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January 18, 2011

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Internal work environment – Power cuts

In hard times, most businesses trim budgets, but risks could build to a dangerous level if cut-backs cause delays in essential electrical safety work. Paul Caddick explores the scale of the risk and gives some advice on how to achieve compliance under financial restrictions.

As well as ensuring that periodic installation testing is conducted by a ‘competent person’, electrical safety compliance also requires the prompt remedy of certain identified faults (see panel overleaf). Many organisations now recognise the need to demonstrate an adequate electrical inspection and testing regime, but all too often, the subsequent reports are either overlooked, or ignored.

Using an iceberg as an analogy for electrical safety, inspection and testing forms the tip of the requirement – the part we can see, measure and assess. The testing tip is also a hint of more below the waterline, or, in electrical safety, the potential mass of faults that may be lurking. Testing can lead us to these faults and it’s vital to take swift remedial action on those of most serious threat. However, currently this appears to be far from the norm.

In a survey PHS conducted of 400 organisations that had contracted inspection and testing to be carried out, more than half of respondents admitted that no remedial work had been done subsequent to that testing – even though periodic reports had identified serious faults. This is a staggering statistic, especially when you consider that the HSE reports about 1000 accidents at work each year involving electric shock or burns, and around 30 fatalities. Added to the immediate risk of electrocution, electrical faults are also a major cause of fires in the UK. This illustrates the severity of the risk and there is a long list of faults that can cause death, serious injury, or potentially start a fire.

Deadly defects

Examples of potentially deadly faults include fittings, such as missing light covers, that leave live parts exposed. In this instance, something as simple as replacing a bulb can turn into a major hazard. Another common fault is missing bonding to mains water pipes or gas pipes, meaning that pipework could potentially become live if a fault in the system comes into contact with the pipes. Fuse carriers could also be missing, leaving live parts exposed, and creating an electrocution risk for anyone who might come into contact with them. Incorrect fuses also present a serious danger, and engineers have encountered cases where blown fuses have been replaced with copper wire, effectively removing circuit protection from the system and meaning that the occurrence of any fault could cause electrocution, or fire.

Quite simply, electrical faults that pose a threat to people or premises must be considered a priority for rectification.

Falling foul of the law

If a duty-holder fails to conduct safety testing and an incident occurs, then it might be argued that they were ignorant, which is no defence in law. Similarly, in a situation where testing has been conducted but failure to act on the reported findings results in an incident, it would be straightforward to prove culpable negligence. So why is it so common for the findings of test reports to be ignored?

One possible reason is the temptation for a busy health and safety officer, or facilities manager to receive periodic reports and file them, believing their electrical safety duty is fulfilled. Alternatively, perhaps the periodic reports never reach the right person, and are intercepted by a third party, such as an outsourced contractor, like a facilities management company. Even if the report does reach the right desk and is opened, it can often be difficult to decipher. Indeed, many people mistake their test report for a pass certificate, which does not exist in electrical safety.  

The periodic report is a thorough technical document that sets out details of the inspection and testing conducted, and any ‘damage, deterioration, defects and dangerous conditions within the installation’. In section G of the test report is a box, which states the overall assessment of the installation. In this box, it is highly likely to say ‘unsatisfactory’ – suggesting that the site isn’t electrically safe, but this crucial piece of information isn’t immediately obvious to identify. Countless people miss it altogether –  including some of the UK’s largest organisations – sometimes with fatal implications!

Most electrical safety professionals will be familiar with and use the NICEIC (the inspection council for electrical installation contractors) industry-standard, periodic-report format, so we’re all somewhat bound by the current system. To improve client understanding and awareness, testing companies could send specific notification to those organisations for which they have carried out tests, alerting them if there’s an unsatisfactory rating and suggesting options for rectification. However, it would be better if there was a clearer set of documentation to help guide duty-holders through the process.

