Periodic Assessments for caravan parks.
My understanding is these can only be assessed IAW ASNZS3001:2008, as per ESR75. Clause 2.7.2 of 3001 directs us to Appendix C for re-verification details.
It’s not a task I’m really involved with, but a discussion was raised elsewhere regarding the requirement for RCD protection for service pillar socket outlets. I believe this is a mandatory requirement, in order to pass a Periodic Verification, as per C5.3 of 3001. If RCD protection wasn’t fitted, it would need to be in order to pass the verification. Is this correct?
Another opinion was, upgrading service pillar outlets to include RCD protection wouldn’t be necessary for older installations as the installation complied in its time, and ESR113 makes provisions for it to remain as is.
This doesn’t sound correct to me? ESR113(2) says ‘Despite anything contrary in these regulations…may continue…to be used’. So ESR75 would be contrary to ESR113, meaning the Periodic Verification must be done as per ESR75 & ASNZS3001?
Thoughts?
Periodic Assessments for caravan parks
Re: Periodic Assessments for caravan parks
Periodic Assessment is not like certification & inspection of PEW.
With certification / inspection, there's a set of criteria that the (new) PEW mist comply with.
That makes it a "pass vs fail" exercise.
Issuing a WoEF is similar.
In order for a valid WoEF to be issued, the caravan (or whatever) must meet the criteria specified for issue.
These are not the same as the criteria for compliance of new work; but again it's either "pass" in all respects, or it's "fail".
PA is different, and while there's a set of criteria set, there is NO requirement for the installation being assessed to meet those criteria.
The result of a PA is simply a record of assessment.
The issue of the RoA is NOT conditional on all benchmarks being met or exceeded.
Clause 4 of ESR 75 doesn't allow for an RoA not to be completed, nor for it to be withheld until remedial action has been taken.
It has to be "completed; and it has to be "given".
Therefore there's NO requirement to upgrade; and no conflict with ESR 113.
The key is in the name: "assessment"; not 'verification" or "inspection".
The point of an RoA is to advise the owner / operator of the site as to the general level of electrical safety, and in particular anything that needs attention.
An RoA need not state which benchmarks are met (or exceeded), but certainly should state which are not.
Taking the example of a PA of a caravan park, and in particular RCD protection of service pillar sockets.
Pre-2003 (?) it wasn't mandatory for RCD protection to be installed.
And as you've noted, ESR 113 states that whet complied when installed, and continues to comply with those requirements,
can continue in service unless it becomes electrically unsafe.
Not having RCD doesn't make it electrically unsafe (as defined).
From 2003(?) (when 1997 Regs changed from citing ECP 1 to instead citing "3001"); RCD protection was required for new SP sockets.
So we can have a mix, even within same caravan park, older sockets without RCD and newer with RCD.
WRT RCD protection; the benchmarks set by "3001" clause C 5.3 are:
- "3112 sockets intended for use to supply caravans shall have RCD
(Note: "3112" sockets intended for other purposes, eg 10 A GPOs, are not covered by this)
- "60309" sockets installed i.a.w. "this edition" (ie 2008) shall have RCD
(Note: if installed i.a.w earlier editions / documents, the requirement does not apply)
Which means older sockets, that didn't have to have RCD protection when installed, don't need to be 'upgraded".
However it does mean the Assessor needs to know which rules applied when the socket was installed.
Even if you don't accept that PA is simply assessment, and not a 'pass / fail" process; older sockets without RCD can "pass' without needing an RCD added.
PA applies on other types of installation also; either mandatorily via ESR 75 or voluntarily following "3019".
And as the relevant Standards are revised; the distinction between "verification" and "assessment" is being made clear.
The next edition of '3019" will be 'Periodic Assessment', instead of "periodic verification".
The particular Standards cited by ESR 75 are also being amended to make absolutely clear that "assessment" is simply that, and no upgrading is required. For example
- 3001.1 202x will state that RoA follws inspection & testing against the stated criteria / benchmarks.
- 3001.2 202x will state that WoEF follows inspection & testing against the benchmarks - AND passing them.
