PAT testing in ‘low risk environments’
At a time when regulations seem to be ever more stringent, the HSE’s guidance last year concerning electrical safety and PAT testing in so-called ‘low risk’ environments caused some surprise.
After all, according to The Health and Safety Executive themselves, 25% of all reportable electrical accidents involve portable appliances. Yet the Electricity at Work Regulations 1989 still require any electrical equipment that has the potential to cause injury to be maintained in a safe condition. However, exactly how this should be achieved is vague under those very same regulations.
In providing guidance based on its own experience within its properties last year, the HSE were trying to provide a common sense approach which, while attempting to provide good safety practice, did not put over arduous demands upon businesses.
Key to this was the idea that businesses should take a risk assessment based approach to electrical safety in the workplace. Employers should consider the type of equipment and how it is used, how often it is used or moved and so forth. This could then be combined with a visual inspection programme rather than PAT testing, unless there were specific high risks.
This risk-based approach is expected to be emphasised in the next revision of the IET’s code of practice.
Risk assessment is a controversial area. Who is competent to carry out such a task? Surely, if someone who is not fully competent is assigned to the task there are clear issues of liability if there is an accident.
The same applies to visual inspections. Visual inspections are an important part of any electrical safety regime because they may identify problems that PAT testing will not in certain cases. They are certainly not the same as ‘user checks’ and require more knowledge and more training on the part of the individual.
The HSE itself says: “More formal visual inspection and testing by a competent person may also be required at appropriate intervals, depending upon the type of equipment and the environment in which it is used.”
The whole notion of a ‘low risk’ environment is tricky. While it’s obvious an environment where heavy-duty electrical power tools are used on a regular basis presents more of a risk than a typical office, an office environment can still present serious dangers. Take a typical office kitchen where there’s bound to be an electric kettle and probably a microwave or some other form of electrical heating appliance. Within the office environment itself there may be portable desk lamps, or computer and printing equipment, maybe portable ventilation fans, or even heaters. There may be maintenance equipment such as vacuum cleaners or floor polishers. There may also be television sets, or AV projection equipment. In a large office block there could be a staff canteen or a handyman’s workshop; neither of which are low risk environments.
In an office environment there is often very little sense of ownership or responsibility. Generally workers do not personally feel responsible for the equipment they use. As a result, it’s clear that the best practice must surely still be to employ a competent person to offer a full range of services, even in so-called ‘low risk’ situations. These people can combine expert visual assessments with PAT testing where required. Many Class II items can be subject to a professional visual inspection while Class I items can receive more rigorous, professional attention during the same visit.
Here, the new HSE guidelines say: “When undertaking combined inspection and testing, a greater level of knowledge and experience is needed, and the person will need the right equipment to do the tests, the ability to use this test equipment properly, and the ability to properly understand the test results.”
There are no hard and fast rules as to how often such an inspection needs to be completed. We would recommend an initial – and thorough – testing of electrical safety on the premises and then a regular and well-documented regime of testing based on the type of equipment found. This might be monthly, or perhaps even as infrequently as every five years, depending on the level of risk expertly identified by the inspector and in consultation with the Duty Holder at the workplace. Test Certificates can be issued after appropriate visual inspection or testing, and armed with these, employers should be convinced that there is no better way to meet their legal safety obligations. We look forward with interest to the introduction of international standard IEC 62638 later this year which is widely expected to further emphasise and define the role of PAT testing. At the moment, the standard is expected to offer a fuller definition of basic PAT tests and test methods. This should include the performance levels expected for in-service testing as well as formal guidance for testing any electrical equipment after it has been repaired.
Steve Dunning is Managing Director, Martindale Electric
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