Not all organisations are lax in taking action on essential electrical repairs – some go to every length to avoid delay by sending electricians around with the test engineers to immediately rectify any Code One faults (see panel overleaf). This is, arguably, a best-practice approach and removes any risk associated with the time delay from identification of a fault to implementing a solution. If a qualified electrician shadows the test engineer then they are able to make immediate repairs, which is a more robust approach from a health and safety perspective, and allows the duty-holder to be secure in the knowledge that any dangerous issue is dealt with as quickly as possible.

A similar – but perhaps more affordable – option would be to select a supplier that can conduct both testing and remedial work. There are many such suppliers, but make sure that the pricing structure is clear, and that ‘cheap’ testing work isn’t counter-balanced by loaded repair costs.

Controlling the cost of compliance

Achieving electrical compliance might sound arduous, and more and more organisations are seeking to outsource work relating to this area. However, you cannot delegate your duty of care, so it’s in your interest to understand, as far as possible, what the implications of a testing regime are, so that you can be truly happy that the precautions being taken are adequate and appropriate.

You can’t sit back and assume your supplier will make you compliant; you can only be comfortable that its service will achieve this by overseeing the process. Check you have either ‘satisfactory’ test reports, or test reports supported by ‘Minor Works’ certificates that validate repairs for any Code One and Code Two faults listed in the ‘unsatisfactory’ report.

Choose your supplier carefully; look for proof of the qualifications held by the engineers who will actually undertake the work. Testing companies should be members of the NICEIC, or the ECA (Electrical Contractors Association). Test engineers should ideally be fully employed, i.e. not sub-contractors, and qualified to City and Guilds 2377 for PAT testing, and 2391 for fixed-wire. Check also that your supplier complies with the IET (Institution of Engineering and Technology) codes of practice.

You also want to ensure commercial viability by achieving compliance without overspend, or being encouraged to do more than is necessary. As a starting point for smart buying, the obvious thing to do is get competitive quotes or tenders. However, take care to ensure that you have comparable quotes, rather than comparing apples with oranges. You must check that your prospective suppliers are quoting for the same thing, or you could end up taking a cheap deal that turns out to be unsatisfactory in the long run. For example, suppliers that are hungry for business may use cut-price testing to entice you and then back-load the price of resultant repairs, which are usually the greater part of the expense.

It’s common for quotes to be compiled on guesswork and approximations, so when the work is conducted the billing can exceed the estimate. The sure way to avoid this unpleasant surprise is to be diligent in your specification. When you go out for tender, make sure you make your exact requirements clear, and keep the testing process straightforward and in line with Approved Codes of Practice (ACoPs).

One option is to phase your testing schedule over time rather than in one big project. This means you can spread the cost out and plan it according to your budget. However, take care when scheduling that no element falls outside the recommended frequency of test. 

To drive down the price of testing you can use flexibility to your advantage. Unsociable hours cost the most, and short timescales can also mean you pay more. Plan in advance and build all the timing and site-access flexibility in that you can. Communicate that intention to your supplier and ask it to find a way to reduce its prices in return for considerations on your part.

Like buying a fixed-price energy deal, if you negotiate a longer contract for inspection and testing that will span three, four or five years you are sure to get preferential pricing. Remember, the supplier wants your business on its order book, so you should be able to drive a better deal on price. By the same token, linking the purchase of your electrical safety to gas and other services should maximise your buying power, and lead to the equivalent of ‘volume discounts’.

Finally, remember that ensuring electrical safety is only part of your duty of care. You may also need to consider gas, fire, emergency lighting and other services, depending on your site. Depending on your needs in regard to these services, there may be advantages in terms of efficiency and price if you single-source all your compliance requirements, with the added advantage that you have one supplier to contract and manage. If they can reduce the number of engineer visits required to fulfil your various compliance requirements their costs should be lower, and so, too, should your invoice for this work.

Final word

In summary, it’s imperative to appreciate that periodic fixed installation inspection and testing is only part of electrical safety compliance. Essential remedial work must be completed in a timeframe appropriate to the coding of the fault, or faults found – and, in the case of Code One and Code Two faults, this means urgently.

Further information

Paul Caddick is managing director of PHS Compliance.

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