Imported Electrical Installations

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PeteRig
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Imported Electrical Installations

Post by PeteRig »

Not sure if I have this in the correct topic, this is on Worksafe web site, a few errors in it.

https://www.worksafe.govt.nz/dmsdocumen ... ngs/latest

Happy reading

Peter
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Slovett (Mon Jun 10, 2024 2:00 pm)
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AlecK
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Re: Imported Electrical Installations

Post by AlecK »

Thanks for posting that.
I knew there was something coming on this.
Sparkznz
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Re: Imported Electrical Installations

Post by Sparkznz »

Cheers for this. What errors did you find?
AlecK
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Re: Imported Electrical Installations

Post by AlecK »

There are a number of errors and omissions, some minor and others more serious.


The methodology described in this Guide depends on an "Installation SDoC", which appears to be mandatory.
However there appears to be n Regulation or Gazette notice to provide the mandate.

And while the guidance correctly notes the need for Inspection of "mains work" when connecting to a grid supply; it ignores the fact that off-grid installations also have "mains work" that needs to be Inspected.

The worst error is that under the assessment approach (Step 4) we are told to record test results on a CoC.
Doing so would be a breach of ESRs.
A CoC is required to include a declaration that the work was done ‘lawfully and safely”.
Yet this entire "Assessment" option is for installations that have NOT been done "lawfully & safely".
Issuing a CoC in accordance with this guidance would be issuing a false declaration, and subject to Level 2 penalty under ESR 69.
While some CoC forms do include provision for recording some test results; a CoC is an entirely inappropriate form for recording a full set of test results i.a.w Section 8 of "3000"

There's also incorrect statements about need for SDoCs for DMRAs.
Yes the importer must issue SDoC for any DMRAs that are imported as part of the installation.
And yes anyone certifying PEW (ie following the "Certification Approach") can rely on these SDoCs when certifying.
But certifiers only have to attach SDoCs to the CoC IF they rely on them.
(though with an imported building, would be remarkably foolish not to use SDoCs as bum-cover)
And those following the "Assessment Approach" are NOT certifying PEW, and so cannot rely on any SDoCs that may exist.
They are certainly NOT responsible for attaching SDoCs to the RoA (because there's NO Regulation of Gazette Notice requiring this to be done).
Nor is any person connecting required[ESR 73A] to sight SDoCs; let alone attach them to ESCs

It's good to see some guidance in this area; we now have two recognised approaches and we can follow either.
But unfortunate that the (Worksafe) authors seem to have a poor grasp of some of the relevant regulatory requirements.
PeteRig
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Re: Imported Electrical Installations

Post by PeteRig »

By email I did ask some questions about the doc to Worksafe after I read it and got a verbal reply the same day (which shocked me) so with the verbal reply that means nothing is put in writing I guess.
I questioned using the CoC for test results and what to write on it, I suggested possibly using Forms 1 or 2 from 3019 and got a positive response.
I was informed to write on the description section of the CoC that it was part of an RoA, it appears they are looking for a CoC for the paper trail.
I mentioned that the CoC was for PEW and Reg 65 clause 6 says a CoC is not required for certification and inspection, no real answer to this question.

Also in my email I wrote " that in Section 7 of the doc it is suggested that an electrical inspector "should" carry out the RoA and record their results on a COC, apparently the reason the word 'should" is used is that this doc is not regulated so the word "shall" for example cant be used?

In the EV guidelines the word "shall" is used multiple times in the October 2019 addendum and only once in the May 2019 guidelines.

WorkSafe I believe may issue an article about this doc soon in ElectroLink or Electron.

Keeping it positive with WorkSafe I did mention that it was good to see a doc giving guidance and that the layout of the sections was of benefit to all.
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