(statements based on the Public Comment drafts (2nd round), and the fact that No PCs have objected to the revised wording)
Similar for "3002: 202x" and "3012: 2019", both of which are already through the process.
For RCD protection of service pillar sockets ; the benchmark will no longer include date-based applicability;
so once the new edition is cited; the benchmark will be that all SP sockets have RCD.
However while any that don't won't need to be upgraded; they will need to be noted in the RoA as being below the expected standard of safety.
Not a mandatory upgrade - which NZ law generally tries to avoid.
But certainly a bit of friendly persuasion.
With certification / inspection, there's a set of criteria that the (new) PEW mist comply with.
That makes it a "pass vs fail" exercise.
Issuing a WoEF is similar.
In order for a valid WoEF to be issued, the caravan (or whatever) must meet the criteria specified for issue.
These are not the same as the criteria for compliance of new work; but again it's either "pass" in all respects, or it's "fail".
PA is different, and while there's a set of criteria set, there is NO requirement for the installation being assessed to meet those criteria.
The result of a PA is simply a record of assessment.
The issue of the RoA is NOT conditional on all benchmarks being met or exceeded.
Clause 4 of ESR 75 doesn't allow for an RoA not to be completed, nor for it to be withheld until remedial action has been taken.
It has to be "completed; and it has to be "given".
Therefore there's NO requirement to upgrade; and no conflict with ESR 113.
The key is in the name: "assessment"; not 'verification" or "inspection".
The point of an RoA is to advise the owner / operator of the site as to the general level of electrical safety, and in particular anything that needs attention.
An RoA need not state which benchmarks are met (or exceeded), but certainly should state which are not.
Taking the example of a PA of a caravan park, and in particular RCD protection of service pillar sockets.
Pre-2003 (?) it wasn't mandatory for RCD protection to be installed.
And as you've noted, ESR 113 states that whet complied when installed, and continues to comply with those requirements,
can continue in service unless it becomes electrically unsafe.
Not having RCD doesn't make it electrically unsafe (as defined).
From 2003(?) (when 1997 Regs changed from citing ECP 1 to instead citing "3001"); RCD protection was required for new SP sockets.
So we can have a mix, even within same caravan park, older sockets without RCD and newer with RCD.
WRT RCD protection; the benchmarks set by "3001" clause C 5.3 are:
- "3112 sockets intended for use to supply caravans shall have RCD
(Note: "3112" sockets intended for other purposes, eg 10 A GPOs, are not covered by this)
- "60309" sockets installed i.a.w. "this edition" (ie 2008) shall have RCD
(Note: if installed i.a.w earlier editions / documents, the requirement does not apply)
Which means older sockets, that didn't have to have RCD protection when installed, don't need to be 'upgraded".
However it does mean the Assessor needs to know which rules applied when the socket was installed.
Even if you don't accept that PA is simply assessment, and not a 'pass / fail" process; older sockets without RCD can "pass' without needing an RCD added.
PA applies on other types of installation also; either mandatorily via ESR 75 or voluntarily following "3019".
And as the relevant Standards are revised; the distinction between "verification" and "assessment" is being made clear.
The next edition of '3019" will be 'Periodic Assessment', instead of "periodic verification".
The particular Standards cited by ESR 75 are also being amended to make absolutely clear that "assessment" is simply that, and no upgrading is required. For example
- 3001.1 202x will state that RoA follws inspection & testing against the stated criteria / benchmarks.
- 3001.2 202x will state that WoEF follows inspection & testing against the benchmarks - AND passing them.
(statements based on the Public Comment drafts (2nd round), and the fact that No PCs have objected to the revised wording)
Similar for "3002: 202x" and "3012: 2019", both of which are already through the process.
For RCD protection of service pillar sockets ; the benchmark will no longer include date-based applicability;
so once the new edition is cited; the benchmark will be that all SP sockets have RCD.
However while any that don't won't need to be upgraded; they will need to be noted in the RoA as being below the expected standard of safety.
Not a mandatory upgrade - which NZ law generally tries to avoid.
