Jim Wallace highlights the main changes in the new IET Code of Practice for maintaining the safety of electrical equipment in the workplace, and discusses what they mean for the services sector.
The recently published fourth edition of the Institution of Engineering and Technology’s (IET) Code of Practice for In-Service Inspection and Testing of Electrical Equipment1 provides a timely reminder for all those with a responsibility for workplace safety under the Electricity At Work Regulations 1989.
By providing comprehensive guidance on periodic in-service inspection and testing of electrical appliances, it is designed to ensure that organisations, administrators and those carrying out the testing fully understand the requirements of the EAWR 1989 and can demonstrate compliance with them.
Although much of the services sector, including offices, shops, some parts of hotels and residential care homes, for example, are now regarded as relatively low-risk environments,2 there is still a requirement for electrical equipment to be maintained to prevent danger.
There is considerable evidence that faulty electrical appliances continue to pose a serious threat to people and property.
In the opening remarks on electrical safety included in the Löfstedt Review,3 reference is made to the 1000 workplace accidents and 30 fatalities involving electric shock and burns that are reported to the Health and Safety Executive each year.
However, electric shock and electrocution represent only part of the problem associated with faulty electrical items; their contributory role in property fires, which are also a major cause of deaths, injuries and considerable costs to businesses, must also be taken into account.
Successive annual UK fire statistics show that faulty appliances and leads continue to be the single most common cause of accidental fires in ‘other buildings’ (non- dwellings).
Against this background, it must be recognised that effective electrical safety precautions for one organisation will be different from those of another, operating in a different sector or environment – this is very much the emphasis of the new IET guidance.
The updated IET Code of Practice is essentially the third step in a process that started just over a year ago with the publication of the aforementioned Löfstedt Review of health and safety, and continued with the HSE’s revised guidance on maintaining portable electrical equipment in low-risk environments (see below).
In both these cases concern was expressed that the implied legal requirement for maintaining the safety of electrical appliances was being applied too widely and disproportionately, resulting in situations of costly over-compliance, particularly in more benign working environments.
To meet the requirements of the Löfstedt Review, new guidance was issued by the HSE in mid-2012 on maintaining portable appliances in low-risk environments.4 In summary, the HSE advises against testing too often, explaining that, for some businesses, there may be little need to test all their equipment every year but testing at various intervals is still advisable, depending on the type of equipment.
The HSE guidance suggests that certain types of equipment – particularly Class II items (i.e. double-insulated equipment) – may not need to be tested. However, the same guidance suggests that Class I equipment (earthed items), together with mains cables, extension leads and battery-charging equipment, should be subject to periodic inspection and test, as should cables and extension leads.
The HSE guidance also includes a table with suggested initial intervals for checking and testing electrical equipment, but advises that the results of previous checks, inspections and tests should be used to determine future intervals.
The fourth edition of the IET Code of Practice follows this theme by focusing on the importance of taking a proportionate response to the need to ensure that all workplace electrical systems should be maintained to prevent danger, so far as is reasonably practicable.
To this end, the new guide has been expanded in scope to include more electrical-equipment categories and workplaces, together with more detailed explanatory notes and definitions of inspection and testing matters.
However, the main thrust of the new edition is to highlight the importance of taking a structured approach to risk assessment for the determination of equipment inspection and testing intervals. Alongside this renewed emphasis on risk assessment, the new guidance provides further clarification of the responsibilities of duty-holders and the extent to which external contractors, or advisors might be used.
A firm emphasis on risk assessment
The Code of Practice has always emphasised that the frequency of inspections and testing should be reviewed on a regular basis, following an assessment of the risks associated with the use of a particular appliance. But the new edition is even more clear 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.
It reiterates that risk-based assessments are the responsibility of the duty-holder (which might be the facilities manager, building manager, landlord, or other such responsible person), but points out that a duty-holder may enlist the services of a competent person to assist in this process.
