Deciphering the new IET PAT code

Jim Wallace highlights the main changes included in the new IET Code of Practice for maintaining the safety of electrical equipment in the workplace

The revised IET Code of Practice for In Service Inspection and Testing of Electrical Equipment is essentially the third step in a process that started with the publication of the Löfstedt review on health and safety and continued with the HSE's revised guidance on maintaining portable electrical equipment in low risk environments.

In all cases, concern was expressed that the implied legal requirement for maintaining the safety of electrical appliances was being applied too broadly and disproportionately, resulting in situations of over compliance, particularly in more benign working environments.

The fourth edition of the IET Code of Practice follows this theme by focusing on the importance of taking a proportionate response to ensure that all workplace electrical systems should be maintained to prevent danger, so far as is reasonably practicable, and in line with the requirements of the Electricity at Work Regulations 1989.

Assessment of risk The clear message in the new IET Code is that electrical safety should be based on a more focused and robust approach to assessing the risks posed by electrical appliances.

The implication is that only when the risk of using electrical equipment has been assessed and understood can it be managed through a programme of inspection and testing. In fact the Code has always emphasised that the frequency of inspections and testing should be reviewed on a regular basis after an assessment of the risks associated with the use of a particular appliance.

However, new prominence is given to this approach in the latest document which also reiterates that risk based assessments are the responsibility of the duty holder (which might be the facilities manager, building manager, landlord or other such responsible person), but that a duty holder may enlist the services of a competent person to assist in this process.

It is also highlighted that risk assessments should be reviewed regularly to ensure that any control measures remain effective. Risk encompasses many factors that can eventually influence a final decision and, for example, should include a full consideration of the environment in which the equipment is being used, the level of user awareness, the equipment construction and type, frequency of use, previous records and type of installation for fixed appliances.

All of the factors used in the risk assessment should culminate in enabling an informed decision to be made on the frequency of any inspections and tests required. To further reflect the new emphasis on assessment of risk, the IET also stresses that its own widely used table on test intervals included in the Code of Practice should be used only as guide to the initial frequencies of inspection and testing.

Labelling and documentation Duty holders have a legal responsibility to ensure that the electrical equipment in their charge is safe and it is their responsibility to decide whether or not to vary the inspection and test frequencies.

However, in doing so, the IET makes it clear that dutyholders can, if necessary, take advice from the person doing the inspection and testing.

The Code also says it is good practice to ensure that all equipment that requires routine inspection and/or testing is clearly identifiable and labelled. However, in a significant change to existing practices, it is now recommended that the date for retesting should not be marked on the pass label. Instead it is advised that "the duty holder should determine the date for the next inspection and/or tests on a risk assessment basis" and record this on their "Equipment formal visual and combined inspection test record".

Clearly, without a visual reminder of any next test due dates, there is likely to be increased reliance on the effective use of electrical equipment asset records and inspection and test data. Although there is no requirement in the Electricity at Work Regulations 1989 to keep records of equipment and of inspections and tests, the HSE Memorandum of Guidance (HSR25) on these regulations advises that records of maintenance including test results should be kept throughout the working life of equipment.

The new Code of Practice should help all those involved in maintaining electrical safety in the workplace to better understand their obligations and use risk assessment to make more informed decisions on the scope of inspection and testing required.

Jim Wallace is associate director of Seaward Group