New regulations on testing and tagging on construction sites

On 1 January 2009, changes to OHS regulations in Western Australia will come into effect that allow the testing and tagging of portable electrical equipment and portable RCDs on construction and demolition sites to be undertaken by a competent person or a licensed electrician.

To assist in effecting this new regulation, the WA Department of Consumer and Employment Protection has produced the document 'Guide to testing and tagging portable electrical equipment and residual current devices at workplaces'.

As prescribed by the Occupational Safety and Health Regulations 1996 and Mines Safety and Inspection Regulations 1995, the person having control of a workplace or access to that workplace (employer, self-employed person, main contractor) must ensure that all portable plug-in electrical equipment and RCDs at the workplace are safe and appropriately inspected, tested and maintained by a competent person.

Listed below are extracts from the guide that outline who is permitted to perform the tests.

Who may test electrical equipment?

A competent person must undertake the testing of electrical equipment. This is a person who has acquired, through training, qualification or experience, or a combination of these, the knowledge and skills required to test electrical equipment competently.

The testing of electrical equipment requires specific expertise and interpretation of results and, therefore, can only be carried out by appropriately qualified or trained people who are able to recognise electrical hazards or potentially unsafe conditions.

The person carrying out the tests must know what to:

• look at;
• look for; and
• do.

The two levels of competency associated with this type of work are:

• A licensed electrician with electrical qualifications and skills uses electrical test instruments that give actual readings requiring technical interpretation (eg, using an insulation resistance meter and ohmmeter).
• A person not qualified in electrical work uses a ‘pass/fail’ electrical test instrument known as a portable appliance tester (PAT), which automatically tests electrical equipment plugged into it. The result requires no technical interpretation. In this case, the person would need to have been trained and have satisfactorily completed a competency-assessed training course on testing and tagging using a PAT. The course needs to have been conducted by an RTO accredited to deliver the training under the vocational education and training (VET) system.

Who may inspect electrical equipment?

The inspection of electrical equipment does not require tagging unless the electrical equipment is being used on a construction or demolition site or mining operation.

Who may inspect electrical equipment will depend on the risk associated with the equipment and the level of knowledge required to assess whether the equipment is damaged. A further consideration is whether the person carrying out the inspection will be required to remove the equipment from use and refer it for further assessment by a competent person, or is competent to fully assess the condition of the electrical equipment at the time of inspection.

Who may test RCDs?

The test for the operating time of an RCD requires specific technical expertise and interpretation of results and, therefore, can only be carried out by an appropriately qualified or trained person. This means a licensed electrician or a person who has successfully completed a competency-assessed training course in the use of an RCD tester. The course needs to have been conducted by an RTO, accredited to deliver the training under the vocational education and training (VET) system.

What key competencies are required?

The key competencies required by a person who carries out testing and tagging apply to both competent persons using a PAT and licensed electricians:

• Being able to distinguish between electrical equipment that is double-insulated and electrical equipment that is protectively earthed, and identify the appropriate test for each type.
• Understanding the limitations of their training and not attempting to test electrical equipment they have not been trained to do.
• Understanding how the OSH or MSI regulations and relevant guidance material apply to electrical equipment used at the workplace.
• Knowing how to use the relevant testing instruments properly, interpret and record results for compliance with the OSH or MSI regulations.
• In accordance with AS3012:2003:
  – know about, and be able to carry out, a visual examination of electrical equipment
  – be able to carry out the earthing continuity tests on electrical equipment
  – be able to carry out the insulation resistance or earth leakage tests on electrical equipment

Who may authorise workers to ‘test and tag’?

Irrespective of who does the work, the worker must be authorised by the employer for the workplace. The person authorising the work must be satisfied that:

• the inspection and testing program is appropriate and adequate for the needs of the workplace; and
• the workers carrying out testing and tagging are competent to do the work (ie, licensed electrician or appropriately trained competent person).

Competent persons will need to produce their statement of attainment or certificate on request to an employer, WorkSafe or mines inspector as appropriate, main contractor, labour hire organisation, a person having control of or control of access to a workplace, or an elected occupational safety and health representative.

Department of Consumer and Employment Protection