But certainly a bit of friendly persuasion.
Re: Periodic Assessments for caravan parks
Thank you for the feedback Alec. This mostly makes sense to me.
To clarify, the ‘Periodic assessment’ for caravan parks is assessed IAW Appendix C of 3001?
Whether it meets all the criteria of Appendix C or not is immaterial, the RoA is still issued? I suspect the RoA should detail the items that do and do not meet the criteria in Appendix C?
So we’re simply completing the assessment to ‘…determine whether they (installations) are electrically safe and otherwise comply with these regulations’ as per ESR75(1)?
If service pillar outlets do not have RCD Protection they can remain in service, as this is not electrically unsafe, and presumably they complied at their time of install?
To clarify, the ‘Periodic assessment’ for caravan parks is assessed IAW Appendix C of 3001?
Whether it meets all the criteria of Appendix C or not is immaterial, the RoA is still issued? I suspect the RoA should detail the items that do and do not meet the criteria in Appendix C?
So we’re simply completing the assessment to ‘…determine whether they (installations) are electrically safe and otherwise comply with these regulations’ as per ESR75(1)?
If service pillar outlets do not have RCD Protection they can remain in service, as this is not electrically unsafe, and presumably they complied at their time of install?
Re: Periodic Assessments for caravan parks
Yes, PA must be i.a.w the relevant Standard; which sets the benchmarks against which the installation is assessed.
For a caravan park; the benchmarks are in App C of '3001.
Yes, any aspect that falls short of the applicable benchmark should be noted in the RoA
which must be issued regardless of whether or not all benchmarks are met / surpassed.
and which must state - as you've noted from the ESR - whether (or not) the installation is electrically safe and otherwise complies with ESRs.
Even if electrically unsafe, RoA is still issued, stating that fact.
The ROA provides info to the owner / operator; who is the one bearing responsibility for having PA carried out.
Whether they act on that info is entirely up to them, and no business of the assessor.
Under currently cited edition, a modern SP without RCD protection would be noted in the RoA as failing to meet the benchmark
However an older SP without RCD does not currently need to be noted.
Whether RCD is or isn't included as a benchmark depends on what type of socket (3112 vs 60309);
and for 60309 on whether the socket was installed i.a.w 2008 edition;
That edition was cited by ESRs from 1 April 2010 - making that the effective date for application of the benchmark.
Probably should have been 1 Jan 2003, when 1997 Regs cited 2001 edition; because that's when RCD protection became mandatory for new SP sockets (and that's why I referred to 2003 in my previous post).
At that time, PA was i.a.w NZS 3019(1nt): 2002 ; and RCD was only a benchmark for "3112' type sockets, not for "60309" type.
But we can only act on what the rules actually say, not what we think they may have intended. And what they currently say is that an RCD protection benchmark applies for all 3112 sockets, but for "60309"type only those installed i.a.w 2008 edition.
And since complying with that edition wasn't mandatory until 1/4/2010; that's when the benchmark applies from.
Next edition will set a benchmark that applies universally, which is intended to encourage upgrading of older SPs - but can't force it.
For a caravan park; the benchmarks are in App C of '3001.
Yes, any aspect that falls short of the applicable benchmark should be noted in the RoA
which must be issued regardless of whether or not all benchmarks are met / surpassed.
and which must state - as you've noted from the ESR - whether (or not) the installation is electrically safe and otherwise complies with ESRs.
Even if electrically unsafe, RoA is still issued, stating that fact.
The ROA provides info to the owner / operator; who is the one bearing responsibility for having PA carried out.
Whether they act on that info is entirely up to them, and no business of the assessor.
Under currently cited edition, a modern SP without RCD protection would be noted in the RoA as failing to meet the benchmark
However an older SP without RCD does not currently need to be noted.
Whether RCD is or isn't included as a benchmark depends on what type of socket (3112 vs 60309);
and for 60309 on whether the socket was installed i.a.w 2008 edition;
That edition was cited by ESRs from 1 April 2010 - making that the effective date for application of the benchmark.
