act 2015

    38 Duty of PCBU who manages or controls fixtures, fittings, or plant
    at workplaces


    (1) A PCBU who manages or controls fixtures, fittings, or plant at a
    workplace must, so far as is reasonably practicable, ensure that the
    fixtures, fittings, or plant are without risks to the health and safety of
    any person.

    What is “reasonably practicable” will depend on the degree of risk the worst possible outcome will occur and the resources available, if things have gone pear shaped, and you have a crispy critter decomposing on your workplace floor, following the get out of jail card afforded by following Reg 26 to get to "deemed safe", along with supplying via "electrically safe RCDs" and documented pre use checks by users before they use an item would make a successful Worksafe prosecution pretty unlikely. Of course, I think you would want to have a set of Test Results providing evidence the item had been correctly tested, and a test history of previous testing conducted, rather than just relying on a smudgy dog eared tag as your defence.

    It is up to the person conducting the business or undertaking (PCBU) to decide whether to test and tag. They can either get the testing equipment and train up a worker, or hire a third-party to carry out the testing.Craig Marriott

    Absolutely, the thing is, as I've outlined above, remarkably few are trained up comprehensively enough to correctly identify the appliance they are testing, any jurisdictional requirements that apply along with correctly performing the tests outlined in AS/NZS3760 (and 3012 for C&D sites)
  • Steve H
    43
    Are There Any Instances Where Testing And Tagging Is Required?

    As it happens, yes, there are two. If a Registered Electrical Worker repairs an appliance,then under E(S)R 90, if that repair could compromise the electrical safety of the item, they must test the item to the requirements of AS/NZS 5762 (in part using the testing methodology in AS/NZS3760) If the item is unsafe, they then must disable it IAW AS/NZS 4701 (this requires that they cut off the items lead where it exits the body of the appliance- so a plug cannot just be fitted to reinstate the device).

    The other mandatory requirement to test & tag an item is if a secondhand appliance is offered for sale NZ Electrical (Safety) Regulation 80 requires such electrical items to tested and tagged IAW
    AS/NZS 5761. There is quite a bit more assessment required under 5761, so if your "competent person" is testing items in this situation,you really do need to buy them a copy of that standard in addition to 3760
  • MattD2
    152
    It's interesting that Energy Safety's "advice" on Testing and Taagging, doesn't provide for any alternative way to get to "deemed safe" Matt, and discharge the obligation that Reg 15 imposes, and thus far no one else has either, but you are correct, the absence of a tag doesn't make the item "unsafe", but it does mean the "safety" of the item is unknownSteve H

    I think that is because the WorkSafe article is raising the point that just because something is tagged doesn't mean that they will take it as electrically safe in an investigation, and there is a lot of other points they would look at to determine if a company has manage an electrical risk SFARP 9including the points you have rasied about the competency of some of those in the TnT market). Agree that their inclusion that TnT is not mandatory is a bit of a red herring.

    following the get out of jail card afforded by following Reg 26 to get to "deemed safe"Steve H

    This is my point - if people are looking at TnT as a "get out of jail" then they will be focusing on that, doing the minimum to not get found guilty rather than actually managing the electricity safety risk they are responsible for.

    Are There Any Instances Where Testing And Tagging Is Required?Steve H

    As I understand it, Reg90 only requires the testing of appliance that has been worked on before releasing the item to another person, no need for tagging it. And Reg80 is relating to a different (but similar) testing regime, but is specifically a one of test and Tagged at the time the appliance is offered for sale - so protecting the seller liability rather than the user.
    So neither of those examples are really relating to the test and tagging we are talking about under AS/NZS 3760.
  • Steve H
    43
    As I understand it, Reg90 only requires the testing of appliance that has been worked on before releasing the item to another person, no need for tagging it. AMattD2

