Electrical Compliance – quality and safety are being swept aside by cost-cutting
By Ian Carnall, Managing Director of Guardian Electrical Compliance Ltd
Electrical compliance is a legal duty, as specified within the Electricity at Work Regulations 1989 (EaWR). Unfortunately, far too many duty-holders see this an obligation that must be dealt with as quickly and cheaply as possible, leading to a box-ticking, corner cutting attitude to compliance.
Maintaining a safe place of work in accordance with the EaWR is not and never has been achieved by compiling records alone.
The risk of an electrical fire, explosion or shock has to some degree been relegated to a tick in the box by someone who may not have an electrical background.
It is reprehensible that cost-saving is the priority over quality and safety throughout much of the industry in a bid to find the cheapest way of achieving electrical compliance. The resulting race to the bottom to offer the cheapest price has, without question, led to a serious decline in reporting standards.
The implications and impact of compliance
There is a dearth of readily available information regarding what constitutes a safe place of work, how to manage electrical reports and how to evidence the continuous monitoring and maintenance of electrical installations. This information is vital in providing a dutyholder with a defence in law, should there be a breach of the EaWR, and this absence is one of the main reasons for the current indifference towards electrical compliance.
25 years’ experience distilled into some simple lessons
Guardian has gained an invaluable insight into the right approach to compliance through thousands of client appointments over a 25-year period, chairing regular client dutyholder meetings, delivering over 70 National Electrical Safety Seminars and currently advising a client base of over 2,500 end users.
Electrical compliance requires serious focus and ongoing attention from a collaborative working partnership between supplier and client. It should never be about simply uploading records to a server until the next time, be it three or five years.
Indeed Regulation 4 (1) & (2) of EaWR 1989 states: As may be necessary to prevent danger, all systems, shall at all times be of such construction, so as not to give rise to danger:
- All systems – from a battery to a power station
- All times – no days off, no respite
- Construction– designed, installed maintained and operated
The regulation is difficult, if not impossible to comply with. However, paragraph 69 of EaWR 1989 does provide a solution and goes on to say, “records of maintenance, including test results, preferably kept throughout the working life of an electrical system will enable the condition of the equipment and the effectiveness of maintenance policies to be monitored. Without effective monitoring, dutyholders cannot be certain that the requirement for maintenance has been complied with.” The IET Wiring Regulations BS7671: 2018 Reg 652.2 goes on to mirror Paragraph 69 of EaWR 1989.
Clearly, EaWR 1989 is calling for an effective monitoring policy, a way of historically evidencing continuous monitoring and maintenance of the electrical system, not just a series of arbitrary tests at the mercy of a contractor who knows how to ‘complete’ electrical reports.
Where or what should the dutyholder(s) refer to for guidance and assistance?
The NICEIC Connections magazine is a great help, particularly from a technical perspective. Hospitals have their Technical Memoranda (HTMs), Universities have something similar, but where is the help for the end user who needs guidance on practically discharging dutyholder responsibilities?
After all, whether electrically biased or not, it is incumbent on the dutyholder under Regulation 3 of the EaWR 1989 to “comply with the provisions of the Electricity at Work Regulations 1989, in so far as matters which are within your CONTROL.” In other words, if you are in control for a particular aspect of electrical compliance, it is your responsibility.
So, what about the legislation?
For 30 years, dutyholders have had an EaWR memorandum of guidance on how to work safely on or near electrical equipment. Together with the current edition of BS7671 and the associated eight guidance notes, there is a basis for formulating a methodology for ensuring the electrical installation is safe to remain in service. Yet still there are gaping holes in basic legislative knowledge and quality of test records, leaving dutyholders unwittingly exposed, should there be an electrical incident leading to a breach of EaWR 1989.
Guardian’s Complete Managed Compliance Service has evolved over a 25-year period, Chastening experiences with the HSE have fundamentally shaped our business, so much so that we employed a former Senior Electrical Inspector from the HSE. As a consequence, this engendered a new focus when working with electricity from every department within our business.
For further information visit www.guardianelectrical.co.uk
