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