Business electrically testing their awnings

[downtoearth]

Hi all,

I've stumbled upon a tricky situation and need some advice. I attended a small business to conduct electrical works and the business in question currently make their own 230v awnings. At the moment when they make them they need to test the units to make sure they work correctly. To do this they currently have a handheld 230v controller which is constructed in the following manner:

230v 3 pin plug - Up/down controller - 3pin female - 3 pin male - 3 core cable with push in connectors.

The push in connectors connect to the bare end cable of the units which they then energise and check to ensure they work. My understanding as outlined in ESR (Schedule 1) 1(1) , 2 is that this is prescribed electrical work. It is not exempt as these works are not done without payment nor are they exempt because they are not done in relation to a ELVS.

There must be a number of business in NZ that need to connect their appliances/items to 230v to make sure they work before having them sold so my question is am I correct and if so is there some regulation around this or a manner in which this can be setup so they can test their units without requiring someone on site who is suitably qualified ie an Electrician or Service Tech?

[AlecK]

It's covered in Schedule 1 of ESRs; which defines what is - and isn't - PEW.

Probably time you reviewed this, as it's clear your understanding is well out of date.
You mention that not being done for hire / reward might have made the work exempt.
Hire / reward is a factor for some types of work, as per clause 2(a) & (n). But just not being paid has never made it OK to do PEW in general; and in particular was never a factor in whether this sort of activity activity is PEW.
Under earlier versions of Act & Regulations, hire / reward was a factor in whether a current PL was needed to do some sorts of PEW. Registered but unlicenced persons could do some work provided there was no hire / reward involved. That allowed "retired" electrical workers to do limited sorts of of charity work without needing to do refresher courses & hold a PL. That provision was revoked many years ago; making a PL required for all PEW not done under a direct Exemption in the Act (Sections 75 - 80).

The work these people are doing falls under clause (2)(m) of Schedule 1; being "temporary conductors", for purpose of "testing", in a "manufacturing facility".
Accordingly the work is not PEW.

[downtoearth]

Thanks Alec. I was confused due to the layout of the ESR and whether the sub heading Extra-low voltage was a continuation onto Testing, Teaching, Experimenting. You have now clarified and relieved me of my uncertainty. I personally don't agree with non-qualified personal being granted the capacity to do such works as these will always pose an inherent risk to the undertaker.

[Peter]

'inherent risk to the undertaker." ....... well said probably not much risk to the " undertaker " ( the undertaker may burry someone here ) maybe more risk to the end user ?

[AlecK]

Every paragraph within Clause 2 of Schedule 1 stands alone; and can be read without reference to any other paragraph.
However they have been arranged in groups; each group being given a heading indicates something in common.
The section headings are intended to help us find the relevant paragraph.
Some of these 'groups' only include one para; others 2 or 3.
For example paras (b), (c), & (d) all relate to various aspects of ELV; while paras (m) & (n) relate to "testing, teaching, experimenting etc".

The other key thing is that Clause 2 over-rides Clause 1.
The activities in Clause 1 are PEW... UNLESS the particular form of the activity in question is listed in Clause 2.

That's the same sort of structure (in reverse) as for risk classifications in ESR 6A; where the PEW listed in Clause 2 is high risk UNLESS Clause 1 has classified it as low risk.

I agree there are risks associated with this sort of product testing. But such risks can - and should - be managed via WHS procedures.
ESRs / PEW are concerned primarily with safety of finished works / installations / products; ie risk to end users and the public.
Requiring a PL for such product testing would be excessive., when an adequately safe outcome could be achieved by using appropriate test equipment and methods - neither of which appear to be in use in this case.

Equipment would include a connection box with cover over terminal; closing the cover livens the A & N terminals and opening it switches them off.
Also an insulation tester and earth continuity tester.