In Service Inspection and Testing of Electrical Equipment

Hi I haven't posted anything here before but take great interest in the topics raised and the comments that it provokes. Keep it up.
The most annoying thing about the forums is that it always takes you to the very beginning of a thread which in some instances is years ago! It would be a good idea if when you click on a comment on the front screen it takes you to the comment in the thread.
Not a great problem but annoying if you have been following a thread and end up scrolling through so much.
Apart from that keep up the good work - I have learnt a lot from the comments on here and hope to in the future.

Phil

You will be pleased to know that in the very near future we will be updating our forum areas so that they will be easier for everyone to use.

If you do have any other thoughts in the meantime then please do let us know.

Gavin
Online Community Manager

Graham.
That is my biggest bug bear with this forum, the lack of edit/delete capabilities.

Other than that, it is an excellent forum.

Bryan,

Welcome. Yes, you are correct.

As you'll also be aware, we work in the world that's dominated with IT. Sometimes it's common to repeat the same transcription error when typing, and not even notice it. I work for a company that provides specialist IT systems, and get involved with "human factors", so I'm aware this is not a one-off occurrence.

I noted that it was only in one post in 2008, so I thought this may be the case and declined to make comment. I also considered the fact thtat there doesn't appear to be a simple way to edit your post on this Forum.

I note some contributors refering to BS 7672 , should this not be BS7671 as the other one all abour womens tights!

Looks like a sound policy to me Malcolm. Maybe you already do but it might be to the mutual benefit of you and your customers if as well as reporting a problem to them you also recommend a solution otherwise your report may be filed away only to be repeated at your next inspection and no progress has been made towards a safer environment. I'm sure that in most cases your customers will be dependant upon your expertise and advise in these matters so please give it.

I don't know what other PAT inspectors supply by way of documentation to their customers but as a part of my report I have an appendix 3, Post PAT Comments: which gives me a vehicle for reporting what I consider poor practices I.e. lack of socket outlets, damaged electrical fittings, poor access to plugs, too much use of multiway adapters etc.

Since 'Hard Wired' small appliances have been included and RCDs as well I also use this page to explain that some tests are limited and in the future I will recommend that some 'Hard Wired' appliances are reverted back to plug & socket to facilitate maintenance.

Regards

Malcolm

First, to come back to Malcolm's excellent points:
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I have found that a large number of appliances just cannot be disconnected due to close proximity to the ground or other barriers. Spur and isolation switches are generally connected to the system with twin core & earth cable which is just not designed to be pulled out and twisted round to gain access to the appliance terminals. In addition, I have found that the plate fixing screws can be corroded, or contaminated with cement or plaster such that they cannot be either removed or tightened. I wonder how many other PAT Testers carry a range of replacement screws and a thread cutter, as I do.
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There are a number of points here, that would indicate questionable "design" under CDM, whether by original electrical system designer, or later designers of "fit-out" of furniture, etc., (e.g. access to outlet faceplates and terminals), and/or management/coordination of construction work (allowing wet plaster to ingress electrical accessories, which, apart from damaging the accessories, we need to consider that we do come across plastering being done around outlets etc. that are "live"), and/or non-conformance to BS7671 Wiring Regulations (fixing screws being corroded may imply incorrect selection of materials for the environmental conditions).

That given, there's still an issue to be considered, where normally "hand-portable" equipment is connected directly to an outlet plate, rather than via plug and socket outlet. This is because the frequency of inspection of the "hand-portable" equipment is far greater than the electrical installation components it is connected to, and Malcolm quite rightly points out that you can actually damage fixed wiring components if you "fiddle" with them too often.

Let's put this on the level.

Hand-portable equipment is hard-wired in hotel rooms to reduce losses: a risk-reduction measure. It can be assigned a "risk-benefit" value, which is why it's done.

The risk of electric shock resulting from faulty appliances can also be risk assessed, and I'd probably recommend in somewhere like a hotel, this is formally assessed, because the exposure to appliances, and also mis-use of appliances, is greater than, say, an office, and hence likelihood of a fatality is increased. So, ultimately, this has a "risk-benefit" value (if memory serves, the "Shall be maintained . . ." Regulation from Electricity at Work Regulations is a "so far as reasonably practicable" ??).

So, maybe if the two cases are looked at, accounting for increased costs of "appliance testing", maybe it's actually cheaper for larger hotels to keep spare kettle leads and small appliances, and/or apply "SMART Tagging" technology with detectors on exits?

These are only thoughts - based on Malcolm's very good points above. I'm sure that CDM, in time at least, will help designers address some of these issues, and consider safe maintenance?

