Jim Wallace, associate director of Seaward, gives his thoughts on the recent HSE announcement on portable appliance testing.
The Health and Safety Executive (HSE) recently launched revised guidance on maintaining portable appliances in low risk environments. The revised advice has been made in response to the earlier Löfstedt report published on health and safety legislation which said that the legal requirements concerning the maintenance of electrical appliances was applied ‘too widely and disproportionately’.
In its updated announcement the HSE is advising 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.
In the interests of clarifying the main points included in the new Guidance, I would make the following points:
- There are no fundamental changes in the Guidance other than an extension of some of the periods between tests.
- The Guidance refers specifically to low risk environments and suggests that certain types of equipment - particularly Class II - may not need to be tested. However, it does suggest that a regular formal visual inspection is performed. It should be noted that this is different to ‘user checks’ and that formal visual inspection does require some degree of training and electrical competency to know what to look for and how to avoid danger.
- The Guidance suggests that Class I equipment together with mains cables, extension leads and battery charging equipment should be subject to periodic inspection and test.
- The HSE has used the Guidance to emphasise the fact that the Electricity at Work Regulations 1989 do not state that there is a requirement for testing electrical equipment. This has always been the case. However, the Regulations do state that electrical equipment should be maintained so as to prevent danger and this has been widely regarded as an implied requirement to test. Without periodic inspection and testing it is not always possible to know whether maintenance is required.
In the HSE Guidance notes it states that ‘Table 1 at the end of this leaflet gives an indication of where a visual inspection should be sufficient and where testing may be needed in order to comply with the law.’
- The new Guidance states that: ‘the person carrying out the test should not assess when the next test will be due as this decision should be made by you the Duty Holder on a risk assessment basis.’ In reality it has always been the responsibility of the Duty Holder to decide if and or when testing is required. A contractor might make a recommendation about the periods between tests but the Duty Holder will make the decision based on experience, guidance notes and recommendations.
- Although reference is made to ‘offices, shops, some parts of hotels and residential care homes’, it is important to understand that a low risk environment can only be properly identified by a thorough assessment of the type of electrical equipment in use, the patterns of use and the competencies/abilities of whoever is using the equipment. The HSE’s own case study of a review of PAT testing undertaken at its premises (available at www.hse.gov.uk), concludes that, only for ‘certain types of portable equipment’, is further testing not required
- The new HSE advice will need to be considered alongside the more detailed guidance to be included in a revised and updated IET Code of Practice for In-Service Inspection and Testing of Electrical Equipment that is expected to be published later this year.
The new fourth edition of the IET code is likely to include more detailed and revised recommendations for the inspection and testing of different types of electrical equipment in different environments.
- Injuries caused by faulty electrical equipment represent only part of the problem concerning accidents and safety in the workplace. An important area not considered by the latest HSE announcement is the contributory role of faulty electrical equipment in fires in business properties.
Portable appliance testing has a strong role to play in fire prevention measures and we strongly believe that any assessment of the workplace risk associated with damaged or faulty electrical appliances should take this factor into account.
- There is indisputable evidence that periodic in-service inspection and testing of portable electrical equipment has made a significant contribution to improving workplace safety. We believe the credibility and standing of PAT will be further reinforced later this year with the introduction of an international standard (IEC 62638) that defines a set of basic tests, including the test methods and the performance levels for in-service testing and testing after repair for electrical appliances.
In summary, Seaward supports all moves to encourage a better and more widespread understanding of the vitally important role played by the in-service inspection and testing of electrical equipment.
We regard the latest HSE announcement as making another important contribution to this effort, but it should also continue to be viewed alongside all the other advice, guidance and pertinent information available on this matter.