Probably should have been 1 Jan 2003, when 1997 Regs cited 2001 edition; because that's when RCD protection became mandatory for new SP sockets (and that's why I referred to 2003 in my previous post).
At that time, PA was i.a.w NZS 3019(1nt): 2002 ; and RCD was only a benchmark for "3112' type sockets, not for "60309" type.
But we can only act on what the rules actually say, not what we think they may have intended. And what they currently say is that an RCD protection benchmark applies for all 3112 sockets, but for "60309"type only those installed i.a.w 2008 edition.
And since complying with that edition wasn't mandatory until 1/4/2010; that's when the benchmark applies from.
Next edition will set a benchmark that applies universally, which is intended to encourage upgrading of older SPs - but can't force it.
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Re: Periodic Assessments for caravan parks
Regarding clause C5.4 of Appendix C, for ‘General Purpose Outlets’. I’m assuming for this benchmark to be met, all outlets would require protection by RCD or an isolating transformer?
The wording in this clause isn’t as specific as C5.3, it’s just ‘General-purpose socket-outlets’.
Different question but same topic. Who can actually do the assessment? I always assumed it was an inspector task, but ESR75(2) doesn’t indicate this.
‘…may be undertaken only by a person who is authorised to assess prescribed electrical work on the relevant kind of installation in the relevant location’
So who is ‘authorised’ to access PEW in caravan parks?
ESR75(3) is a bit clearer, seems to indicate the competencies required to complete these assessments are set out in the relevant standard(s)’.
The wording in this clause isn’t as specific as C5.3, it’s just ‘General-purpose socket-outlets’.
Different question but same topic. Who can actually do the assessment? I always assumed it was an inspector task, but ESR75(2) doesn’t indicate this.
‘…may be undertaken only by a person who is authorised to assess prescribed electrical work on the relevant kind of installation in the relevant location’
So who is ‘authorised’ to access PEW in caravan parks?
ESR75(3) is a bit clearer, seems to indicate the competencies required to complete these assessments are set out in the relevant standard(s)’.
Re: Periodic Assessments for caravan parks
Yes, there's a difference between sockets intended for supply to connectable installations, and general purpose sockets.
Covered by 2 different clauses, C5.3 for the CI sockets, and C5.4 for GPOs
GPOs will typically be "3112" type, rated 10 A - but could be any type and any rating.
And yes the benchmark for them is personal protection by either RCD or isolating tx.
Your second question opens a very messy can of worms.
Easy bit first.
PA of hazardous, medical and showgrounds doesn't require any authorisation, and therefore no PL is needed.
Just the "competencies" specified by the relevant Standard.
Unfortunately none of the cited standard details the necessary competencies; though they all have a (fairlygeneric) definition of "competent person".
There is an entire Standard for competencies in hazardous areas, but it isn't the one cited in ESR 75.
So who can carry out those PAs is down to who claims thay are competent - and whether anyone challenges their competence.
However there is nothing in clause (3) that can be properly interpreted as requiring a PL
PA of caravan parks (also marinas and construction / demolition sites) is restricted to persons authorised to assess PEW on that kind of installation .
I believe "authorised" refers to Section 74 of the Act, which sets a general requiremnent for people carryingb out PEW to be authorised.
And the most common form of authorisation is a PL; so were talking a PL with limits of work that include "assessment".
However there are no such PLs, and never have been. Which is only to be expected; because authorisation is for various sorts of PEW; and "assessment" isn't PEW under Schedule 1 of ESRs.
Meanwhile we have to work with what it says now, ie "assess"; and clause 6 ,makes it an offence to carry out a PA unless authorised.
So we have to decide what we think "authorised to assess" means legally.
Until the 2012 amendment, the wording used was "authorised to inspect".
Part of that amendment was altering many Regs so that the words 'inspect" & "inspection" were reserved so that - for purposes of ESRs - they refer only to inspection of high risk PEW. And the minions doing the amendments got a bit carried away.
So from that history, we can deduce that the intent was, and probably remains, that an "Inspector" PL is required.