Malcolm I think that’s a good policy for the future but please remember that the legal requirement in the Electricity at Work Regulations 1989 is simply that, "As may be necessary to prevent danger, all systems shall be maintained so as to prevent, so far as is reasonably practicable, such danger."
For fairly obvious reasons it is not possible for the regulations to describe in detail the exact maintenance requirements for every single item of electrical equipment in every possible situation it can be found. That assessment is left to the discretion of competent people to make considering all of the circumstances. All of the guidance available is simply that, guidance, which in most cases if followed will hopefully lead to compliance with the regulations.
There is no specific requirement to carry out inspections and testing of all electrical equipment although most would agree that in all cases some combination of the two is appropriate. Also, most faults with electrical equipment of the type usually associated with PAT can be identified by visual inspection so for lots of situations a thorough visual inspection by competent persons would be adequate. Of course equipment deemed to be unsafe should be taken out of service immediately.
Where equipment is intended to be moved frequently or whilst in operation such as kettles hair dryers etc as well as earthed equipment more detailed testing may be required at suitable intervals. In this case it is the responsibility of your customers to make the equipment available for you to carry out the tests safely, which in all but very exceptional circumstances means with the equipment dead. I struggle to think of a situation, in a hotel for instance, where working live could be justified.
I think a better solution to carrying out tests live is to restrict the maintenance to visual inspections until the equipment can be accessed safely and providing that any certification or labels you apply states clearly that the maintenance you have carried out is limited to a visual inspection then you will have discharged your duty to your customer in a responsible way. You might also, in your report, make recommendations for the future testing of equipment as necessary reinforcing the message that the responsibility is his.
Graham, without putting you on the spot too much, I’d be most interested in your comments. I’m sure Malcolm would find them useful.

Ernie

I accept all that you have posted and Graham as well. Assuming that a spur can be isolated, I have found that a large number of appliances just cannot be disconnected due to close proximity to the ground or other barriers. Spur and isolation switches are generally connected to the system with twin core & earth cable which is just not designed to be pulled out and twisted round to gain access to the appliance terminals. In addition, I have found that the plate fixing screws can be corroded, or contaminated with cement or plaster such that they cannot be either removed or tightened. I wonder how many other PAT Testers carry a range of replacement screws and a thread cutter, as I do.

Ernie - I think you may have a really good point about hard wiring to avoid walkabouts. I think that in future I will tell my customers to revert back to plug & socket if they want hard wired appliances tested - as you both have said, it is the customer's responsibility.

Regards

Malcolm

I suspect that a lot of this "fixed equipment" has had the plugs removed and connected via fused spurs to stop it going walk about. Whereas Graham is spot on and his advice very professional I fear some of the other advice being given on some of these posts is not quite so sound, at best irresponsible and bordering on dangerous. In the scenario I have described above if the customers want their "fixed equipment" tested by portable appliance testers then carrying out the tests live is neither safe nor legal. The only acceptable options are to put the equipment back on plug tops or provide sufficient methods of isolation and employ competent electrical people to carry out the maintenance. The latter would probably be very disruptive and likely expensive but we shouldn't forget that whilst it is important to get the job done it is not nearly as important as getting the job done safely. The resonsibility is with the owners of the equipment to have a safe and maintainable installation but the people carrying out the work also have a duty to carry out the maintenance safely. We also have a responsibility to know our own limitations and not carry out work for which we have insufficient knowledge to ensure our own safety and the safety of others. Electricity is a pretty unforgiving medium to work with, quite often one mistake and you're out. Stay safe folks the cemeteries are too full now.

Andy Murphy
Member - 1 post

Hi I run my own PAT testing business and I am C&G 2377 qualified, I have just received a call from a large hotel asking me to PAT test 120 rooms all of which are HARDWIRED! there are over 800 items. My question is, is there no test equipment that performs basic PAT on HARDWIRED items or as Malcolm already mentioned would I have to conduct a basic Earth test (LIVE)?
Regards Andy

Andy because you have asked this question I cannot help but think that you are not an electrician or an electrical engineer but someone whose knowledge of electrical things is limited to that gained from attending the City and Guilds courses for PAT testing. If I have picked this up wrong then please accept my appologies but if not please see my previous post and please unless you can effect the isolation of a piece of equipment by removing its plug from a socket then do not attempt to work on the equipment unless you have someone who is electrically competent with you or you obtain some additional training that will enable you to recognise and deal with risks associated with fixed/hard wired equipment.

