• Rob McAulay
    We have a building that is fully RCD'd and I have been advised that because of this we no longer need to test and tag plug in tools and appliances. I would appreciate any guidance on this question. Thanks
  • Steve H
    Functional, correctly wired RCDs "should" prevent an unlucky soul from becoming the dearly departed in most circumstances Rob, however there are at least four possible scenarios where even if the RCD trips at its rated leakage current within the time limit, they will receive a zap that proves lethal.

    The Electrical (Safety) Regs don't "require" items to be tested & tagged, but a current tag indicating an item has been inspected and tested IAW AS/NZS3760 is a method to get to "deemed safe", a history of test results provides evidence of an items safety over the period of time an item has been the subject of regular testing.

    There are some obvious limitations of TnT, it depends on the skill, training, knowledge, equipment and enthusiasm of the person performing the inspection and tests. It is a snapshot of how something is at the time it was tested, I've TnT'ed a tool in a builders shed one afternoon, gone back to finish off the following morning and found that tool back in the rack with a damaged lead and my tag removed.

    I would suggest that your installation RCDs are tested annually and their correct operation confirmed, depending on the nature of your work and the use tools and other electrical equipment are put to, and the environment these items are used in, possibly look at longer retest intervals. This assessment should ideally be documented for future reference.
  • Steve H
    One thing my reply above neglected Rob, under AS/NZS3760 safety features fitted by an item's maker must be present, unmodified and functional for the item to be visually assessed as "safe to use", this part of the test & tag regime is something that in my experience sparkies typically ignore.

    How will your proposed alternative address this? Typical visual fails are guards missing or modified to reduce their effectiveness, Things like trigger release buttons on circular saws missing and replaced with a metal screw
  • Steve H
    On the subject of switchboard RCDs, Daylight Saving starts this weekend,along with testing that your smoke alarms are working, checking that your RCDs protecting outlets will trip when you push their test buttons falls into the good idea category.

    This "test" won't tell you if it's tripping within the correct time limit, but if you plug a light into the outlet each tripped RCD is protecting, it will give you an indication that it is functional.

    Why "test trip" RCDs? Because these items have power on contacts, there can be a galvanic reaction that causes these contacts to stick to each other and not disconnect cleanly/or at all, if the RCD is tripped, either by test or a current leakage issue
  • Rob McAulay
    Thanks Steve, I am having a discussion with a facility manager who has been advised by the electrical Engineer that because the whole building is RCD'd then individual equipment that is plugged into the building does not require TnT, I just wanted to check this as my knowledge in this field isn't enough to question this assumption and I feel the TnT is just and another "reasonably practical step" we can take to help manage electrical safety of our staff and students.
  • Matt Sadgrove
    Rob, have asked around work and the general consensus is the tools and appliances should still be tested and tagged.
  • Janene Magson
    I have come across this where I currently work too - not the RDC bit but that our Facilities/ Property management team are of the opinion that because it is not regulated, it is not needed......We have also tried informing them that testing at least gives an indication, if something were to happen, of a timeline from when something could have gone wrong and also in the HSWA Act 2015 Article 36 that
    " A PCBU must ensure, so far as is reasonably practicable, the health and safety of—
    (a) workers who work for the PCBU, while the workers are at work in the business or undertaking; and"

    This has not convinced them as yet - a document has been drawn up by me to present to the HSSG - but nothing has come of that either......
  • Steve H
    My take, FWIW, Electrical Appliance Safety is a tripod, supplying appliances via a "regularly tested RCD" type A is one leg, Competent test & tag of appliances should confirm that tagged appliances comply with NZ Electrical Safety requirements and are "safe" to use at that point is the second leg, regular "documented" user checks are the third leg.

    The legal obligation to do "something" is created by Regulation 15 of the Electrical (Safety) Regulations:
    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. .

    Regulation 26 describes some ways that this obligation can be discharged by the person responsible for an electrical installation, or hired or rental equipment,

    26 When fittings and appliances in use deemed to be electrically safe

    (1)This regulation applies to a fitting or appliance, other than an electrical medical device, that is in
    use, or available for use,—
    (a) by an employee or contractor of the owner of the fitting or appliance; or
    (b) by a hirer or lessee under a hire or lease agreement with the owner of the fitting or appliance; or
    (c) by the occupier of premises that are rented or leased from the owner of the fitting or appliance.