And it seems very unlikely that the holder of a valid "Inspector' PL would be prosecuted for carrying out an unauthorised PA.
EWRB have announced intent to include "assessment' when they next revise LoW; and I expect "assessment" will be added to "Inspector" PLs.
However that won't fix the problem; because - as stated above - "assessment" isn't PEW, so no authorisation" is needed.
Nor does EWRB have the power to issue any such authorisation; because their powers under Section 149 of the Act are limited to matters relating to PEW.
There's a ruling on record where EWRB have stated that issuing a WoEF is PEW, being - in their view - maintenance of a connectable installation.
Which is complete nonsense, but distorting the definition of PEW allowed them to take disciplinary action against the person; whereas they cannot take action against someone who wasn't doing PEW at the time.
The person in question clearly stuffed up; and arguably wasn't adequately competent to hold an "Inspector PL.
But that's an entirely different matter from the fact that EWRB had no proper basis to take disciplinary action.
For PA; the fact that ESR 75 allows three types of PA to be carried out with no PL whatsoever shows clearly that PA was never intended to be PEW.
The intent was only ever to have PA carried out by those with considerable experience; and holding an "inspector' PL was believed to be a suitable level for simple PAs, while more detailed competencies were desired for more complex stuff like PA of medical or hazardous.
Covered by 2 different clauses, C5.3 for the CI sockets, and C5.4 for GPOs
GPOs will typically be "3112" type, rated 10 A - but could be any type and any rating.
And yes the benchmark for them is personal protection by either RCD or isolating tx.
Your second question opens a very messy can of worms.
Easy bit first.
PA of hazardous, medical and showgrounds doesn't require any authorisation, and therefore no PL is needed.
Just the "competencies" specified by the relevant Standard.
Unfortunately none of the cited standard details the necessary competencies; though they all have a (fairlygeneric) definition of "competent person".
There is an entire Standard for competencies in hazardous areas, but it isn't the one cited in ESR 75.
So who can carry out those PAs is down to who claims thay are competent - and whether anyone challenges their competence.
However there is nothing in clause (3) that can be properly interpreted as requiring a PL
PA of caravan parks (also marinas and construction / demolition sites) is restricted to persons authorised to assess PEW on that kind of installation .
I believe "authorised" refers to Section 74 of the Act, which sets a general requiremnent for people carryingb out PEW to be authorised.
And the most common form of authorisation is a PL; so were talking a PL with limits of work that include "assessment".
However there are no such PLs, and never have been. Which is only to be expected; because authorisation is for various sorts of PEW; and "assessment" isn't PEW under Schedule 1 of ESRs.
Meanwhile we have to work with what it says now, ie "assess"; and clause 6 ,makes it an offence to carry out a PA unless authorised.
So we have to decide what we think "authorised to assess" means legally.
Until the 2012 amendment, the wording used was "authorised to inspect".
Part of that amendment was altering many Regs so that the words 'inspect" & "inspection" were reserved so that - for purposes of ESRs - they refer only to inspection of high risk PEW. And the minions doing the amendments got a bit carried away.
So from that history, we can deduce that the intent was, and probably remains, that an "Inspector" PL is required.
And it seems very unlikely that the holder of a valid "Inspector' PL would be prosecuted for carrying out an unauthorised PA.
EWRB have announced intent to include "assessment' when they next revise LoW; and I expect "assessment" will be added to "Inspector" PLs.
However that won't fix the problem; because - as stated above - "assessment" isn't PEW, so no authorisation" is needed.
Nor does EWRB have the power to issue any such authorisation; because their powers under Section 149 of the Act are limited to matters relating to PEW.
There's a ruling on record where EWRB have stated that issuing a WoEF is PEW, being - in their view - maintenance of a connectable installation.
Which is complete nonsense, but distorting the definition of PEW allowed them to take disciplinary action against the person; whereas they cannot take action against someone who wasn't doing PEW at the time.
The person in question clearly stuffed up; and arguably wasn't adequately competent to hold an "Inspector PL.
But that's an entirely different matter from the fact that EWRB had no proper basis to take disciplinary action.