I've disliked the term portable appliance testing since it was first coined and used. The requirement for the maintenance of any piece of electrical equipment is the same irrespective of whether it can be called a portable appliance, hard wired, fixed installation or any other description that may be used. Regulation 4 of The Electricity at Work Regulations 1989 tells us that "All systems shall at all times be of such construction as to prevent, so far as isreasonably practicalable, danger." and that "As may be necesssary to prevent danger, all systems shall be maintained so as to prevent, so far as is reasonably practicable, such danger."
In the case of electrical equipment supplied from a socket by a flexible lead and plug an off the shelf portable appliance testing instrument is an appropriate aid in assisting a competant person to asses the condition of such pieces of equipment. The key element is the competency of people to carry out such work and whilst it may be possible to train non electrically competent people to carry out "Portable Appliance Testing" the same cannot be said for the maintenace of other items of electrical equipment where the operator may be exposed to more risk or an increased level of knowledge necessary to recognise and deal with those risks is required.
As stated in a number of posts above whilst there is plenty of guidance available there are no hard and fast rules that can be applied to every piece of electrical equipment in every location.
The best advice is if you do not have the expertise to make the assesments yourself then it is essential that you enlist the assistance of a competent electrical engineering organisation to carry out the work on your behalf.
Malcolm in your post you stated that "All this means is that the only way to test a hard wired appliance is live." This may not be a responsible thing to say to someone who is not as electrically competent as I suspect you are. The law requires that where necessary to prevent danger there should be a means for cutting of the supply to and a means for isolating any electrical equipment. Because the law prohibits working at or near live conductors except in "exceptional" circumstances and only when other means for reducing danger have been employed working on live equipment should be very much the exception and not the rule.
A visual inspection is always required and an insulation test and where appropriate an earth integrity test can be considered the compulsory tests most of the others are functional tests. Hope this helps.

Take a look at "Maintaining portable electrical equipment in HOTELS and tourist accommodation" INDG237

http://www.hse.gov.uk/pubns/indg237.pdf

regards

David

Hi I have followed all comments with interest. It may be useful to this discussion to look at HSG 107 'Maintaining portable and transportable electrical equipment.
This is a free download of the HSE guide. As it is normally the HSE who will prosecute in the event of an infringment of the regulations, to follow their guidelines should help in the defense.

Regards

Trev

Hi I run my own PAT testing business and I am C&G 2377 qualified, I have just received a call from a large hotel asking me to PAT test 120 rooms all of which are HARDWIRED! there are over 800 items. My question is, is there no test equipment that performs basic PAT on HARDWIRED items or as Malcolm already mentioned would I have to conduct a basic Earth test (LIVE)?
Regards Andy

I think a fused spur going into a 2 pole keyswitch, to isolate small appliances, would be an excellent way to overcome the safe isolation procedure. It might be a bit tricky with towel rails in the bathroom, or similar but if the circuit was protected with an RCD or MCBO it would work. Maybe a new design of fused spur with well insulated input connectors, feeding a 2 pole isolator keyswitch via the fuse, is needed - designers take note please!.

Until all this comes to pass, I am paid to PAT Test all electrical appliances which come under the heading 'Portable' and which now appears to include fixed appliances connected to a spur or switch. I generally try to test 100 items a day, a few more if it is IT only, including repairs such as replacing plugs with RCDs where required etc. etc. The problem of isolation is not so much that of method, thanks to your posts, but more to do with time. By the time it would take to identify a spur, and any other users connected to the circuit; then switch off the said circuit, having got agreement with those other possible users; then dropped the spur, disconnected the appliance, fitted flying leads for connection to the PAT Test instrument , then tested the appliance, then reconnected the appliance to the spur - well you get the idea. It would not take many hard wired appliances to cut my 100 items a day down to 50, effectively putting me out of business.

I say 'roll on' to isolator switches but in this current economic climate I cannot see companies fitting them retrospectively although I will try to encourage it.

Regards

Malcolm,

I understand the problem you've got trying to ascertain safe isolation procedures for equipment. But in actual fact, it's still the "Employer's" problem:

Regulation 12 of the Electricity at Work Regulations (http://www.opsi.gov.uk/si/si1989/Uksi_19890635_en_3.htm#mdiv12) requires suitable means for isolation to ensure safety. I believe that this Regulation is mandatory unless the device being isolated is itself a source of supply (such as a tranasformer UPS or generator), in which case Regulation 12 Para (3) applies, to still require danger is prevented SFARP.

Therefore, if a fixed appliance is to be regularly inspected and tested, and the test procedure necessarily involves opening up the connection unit (as is normally the case) there must be adequate means of isolation to allow this to be carried out safely.