    Probably an idea to read the standard rather than relying on the view of others Matt, Reg 90 requires the item be tested to AS/NZS 5762, That standard under section 2.5 Action Resulting From Inspection and Testing, in clause 2.5.2 Compliant Equipment, says that a durable, non reusable, non metallic tag or other indicator shall be fitted. As reg 90 states that we have to follow 5762, we have to follow all the mandatory (shall, must etc)parts to comply with that requirement. 5762 provides an example tag which is an informative part, but 2.5 is a normative part, so our "tag"or indicator should have the date of test, the name of the company/person testing and wording to the effect that it has been tested to AS/NZS 5762 (it would be incorrect to use a 3760 tag- unless you altered 3760 to 5762)
  • MattD2
    152
    I was more referring to the regulation only specifying the testing, where as Reg80 specifies the requirements are to test, inspect and tag the appliance. Possible semantics but unless we have case law that clarifies that Reg90 intention was that the appliance is to be tagged then we can't really say for sure either way.
    Either way both these regulations are relating to the seller or repairer's obligations/liability to provide electrically safe appliances (a one-off obligation), rather than the owner's obligations to not use or allow to be used electrically unsafe appliances (an continuous obligation) - which is what we were originally discussing with regards to mandatory (or not) test and tag requirements in the regulations.
  • Steve H
    43
    but unless we have case law that clarifies that Reg90 intention was that the appliance is to be tagged then we can't really say for sure either way.MattD2

    That's a huge part of the whole issue Matt, we have an Electrical Regulator that isn't fit for purpose, it lacks the resources to get Regulations citing Standards updated to the latest versions, much less investigate instances of non compliance, or provide clear guidance on alternative solutions to safe outcomes that will comply with the various provisions of the regulations that it is responsible for .

    We are all agreed that testing & tagging to 3760 isn't mandatory, and no where above has it been argued that it is, the case i am trying to make is for improving the test & tag option. Unit Standards that anyone (Registered Electrical Worker or layman) must complete to test & tag to get to deemed safe under Reg 26 (and the instances in Reg 25 and Reg 80)
    I envisage a generic "Test and Tag to 3760 requirements" paper, and a "Test and Tag to 3102" extension paper for building site test and tag, along with pulling in a standard electrical NZQA paper covering basic safety while working with electricity. I see this evolving into a "test and tag" qualification in its own right, able to be completed by anyone, but subject to some external scrutiny (maybe from the EWRB) that would put a stop to the tick and flick brigade by either having to prepare their trainees for an externally assessed competency test, or at least having some external oversight on their training activities. Having two test and tag unit standards that could be pulled into various classes of electrical registration would help lift the qualified folks game.Steve H

    In this thread, I've tried to provide some background information to assist anyone choosing to use the pathway provided by Reg 26, to get the best outcome. Hopefully, anyone in that position will review their situation and take whatever steps needed to improve it.
  • MattD2
    152
    That's a huge part of the whole issue Matt, we have an Electrical Regulator that isn't fit for purpose, it lacks the resources to get Regulations citing Standards updated to the latest versions, much less investigate instances of non compliance, or provide clear guidance on alternative solutions to safe outcomes that will comply with the various provisions of the regulations that it is responsible for .Steve H

    But can the answer to bureaucratic failure ever be more bureaucracy (more regulations, NZQA standards, etc. for who can TnT)? You already rightly point out that the electricity regulator is stretched to regulate what is currently on their plate (and so is WorkSafe). Adding more can't help that.

    To be honest, I see a similar thing has happened with HSWA. We have had a "major" rewrite of our H&S legislation expected to be administrated by a still under-resourced regulator, and unsurprisingly little has really come of it. And that is because the rewrite is basically following the same format as the old legislation that was failing, which was definitely not help by a regulator that was trying to go back to what it knew - HSE (I personally found it infuriating when the WorkSafe mantra was all about identifying your critical risks that could kill or seriously harm and controls those, which was basically a regurgitation of HSE's significant hazards requirements and didn't actually follow the "risk based approach" the new legislation was apparently putting forward... but that's off topic, sorry)

    My suggestion is to actually clarify the electricity safety regulations by removing the term "electrically safe". This would remove the paradox where as per the regulation an appliance could be deemed to be electrically safe and electrically unsafe at the same time. And so the regulations would be focused on what is considered electrically unsafe, such as for the repair or sales regs - that an appliance is deemed electrically unsafe until tested as per the regulations.

    The approach to ensuring that appliances are not electrically unsafe (so far as reasonably practicable) would be better placed within an Approved Code of Practice, which can better detail the wider range of measures required (and is somewhat easier to update as/when required, rather than having to go through the parliamentary processes.

    And fair enough on the mandatory 3760 TnT never being claimed, I think I just got distracted by the "is there mandatory testing requirements" post.
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