Importantly, the new emphasis on risk assessment is completely consistent with the existing legal requirements of the Management of Health and Safety at Work Regulations 1999, reg.3 of which requires all employers and self-employed persons to assess the risks to workers and others who may be affected by their undertaking.
In support of this, the IET Code recognises that there are many different methods of risk assessment and, provided that they are carried out within their individual scope of use, any can be used. The key is that risk assessments should be reviewed regularly to ensure that any control measures are effective and that there are no changes in the assessment factors. If there are any significant changes, the risk assessment should be updated to reflect them.
By their nature, risk assessments are subjective and it can often be difficult to show, or explain the reasoning behinda judgement taken at an earlier date. With electrical safety, such reviews need to consider not only the technical aspects of the particular item of equipment but also the practicalities of the location (is the photocopier near pot plants that are frequently watered, for example) and the human factors associated with attitudes to safety and the use of equipment.
As a result, the new Code acknowledges that risk encompasses many factors that can eventually influence a final decision on electrical inspection and test frequencies, but goes on to highlight the following factors on which an informed decision should be made regarding the frequency of any inspections and tests required:
Further reflecting the new emphasis on assessment of risk, the IET’s Code also stresses that its own widely-used table on test intervals should be used only as 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.
The duty-holder, labelling and documentation
Duty-holders or managers of premises are required to know their legal responsibilities as laid down in the EAWR 1989. The IET Code of Practice requires that they should understand and apply the legislation, and assess the risks in respect of electrical equipment and appliances within their charge, or which they are contracted to inspect, test, and repair or replace.
Duty-holders have a legal responsibility to ensure that the electrical equipment in their charge is safe; it is also their responsibility to decide whether or not to vary the inspection and test frequencies. However, in doing so, duty-holders can take advice from the competent person doing the inspection and testing.
The Code also recommends that it is good practice to ensure that all equipment that requires routine inspection and/or testing is clearly identified and labelled. The information provided may consist of a barcode, which makes the equipment uniquely identifiable, even if several similar items exist within the same premises.
Importantly, in a significant change to existing practices and as further emphasis of the link between the duty-holder, risk assessment and inspection and testing intervals, the new Code also recommends that the date for re-testing should not be marked on the pass label. Instead, it is advised that the “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’.”
Clearly, without a visual reminder of any next-test due dates, there is likely to be increased reliance on the effective use of electrical equipment asset records and inspection and test data. Although there is no requirement in the Electricity at Work Regulations 1989 to keep records of equipment and of inspections and tests, the HSE Memorandum of Guidance (HSR25) on these regulations advises that records of maintenance, including test results, should be kept throughout the working life of equipment.
Set against the principles of new risk-based maintenance programmes, test record-keeping systems are therefore likely to become more important as a management tool for reviewing the frequency of inspection and testing; without records, duty-holders cannot be certain that inspection and testing have actually been carried out.
Summary
The new IET Code of Practice should help all those involved in maintaining electrical safety in the workplace to understand their obligations better and make more informed decisions on the scope of electrical inspection and testing required.
The application of a risk-based approach, together with the use of enhanced compliance records and documentation systems, should also enable duty-holders to exercise greater control and security over portable-appliance maintenance procedures.
Overall, even though there are some who anticipate that responsible duty-holders will continue to take an ultra-cautious approach and test more frequently to be on the safe side of the law, if properly applied, the risk-assessment approach should mean that the costs of complying with the Electricity at Work Regulations 1989 are reduced – which is exactly what the Löfstedt Review set out to achieve!
References
1 http://electrical.theiet.org/books/inspection-test/in-service-inspection-4th-ed.cfm
2 www.shponline.co.uk/news-content/full/government-wields-axe-over-safety-inspections
3 Löfstedt, Prof R (2011): Reclaiming health and safety for all (p49) – www.dwp.gov.uk/docs/lofstedt-report.pdf
4 HSE (2012): Maintaining portable electric equipment in low-risk environments – www.hse.gov.uk/pubns/indg236.pdf
Jim Wallace is associate director at the Seaward Group.
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