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Monday 22nd April 2013
Jim Wallace finds that the new IET Code of Practice for maintaining the safety of electrical equipment will require a more robust approach to risk assessment
22 April 2013
A renewed emphasis on risk-based approaches to electrical safety at work is likely to pose a significant challenge for FMs responsible as health and safety duty holders, and also those carrying out electrical testing.
The revised IET Code of Practice for In-Service Inspection and Testing of Electrical Equipment is essentially the third step in a process that started with the publication of the Löfstedt Review on health and safety. This process continued with the HSE's revised guidance on maintaining portable electrical equipment in low-risk environments.
In all cases, concern was expressed that the implied legal requirement for maintaining the safety of electrical appliances was being applied too broadly and disproportionately, resulting in situations of over-compliance, particularly in more benign working environments.
The IET Code of Practice is now in its fourth edition. It focuses on the importance of taking a proportionate response to ensure that all workplace electrical systems should be maintained to prevent danger, so far as is reasonably practicable and in line with the requirements of the Electricity at Work Regulations 1989.
To do this, it says that electrical equipment inspection and testing regimes should be based on a more structured and robust approach to assessing the safety risks posed by appliances.
Importantly, the code's emphasis on risk assessment is completely consistent with the existing legal requirements of the Management of Health and Safety at Work Regulations 1999.
Regulation Three of the regulation requires all employers and self-employed persons to assess the risks to workers and others who may be affected by their undertaking. Employers with five or more employees should also record the significant findings of that assessment.
The implication is that only when the risk of using electrical equipment has been assessed
and understood can it be managed through a programme of inspection and testing.
In fact, the code has always advised that the frequency of inspections and testing should be reviewed on a regular basis, after an assessment of the risks associated with the use of a particular appliance. Greater prominence is given to this approach, which also emphasises that risk-based assessments are the responsibility of the duty holder, but that a duty holder may enlist the services of a competent person, such as an outside PAT company, to assist in this process.
The factors of risk
To comply with the new guidance, duty holders need to understand that risk encompasses many factors that can eventually influence a final decision.
With electrical equipment, this should include a full consideration of the environment in which the equipment is being used, the level of user awareness, the equipment construction and type, frequency of use, previous records and type of installation for fixed appliances.
Consideration of all of these factors should culminate in an informed decision being made on the frequency of any inspections and tests required.
To further reflect the new emphasis on assessment of risk, the IET also stresses that its own widely-used table on test intervals included in the code should be used only as a guide to the initial frequencies of inspection and testing. Future and continuing inspection and test intervals should depend on ongoing risk-based assessments, with periods being increased, decreased or kept the same, as appropriate.
Duty holders have a legal responsibility to ensure that the electrical equipment in their charge is safe and it is their responsibility to decide whether or not to vary the inspection and test frequencies. However, in doing so, the new advice makes it clear that duty holders can, if necessary, take advice from the person doing the inspection and testing.
Also, in a significant change to existing practices, it is also now recommended that the date for re-testing should not be marked on the pass label attached to an electrical item. Instead, it is advised that the duty holder should determine the date for the next inspection and/or tests on a risk-assessment basis and record this on their 'Equipment formal visual and combined inspection test record'. This, again, is a change in emphasis and is likely to place even greater importance on the management of effective test and maintenance records.
Testing saves lives
Over many years, there is indisputable evidence that the periodic in-service testing of electrical equipment has prevented injuries, saved lives and avoided workplace fires that would otherwise have been devastating for those involved. This has not changed.
However, in certain situations, an over-zealous approach to testing has led to costly over-compliance with the regulations.
The new emphasis on risk assessment is designed to overcome this. In clarifying the responsibilities of FM duty holders, the code will help to ensure that those involved in maintaining electrical safety make more informed decisions on the scope of inspection and testing, tailored to suit their own circumstances.