If this means that the means of isolation (e.g. 2-pole keyswitch for small appliances) is separate to the connection unit, i.e. you can isolate all conductors to the connection unit before opening up, proving dead, and testing the appliance, then that is what is required.

Alternatively, if the means of isolation is at the Distribution Board, then the Employer must give you access to isolate and lock off before opening the connection unit.

This is, of course, part of the Fixed Electrical Installation. Hopefully, more Designers (of fixed electrical installations) will begin to take periodic inspection procedures into account from the outset - it's required under CDM Regulations, if nothing else.

Graham, I think that everyone reading your post, cannot but be impressed by your efforts on bringing together all these standards and definitions in what clearly is a difficult subject. It is a pity that your post cannot be published such that all ordinary electricians, old & new could read it and be aware of what should be required of those proposing to do periodic inspections.

I suspect that the Portable/Fixed Appliance, hard wired via a spur to a Fixed Installation will continue to create a grey area, especially for contractors like myself, who come in between periodics and who try to pick up the pieces of what should have been sorted out previously.

From a PAT inspectors point of view, all I see is are clients who are trying to comply with an avalanche of regulations and want it done as cheaply as possible. To advise a client that he should have arranged to get his fixed appliances tested at the time of the last periodic is probably correct but unhelpful. In the real world he wants it done now and if you can't or wont do it, there are scores of professional label fitters out there, ready to take the job and your income with it.

The best that I can come up with is the live test but I would prefer not to do it at all as it carries some risk and takes much longer.

Regards

Malcolm Wallace
Senior PAT Inspector
Safetest Electrical

In response to Kelly Mansfield, reference information provided by Mahendra Mistry, Electrical Engineering Specialist, Bureau Veritas UK Ltd., which I believe to be mis-leading.

FIrst, the fixed Electrical Installation may include "fixed equipment". However, periodic inspection and testing of the installation, as defined by Chapter 62 of BS7671: 2008, and associated IEE Guidance Note 3, only covers testing for the fixed wiring.

BS7671, against which the installation is inspected and tested, only covers the SELECTION of equipment - it does NOT deal with safety of the equipment itself which must comply with appropriate standards. It also specifically excludes equipment (or assemblies or systems) classed as "Machinery".

When a "periodic inspection" is booked, it is arranged against the current version of BS7671. If the customer wants fixed equipment inspected and tested, this should be identified BEFORE the inspection and test, and listed separately with any relevant standards that apply (e.g. IEE's Code of Practice for In-Service Inspection of Electrical Equipment). Please see Section 3.6 of Guidance Note 3 on BS7671: 2008.

The IEE's CoP for In-Service Inspection of Electrical Equipment does NOT preclude its use for "fixed equipment", and adequately fills the gap.

If you don't specify inspection and testing of fixed equipment when you procure a Periodic Inspection of the electrical installation, then then only a cursory visual inspection of the outside of the equipment will be made by the electrical inspector.


I think this is quite plain, and it's up to the person responsible for the electrical installation to agree an appropriate scope with the electrical contractor for the periodic inspection - including getting competent persons to inspect and test. THIS MAY MEAN DIFFERENT PEOPLE ARE REQUIRED TO INSPECT THE FIXED EQUIPMENT, TO THE FIXED WIRING INSTALLATION, ESPECIALLY IN THE CASE OF "MACHINERY".


Second, the Electricity At Work Regulations doesn't care whether the electrical equipment (or "system") is "portable" or not. The Regulations simply require adequate maintenance to ensure safety. The difference arises simply in that, if you carry out a risk assessment, you may decide that Portable Appliances carry more risks, therefore require more frequent inspection and testing, than fixed equipment and installations. To carry this illustration further, it is possible to have "mobile or transportable equipment" (generators and exebition/show equipment) which is equipment that's typically "fixed", but is arranged for transport to different locations: that would require more frequent inspection and testing than "fixed equipment" that never moved throughout its life.

Third, on the definition of "Portable Appliance". It is possible to remove the plug of a "portable appliance" and connect the appliance to a fused spur - regardless of whether it remains hand-portable (such as a hair-dryer in a hotel room), or becomes "fixed". It is also possible to have "fixed equipment " connecting via normal plug and socket - here, I'm not only talking about a washing machine (which is "movable" or "transportable", rather than "portable" or "hand-portable"), but about things like IT Servers, that are permanently bolted into racking systems except when they are being maintained.

