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Maintaining Portable Electrical Equipment

THE ELECTRICITY AT WORK REGULATIONS AND HSE GUIDANCE


Most Consultants will be aware of the fact that under the Electricity at Work Regulations (EAWR) an employer is required to ensure that electrical equipment is maintained in order to prevent danger, but the EAWR does not say how this is to be accomplished or how often. Instead, a proportionate, risk-based approach should be taken as advocated by the HSE.


In March 2011, the Government established an Independent Review of Health and Safety Legislation to make proposals for simplifying the existing raft of health and safety legislation. The report which followed this study included reference to the fact that the legal requirement concerning maintenance of electrical appliances is “applied too widely and disproportionately”, resulting in costly over-compliance with the law. This is evidenced by a misunderstanding by many businesses that all portable electrical appliances have to be tested annually, and is often intensified by contractors offering misleading advice and advertising.


This particular point has been taken up by the HSE, as a result of which their guidance document INDG236 has been revised and published under the title: Maintaining portable electric equipment in low-risk environments, in which a risk-based approach is further emphasised. This is published alongside HSG107: Maintaining portable electrical equipment, both of which are available on free download for those Consultants wishing to refresh their knowledge on this subject. (INDG 237 which specifically related to portable appliances in hotels has been withdrawn.)


Each of these HSE publications includes a Table with suggested initial intervals for checking portable appliances, spanning user checks, formal visual inspection and combined inspection and testing. A further important point of note is that the HSE recognise that visual inspection does not need the employment of an electrician and can be accomplished satisfactorily by a competent member of staff with suitable knowledge and training. However, when undertaking combined inspection and testing, a greater level of knowledge and experience is required, and the person will need:-


  • the appropriate testing equipment

  • the ability to use the equipment correctly


  • the ability to properly understand the test results.


Whilst for major businesses combined inspection and testing will often be carried out in-house by a member of the maintenance team, businesses in the SME sector are, in most cases, likely to employ the services of a specialist contractor.


HSG107 has recently been revised which includes the following table of suggested initial maintenance intervals across a wide range of equipment, including those in low risk environments (within the scope of INDG236):


Notes to Table:

  1. Cables, leads and plugs connected to Class II equipment should be maintained as part of that equipment. Cables leads and plugs not dedicated to an item of equipment should be maintained as individual items as appropriate.

  2. In many premises, e.g. in the health service, in educational premises, hotels and offices, more than one inspection and test regime may apply to different equipment due to a mix of high-risk areas (e.g. kitchens, laundries) and low-risk areas (e.g. offices).

  3. Where the Table indicates a variable interval, a precise interval should be determined by the dutyholder based on a risk assessment. 

  4. After the first few formal visual inspections, the information obtained can be used to revise the intervals between future inspections. The same is true for combined inspection and testing.

 

MAINTENANCE RECORDS


There is no legal requirement to keep maintenance records for portable electrical equipment. However, formal recording is strongly recommended as a means of demonstrating legal compliance and for monitoring and reviewing the effectiveness of the maintenance plan. 

                                                          

SURVEY EXPECTATIONS


In addition to making observations and enquiries as to the visual condition and maintenance of the electrical installation, this activity should extend to portable appliances generally, based on the best practice guidance of the HSE including the above Table.


This should be reported as required and Risk Improvements raised where considered appropriate, based on the standard wordings, which have been revised to align with the alterations in HSE documentation.

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