    I would suggest reading the whole of Reg 26, and not just extracting the portions of it that suit your position.
  • robert p
    got to pile in on the 'not needed' team and go further - it creates a false sense of security like a W.O.F. PCBU are also expected to train people for the risks they're exposed to, a regular check of cords that are run out and walked over is much more convincing than a tag on a monitor that is Never moved. remember that part of reasonably practicable is essentially a proportionality test - understand the risk rather than one size fits all tick and flick
  • Steve H
    In your electrical safety model Rob, how do you detect the item that your managing director saw in the US or China at a trade show and thought "gee that would be a useful thing for the troops to use", brought one (or more home) cut off the plug the item's maker fitted to it and replaced it with an A/NZ plug? The item in question is rated at 110V.****

    The popular assumption with Electrical Safety is that it's wholly and solely concerned with stopping an individual getting zapped, lethally or otherwise. That is a part of it, but it is just as much concerned with a dodgy item not causing an issue with the electrical installation or the grid in the event of a major issue. So it's detecting things that could cause a fire, are missing guards and safety features, aren't compliant with NZ electrical requirements

    **** Have encountered this with a steel reinforcing manufacturer who brought in a bunch of benders and cutters, also struck something that might be a little more in your comfort zone. An office for a US based equipment maker that used computer equipment sent to them from the US parent office, these items all had 110V IEC leads that they were connecting via a travel adaptor. This is a bad thing, but what was worse, a Registered Electrician had fitted pass tags to these. So two issues, wrongly rated lead, connected with a non compliant plug- potential risk of catching fire.

    In the case of the benders, sorry these don't comply, with the computer equipment, the issue was the leads/plugs, so the competent fix was to replace all the 110V IEC leads with 240V ones (after confirming that the item it was connecting was rated at 110-240V (NZ nominal voltage 230V so good to go with suitable lead)
  • robert p
    there's duties in the HSWA to deal with importers of equipment for workplaces Steve, I'm picking a CE that is that careless isn't getting T&T done anyways. Using the extreme examples to justify mindless tick and flick doesn't hold in my electrical safety model. The driver who swaps her illegal rims and rubber to get the WOF doesn't justify everyone having to have a WOF it underlines the futility of it.
  • Steve H
    Funnily enough, we went through their manufacturing plant every six months, Aussie owned company, so H&S/test & tag/PPE stitched into their DNA. Yes there are specific requirements in the HSWA for importers/suppliers of equipment, but from experience, largely ignored by many, especially someone on their computer searching Temu or Aliexpress etc who sees what they perceive as a "bargain".

    Take portable RCDs as an example, the HPM little orange RCD box sold in NZ complies with our electrical requirements for these items to contain a Type A RCD, these can cope with AC that has (possibly) a DC component, so cheap RCD boxes from Aussie or Asia won't have the correct RCD to cope with our situation. The New Zealand Regulator requires Type A's because we have the High Voltage DC link for the grid from Benmore to Haywards, and the theory is remnants of this could be present in the reconverted AC from Haywards on.

    The Fire Evacuation regulations also impose a responsibility to maintain electrical appliances in a safe condition
  • Nancy Robbie
    unfortunately I have come up against similar responses but on different H&S issues. Trying to convince management/directors that, although that point is not written in law, not following best practice with no feasible alternative is in effect still contraventing the HSWA, is difficult.
  • robert p
    are you a test & tagger yourself Steve?
  • Steve H
    I was Rob, my wife and I were the first Jim's Test & Tag franchisees in Christchurch back in 2009, we operated under the JTT banner for the ten year contract we had with them, and then ran our business as an indi operation, At that point we expanded into Thermal Imaging along with being a test & tag service provider, I was also a contract Test & Tag Trainer for a couple of years.

    My intro to T&T occurred when i took over managing a plastic recycling plant with a HQ in Aussie, I'd only had my butt in the chair for a week or so when i got a call from their Sydney based H&S manager asking me where my Test & Tag results were, fobbed him off with the newbie speech. Duly asked the Office Manager and she looked at me blankly and suggested calling the Electricians that handled our plant's break downs, boss there said 'mate if you want to know when we last tagged your stuff, get off the phone and have a look at our tags, or go back through our invoices"- couldn't see either of these options calming the bloke in Sydney down, so I wound up breaking out my test gear and brought some tags and a log book.

    Few years down the track and both me and "Mrs Jim", as she became affectionately known, needed jobs and we decided that after fifteen years of running businesses for others, we should do something for ourselves, Test & Tag ticked a number boxes (LOL) We wound up having to sell up when I was diagnosed with terminal rust in 2019.
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