For PA; the fact that ESR 75 allows three types of PA to be carried out with no PL whatsoever shows clearly that PA was never intended to be PEW.
The intent was only ever to have PA carried out by those with considerable experience; and holding an "inspector' PL was believed to be a suitable level for simple PAs, while more detailed competencies were desired for more complex stuff like PA of medical or hazardous.
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Re: Periodic Assessments for caravan parks
Most of it is in the words used.
Both Regs & Standards are formal documents, that use words in formal ways.
So if we take time to read carefully, and leave our pre-conceptions behind, we'll generally be able to arrive at the correct meaning.
We need to consider why particular words have been used; compared with other wordings that might have been but weren't.
Sometimes the words that are not used can be just as important to establishing meaning as those that are.
However even with best efforts to write rules carefully & clearly, the results can be less clear than desirable.
Knowing the history can assist; so it's helpful to maintain a library of old documents - and to keep track of citation dates.
In this case it seems clear that a find-&-swap exercise just went too far.
Probably because those doing it had little if any understanding of the real-world effects
----------------
The idea that PA is a pass / fail exercise, and that it can be used to force remedial work, is widespread.
However as you noted it's contrary to the clear intent of ESR 113; which is an example of the 'no mandatory upgrades" doctrine that underpins most NZ law.
And if we look back over the history of the words used, they have never (since introduced 1993) supported anything more than a simple assessment & report. 1993 R.39 called it a "safety check".
The certificate if re-inspection under ECP 1 only certified that the place had been inspected, not that it met any particular criteria.
However the (non-mandatory) example record of checks / tests included tick boxes for "pass" & "fail" (instead of 'yes" & "no") beside each benchmark; and I believe that's why many have assumed that assessors had some sort of power to require remedial work before issuing the certificate.
Mandatory upgrades are only ever imposed for specific items; and based on evidence of improved safety outcomes.
The last one I know of in our game was (1987) when caravans were forced - via WoEF provisions - to change from old Reyrolle supply fittings to modern plastic types.
As far as I can tell, the corresponding change for caravan parks was never officially mandatory; it certainly wasn't in the relevant amendment to 1976 Regs.
So it would have been just a natural consequence of wanting to be able to supply caravans with the new style plugs.
Both Regs & Standards are formal documents, that use words in formal ways.
So if we take time to read carefully, and leave our pre-conceptions behind, we'll generally be able to arrive at the correct meaning.
We need to consider why particular words have been used; compared with other wordings that might have been but weren't.
Sometimes the words that are not used can be just as important to establishing meaning as those that are.
However even with best efforts to write rules carefully & clearly, the results can be less clear than desirable.
Knowing the history can assist; so it's helpful to maintain a library of old documents - and to keep track of citation dates.
In this case it seems clear that a find-&-swap exercise just went too far.
Probably because those doing it had little if any understanding of the real-world effects
----------------
The idea that PA is a pass / fail exercise, and that it can be used to force remedial work, is widespread.
However as you noted it's contrary to the clear intent of ESR 113; which is an example of the 'no mandatory upgrades" doctrine that underpins most NZ law.
And if we look back over the history of the words used, they have never (since introduced 1993) supported anything more than a simple assessment & report. 1993 R.39 called it a "safety check".
The certificate if re-inspection under ECP 1 only certified that the place had been inspected, not that it met any particular criteria.
However the (non-mandatory) example record of checks / tests included tick boxes for "pass" & "fail" (instead of 'yes" & "no") beside each benchmark; and I believe that's why many have assumed that assessors had some sort of power to require remedial work before issuing the certificate.
Mandatory upgrades are only ever imposed for specific items; and based on evidence of improved safety outcomes.
The last one I know of in our game was (1987) when caravans were forced - via WoEF provisions - to change from old Reyrolle supply fittings to modern plastic types.
As far as I can tell, the corresponding change for caravan parks was never officially mandatory; it certainly wasn't in the relevant amendment to 1976 Regs.
So it would have been just a natural consequence of wanting to be able to supply caravans with the new style plugs.
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