I'm coming in late to this post but feel this topic has confused a lot of people so I need to clear up the mis-conception.
Recently the Health and Safety Executive (HSE) released a document entitled Maintaining portable electric equipment in low-risk environments which prompted loads of articles, blogs, tweets, Facebook posts, etc. stating that the HSE had announced that there was no law that says PAT Testing is required, and that PAT Testing was illegal or didnt have to be done.
As someone who has read this article in detail more than once, and seen many of the other articles, and to add to that, put many people right, I need to ask the question did the source of this post start with someone who hadnt read the article correctly?
The issue: at no point in the document does it say that you dont have to get PAT Tested
In fact the first time the term Portable Appliance Test (PAT) is mentioned the document states
not every electrical item needs a portable appliance test (PAT). It didn't say "
no electrical items need a portable appliance test (PAT)".
So this thread is entitled "
now NO need for PAT Testing"; how far into the document did you read? The term PAT is not mentioned until the bottom of page 1, until then the document
INDG236 (rev2) has discussed
maintaining electrical equipment.
Follow the link to open the document if you like.
The important point to notice is that the document is about maintaining electrical equipment, of which the practice of PAT Testing is a part.
Note: PAT Testing is a term used for ease because people know it, it's not a correct term to use and is a general term for different assessments that are carried out on electrical equipment of all sizes and uses, whether portable or not.
This post is about a document released by the HSE making recommendations for maintaining electrical equipment in the workplace. The thread has been started by someone who has mis-read an important document, or more likely is jumping on the band wagon of the first article and hasn't actually read the document but is just repeating someone elses (incorrect) opinion. This thread is telling people there is no need to be PAT Tested, which if you read the document correctly (doesn't need to be read that carefully) and understand what PAT testing is you will see that there is a need to get tested, and that even the HSE tells you so.
The HSE says in the document, that not every item needs a PAT test. With this in mind, isn't it also saying that some items DO need a PAT test. Thus it is not saying that there is no need for PAT Testing but is in fact saying that PAT Testing IS a requirement.
What the document does say, in depth and I think this is where people are taking it out of proportion is you must maintain electrical equipment if it can cause danger, but the law* does not say how you must do this or how often.
This is referring to
maintaining electrical equipment. The inspection and/or testing procedure more commonly referred to as PAT Testing is only a part or an option of this.
Based on these misconceptions are you also saying that a faulty electrical appliance (eg a circular saw without a guard) doesn't need repairing?
*In this case the law referred to is stated as the Electricity at Work Regulations 1999.
Dependant on your opinion of this, if the PAT is
part of the maintenance programme and the law does state you must 'maintain' then does that mean you must also PAT, by law? That is a matter of opinion but is worth considering as a question.
The document does say that The business owner or manager must ensure they maintain the electrical equipment if it can cause danger all electrical equipment can cause danger because it is electrical; it works from electricity, which is dangerous.
How many owners or managers can honestly say that they maintain their electrical equipment on a regular basis and keep records to prove it. As an experience electrical inspection engineer I can honestly say, not many.
By conducting what is generally referred to as a PAT Test, you are showing that you are taking action to ensure your electrical appliances are safe, and with the certificate issued you have evidence to prove you have done this.
The second part of the statement says that the law does not say how you must do this or how often, but this HSE document and other HSE documents do, as does the Code of Practice for In-service Inspection and Testing of electrical equipment, which PAT Testing companies are supposed to work to.
As the law doesnt say this, and most people dont know what the guidelines are they quite rightly turn to their PAT Testing company, and ask the question. 8 out of 10 companies will tell their clients everything has to be tested every year to ensure compliance.
It is this advice that has given our industry a bad name, because
this advice is wrong. How often an item needs testing is dependent on your own risk assessment of the appliance and the environment it is used in. Your risk assessment must comply with the Health and Safety at Work Act 1974.
Some equipment in some environments do need inspecting or testing annually, some even more frequent than that, but this document, the document that started this post doesn't relate to those environments.
I would like to clear something up; when the HSE document talks about maintaining electrical equipment it is talking about:
- assessing (user checks)
- repairing
- inspecting (visual inspections)
- electrical testing (formal visual inspection and/or combined inspection and testing AKA PAT)
Users of the equipment are meant to do a user check before they use the equipment every time, and report any faults and thus get them repaired. Dependant on the risk factor of the equipment and the environment it may be deemed necessary for a formal visual inspection and/or a combined inspection and test.
The
formal visual inspection and the
combined inspection and test is what people generally refer to as PAT Testing. Which is done and when is dependant on the risk assessment and the guidelines.
The guidelines are in a table form, in this document. I'm going to skip the user checks as you should be doing them anyway.
This document by the way, only relates to Low risk environments (mainly offices); the guidelines for construction sites, factories, industry etc. remain the same. In fact the low risk environments guideline hasn't changed it's just been put into a document.
If you have a look at the table the only items the HSE say don't need a PAT Test in some respect (the last 2 columns relate to the PAT Test) at all or battery operated equipment or extra low voltage equipment. The battery operated equipment wouldn't have been tested in the past anyway, and the extra low voltage equipment sometimes has a visual on it, and sometimes isn't tested; dependant on what the client deems a risk.
So, the title of the post should have been:
Nothings changed; there's NO need for PAT Testing on battery operated or extra low voltage equipment.
Then chances are no one would have commented on it.
