4th Edition Code of Practice for Portable Appliance Testing (PAT testing)
16 July 2013
In late 2012, the Institute of Engineering and Technology (IET) published the 4th edition of its Code of Practice for the in-service inspection and testing of electrical appliances.
The Code provides comprehensive guidance on the periodic in-service inspection and testing of electrical appliances (commonly referred to as PAT testing). It is designed to ensure that organisations, administrators and those carrying out the testing fully understand the requirements of the Electricity At Work Regulations (EAWR) 1989 and can demonstrate compliance with it.
Currently, many organisations carry out their PAT testing annually in the belief that this is a legal requirement. But PAT testing has never been an annual legal requirement in a wide variety of environments, as the duration for PAT testing should be assessed based on the risk factor of an environment. The IET estimates that millions of pounds are spent every year needlessly by low risk businesses for over-the-top PAT testing procedures. The new Code of Practice aims to address this issue by making clearer the rules and regulations of the PAT testing process.
The publication of the revised and updated Code is part of a process that started in 2011 with the publication of Professor Löfstedt’s report on health and safety and continued with the Health & Safety Executive’s (HSE) revised guidance on maintaining portable electrical equipment in low risk environments with a proportionate approach to PAT testing.
Both Professor Löfsted and the HSE expressed concern that the implied legal requirement for maintaining the safety of electrical appliances was being applied too broadly and disproportionately, resulting in situations of costly over compliance.
The main thrust of the new Code is to highlight the importance of taking a structured approach to risk assessment for the determination of equipment inspection and testing intervals. Alongside this renewed emphasis on risk assessment, the new guidance also provides further clarification on the responsibilities of dutyholders and the extent to which the involvement of external contractors or advisors might be used. It clarifies which equipment is covered - including hired and second-hand equipment. In addition, there is an explanation of the risk assessment required to determine frequencies between inspection and testing, if it is required. The changes in the guide have also removed microwave leakage testing, which is no longer considered to be part of an in-service inspection. Similarly, production testing of items like audio and video appliances has also been removed.
New prominence is given in the Code to the responsibility of the duty holder (which might be the facilities manager, building manager, landlord or other such responsible person) to ensure that appropriate risk-based assessments are carried out. However, the code also makes it clear that a duty holder may enlist the services of a competent person (including a contractor) to assist in this process.
Importantly, the Code’s new emphasis on risk assessment is now fully consistent with the existing legal requirements of the Management of Health and Safety at Work Regulations 1999. Regulation 3 of the regulation requires all employers and self employed persons to assess the risks to workers and others who may be affected by their undertaking. Employers with five or more employees should also record the significant findings of that assessment.
To further reflect the new emphasis on assessment of risk, the IET has stressed that its own widely used table on test intervals included in the Code should be used only as guide to the initial frequencies of inspection and testing. Future and continuing inspection and test intervals should depend on ongoing risk-based assessments, with periods being increased, decreased or kept the same, as appropriate. For example, retest scales for some IT equipment are now up to 60 months, while hire equipment (like vending machines, water coolers and PA systems) should be tested if based on site for longer than one week as part of the routine inspection of other appliances. However, environments that are judged by the Code to be risky will continue to require regular testing. For example, an area such as a construction site is clearly a more dangerous environment than an office because there is a greater likelihood of a portable appliance being damaged. In contrast, a portable appliance is unlikely to be damaged in an office type environment as many appliances simply sit under desks (such as computers) or remain in a fixed area.
In a significant change to existing practices and as a further emphasis of the link between the dutyholder, risk assessment and inspection and testing intervals, the new Code also recommends that the date for re-testing 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’s 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. In summary, the new Code should help all those involved in maintaining electrical safety in the workplace to better understand their obligations and be able to make more informed decisions on the scope of inspection and testing required.