There is a definition of "portable appliance" on page 18 of the IEE Code of Practice for In-Service Inspection and Testing of Electrical Equipment, that does NOT include the definition of having a plug.

Please be careful about trying to define what a "portable appliance" is by yourself: definitions already exist in many equipment safety standards as well as the IEE CoP (which seems to accord with the safety standards in general), and therefore you are leaving yourself open to being challenged.


Hope this is useful, but to summarise:

1. "Portable Appliance" does NOT mean "has a UK plug" (or similar definition).

2. Your "fixed" or "permanently-wired" equipment won't be inspected or tested adequately by the contractor carrying out the Periodic Inspection to BS7671, UNLESS you specifically include this in your requirements. Expect to be charged more for this, or to seek advice from relevant specialists in the equipment itself (e.g. for "Machinery").

Graham Kenyon,
Chartered Electrical Engineer.

I have just carried out a PAT inspection of a hotel where 3 out of four appliances in every room were hard wired to a fused or unfused spur. My method of live testing worked very well and I was brought in because the electrical company who had just carried out a full periodic inspection of the hotel did not and never had tested anything past the spurs. I consider myself a high quality PAT Tester who is trying to do the right thing and my clients look to me for advice.
Mahendra says these appliances are fixed wiring, electricians appear to consider them portable appliances, Graham says its not up to the PAT Tester but up to the organisation as a result of a risk assessment and the new CoP (para 5.5) lists them with all other catagories of appliance.

Does the IEE have the part number of a crystal ball because I will need to order one - in the meantime I shall carry on with the method I outlined in an earlier post.

Regards

"as does most people here"

wheres me grammar?

"The general definition of a portable appliance is a equipment that has a flexible cord and is supplied by a plug"

Is that why it is not called Personal Appliance testing (except as a nickname) any more?

"The Electricity at Work Regulations 1989 clearly states the for a person to work on electrical equipment and installations they must be competent to do so and competency is defined as a person who has the theoretical knowledge of electricity, has recieved the necessary training, is familiar with the class of installation and equipment to be worked on, understands the dangers that could arise and knows when to stop working."

To what level? if someone has attended a course for 'PAT' testing, and has then passed the exams, arent they then competent to a certain level.

I'm not deliberately picking holes in what you say, because I largely agree with what you are saying, as does most people here.

But it is, in my opinion, not clearly defined and as Malcolm said before it's the IEE sitting on the fence.

I have spoken to other Electricians, and none of them are absolutely sure when it comes to testing.

Mahendra Mistry,
Electrical Engineering Specialist,
Bureau Veritas UK Ltd:

Stationary equipment supplied by a fused spur should be inspected and tested as part of the fixed wiring installation. The general definition of a portable appliance is a equipment that has a flexible cord and is supplied by a plug. In this case equipment is supplied by a spur unit which cannot be physically disconnected from the electrical installation. There are some PAT testing companies that allow their engineers to test these items and are placing the engineers at risk.
In order to fully test an appliance supplied by a spur unit, the spur unit has to be opened which exposes live electrical parts which increases the risk of electrical shock. If engineers do not understand the dangers of electricity and have not recieved the appropriate training then they should not be working on or near live equipment. The Electricity at Work Regulations 1989 clearly states the for a person to work on electrical equipment and installations they must be competent to do so and competency is defined as a person who has the theoretical knowledge of electricity, has recieved the necessary training, is familiar with the class of installation and equipment to be worked on, understands the dangers that could arise and knows when to stop working. Hence to work on spur units an engineer would need to be a qualified electrician. Further more the ELectricity at Work Regulations 1989 say that a person should only work on live equipment if 1) it is unreasonable in all circumstances to switch it off AND 2) it must be reasonable for him to work on the equipment live AND 3) where following a risk assessment it has been decided to work on live equipment then appropriate safety measures must be in place ie procedures, PPE, barriers, notices etc.

If access is not made available to any part of the equipment during inspection and testing then this must be clearly stated in the report and the client advised accordingly. The client must then make the necessary arrangement to make all parts of the equipment accessible, this could be removing shelves, moving heavy filing cabinets, unlocking rooms etc.

Regards
Mahendra Mistry
Electrical Engineering Specialist
Bureau Veritas UK Ltd

The equipment should be tested using a procedure recommended by the manufacturer, or, alternatively, the original installer.

It is not possible for the IET to provide guidance that is suitable for each and every item of fixed equipment - there are literally 100s of standards covering the electrical safety of equipment.

If you wanted to build up a general knowledge of equipment safety, ERA used to run a course that covered equipment safety, something like "Safe Design of Electrical and Electronic Products".