Proposed limits of work

[ZL2AJ]

Hi all. Had a chance to read the proposed new limits of work?

One thing I am struggling to grapple (and maybe I am over thinking it)
eg
EST can do low risk work except maintenance of any work included in ESR 6A(2)
ESR 6A(2) lists the following as High Risk except when they are LOW RISK

I smell a circular argument here.

So currently an EST can replace a mains entry box

In future no?

I'm still working my way through this so will likely have more issues with this as I progress. On the whole I like the direction though.

[ZL2AJ]

Q2

Endorsements as they relate to inspectors

Inspector limits - not permitted to carry out PEW in .... mains parallel generation system... unless authorized by appropriate endorsement (remember inpsectrion of PEW is PEW)

MPGS endorsement limits of work
3) Does not allow a person to:
a) Inspect PEW

Another circular argument? So can inspectors inspect MPGS or not? (I'm guessing yes but they havent worded it well)

I also hate the fact that they used the word assess in the inspectors limits of work.

[gregmcc]

do a submission, that's what the email is about, I see the point about EST's replacing a mains entry box, technically it is low risk, but keep in mind poor wording in the past means that a lineman can issue a COV for an installation.......

[ZL2AJ]

Yea I will be doing a submission. I just wanted to highlight it to the group here.

The CoV poor wording was a mistake rather than poor wording (a fine distinction I realize) that was consciously left to persist. That said a Section 3 - 3019 verification is fairly basic. That said you will need to be competent to do so now (as defined by new limits) in anycase. I like that clause but I think it will be hard to prove until one has a mistook and proves oneself incompetent.

[ZL2AJ]

we could also co-ordinate the submissions, that way the EWRB get a clear picture of what electrical workers want/think

[AlecK]

Good luck trying to co-ordinate anything in the few weeks available

Q1
replacing a mains entry box is low risk; and within current LoW for EST
But not within proposed LoW for EST, assuming the phrasing 'maintenance of work" has any real meaning.
Which it doesn't, because you don't maintain "work"; you do work, and that work is either installation work or maintenance work.

I infer that EWRB are trying to say that an ESR won't be authorised to do maintenance on anything for which installation would be high risk PEW.
But the words they've used could never stand up in court.
On the other hand,. they don't have to (stand up in court), as for any disciplinary action there's no court involved,
and the board can choose to believe the words have whatever meaning they want them to have.


Q2
Yes inspection of PEW is itself PEW - so must be authorised to do it (generally by holding "Inspector" PL).
as you've noted, the MPGS endorsement allows the carrying out of PEW on a MPGS (all risk categories).
(similar for the other proposed endorsements).

The exclusionary language proposed for all LoW means that not even low risk PEW can be carried out unless the EW has the relevant endorsement.
If the work on MPGS is maintenance, low risk so no inspection required.
If installation / alteration work, then high risk, and inspection required.
I think the intent is that only an Inspector with relevant endorsement can inspect the work.
"Inspector" LoW say that no PEW can be done of any 'endorsement' type unless holding relevant endorsement.
That would include inspection of high risk PEW on those areas / in those parts of installations.

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i like the addition of "assess'; which has been needed ever since end 2013.
ESR 75 covers periodic assessments, and for three of the 6 types the assessor has to be "authorised to assess" PEW on the relevant type of installation.
But so far there has been nobody who actually held such an authorisation - so any PAs carried out in last 8 years have been invalid.

I'd have preferred the error in ESR 75 to have been corrected; because it isn't PEW that's being assessed, it's the installation (or specified part of it)
But I'll accept this alternative fix for the problem as a workaround.

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I agree the wordings are very difficult to get to grips with.Even worse than now.
I don't think the "negative" approach (saying what you can't do instead of - as required by the Act - what you are authorised to do) helps at all.
An argument could be made that neither the current nor proposed LoW amount to an 'authorisation" to do PEW.
The word 'authorised' doesn't appear anywhere in either LoW or the PL itself.


Constantly having to scroll back & forward through the proposal document, with no 'bookmark" shortcuts, doesn't help