Exam and legal
Introduction to PAT
PAT testing or portable appliance testing is an very important part of any company health & safety policy. This page is intended as a guide only to both the technical requirements and the legal implications of PAT Testing.
According to The Health & Safety Executive, around 25% of all reportable electrical accidents involve portable appliances. The Electricity at Work Regulations place a legal responsibility on employers, employees and self-employed persons to comply with the provisions of the Electricity at Work regulations and take all reasonable steps to ensure that no danger arises from the use of such equipment. Thus, in effect, a systematic and regular program of maintenance, inspection and testing is required. The Health & Safety at Work Act (1974) places this obligation in the following circumstances:
• Where portable appliances are used by employees.
• Where the public may use portable appliances in establishments such as schools, hospitals, shops and hotels etc.
• Where appliances are repaired or serviced.
• Where appliances are supplied or hired.
The level of inspection and testing requirement depends upon the level of risk of the portable appliance becoming faulty, which is in turn dependant upon the type of portable appliance, the nature of its use and the environment in which the appliance is used.
The publication the "Code of Practice for In-service Inspection and Testing of Electrical Equipment" (ISBN: 0-85296-776-4), published by The Institution of Electrical Engineers (the IEE) is a guide that forms the basis for portable appliance testing (PAT) in the U.K.
The legislation that is relevant to portable appliance testing include the Health & Safety at Work Act 1974, the Electricity at Work Regulations 1989, the Management of Health & Safety at Work Regulations 1999, the Workplace (Health, Safety and Welfare) Regulations 1992 and the Provision and Use of Work Equipment Regulations 1998.
The Health & Safety at Work Act 1974 puts the duty of care upon both the employee and the employer to ensure the safety of all persons on the work premises. This also applies to the self employed.
Specifically, the ‘Provision and Use of Work Equipment Regulations 1998’ states that:
"Every employer shall ensure that work equipment is maintained in an efficient state, in efficient working order and in good repair."
This is just one example of one piece of legislation relevant to PAT testing and it is clear that there is a legal requirement to inspect and test all types of electrical equipment in all work situations.
The Provision and Use of Work Equipment Regulations 1998 (PUWER) places a requirement on every employer to ensure that available work equipment is suitable for the purpose for which it is provided and only used in the place and under the provisions for which it is provided. Further, every employer is required to ensure work equipment is effectively maintained and kept in a condition suitable for its intended purpose. The equipment must not be allowed to deteriorate in performance or function to such a level that it puts people at risk. This calls for regular, routine and planned maintenance regimes.
Regulation 3 of the Electricity at Work Regulations 1989 recognises the responsibility that employers and also many employees may have for electrical systems.
"It shall be the duty of every employer and self employed person to comply with the provisions of the Regulations in so far as they relate to matters which are within his control.
It shall be the duty of every employee while at work:
(a) to co-operate with his employer so far as is necessary to enable and duty placed on that employer by the provision of the Regulations to be complied with: and
(b) to comply with the provision of these regulations in so far as they relate to matters which are within his control."
What is a Portable Appliance?
Although there is no specific definition of a portable appliance, it is generally accepted that portable appliance equipment is usually either hand held whilst connected to an electricity supply, or is intended to be or capable of being moved whilst connected to the supply.
The definition of a portable appliance, according to The National Association of Professional Inspectors and Testers (napit) is 'any electrical item which can or is intended, to be moved whilst connected to an electrical supply.'
An appliance of less than 18kg in mass that is intended to be moved whilst in operation or an appliance which can easily be moved from one place to another, e.g. vacuum cleaner, toaster, food mixer, etc.
Transportable or movable equipment
This equipment is either:
a weight of 18 kg or less and not fixed, e.g. electric heater
Equipment with castors, wheels or other means to facilitate movement by the operator as required to perform its intended use, e.g. portable air conditioning unit
Hand held appliances or equipment
Defined as portable equipment intended to be hand held during normal use, e.g. hair dryer
Stationary appliances or equipment
This is defined as equipment with a weight exceeding 18kg and not provided with a carrying handle, e.g. Washing machine, refrigerator
Fixed appliances or equipment
This is defined as equipment or an appliance which is fixed to a support or otherwise secured in a specific location, e.g. bathroom heater
Equipment or appliances for building in
This is defined as equipment which is intended to be installed in a prepared aperture or recess such as a cupboard or similar. In general, equipment or appliances designed for building in, does not have exposure on all sides because one or more of the sides are covered or built in, which provides additional protection against electrical shock. e.g. built in electric cooker
Information technology (IT) equipment
IT equipment includes electrical business equipment such as mains powered telecommunications equipment, computers, and other equipment for general business use, such as monitors and photo-copiers etc.
Frequency of Testing
The are no definitive rules offered by the Health & Safety Executive offers on how often the testing and inspection of portable appliances should occur. The Memorandum of Guidance on the Electricity at Work Regulations suggests that 'regular inspection of equipment is an essential part of any preventative maintenance program', but there is no attempt is made to define the meaning of the word 'regular' as applied in this case. There may be a clear reason for this omission. Depending on the situation, different measures may be needed to to ensure that the danger is prevented. The factors which affect how often the portable appliance is tested must be assessed by the duty holder who is responsible for making the judgement.
In making his/her decision as to the frequency of testing, a duty holder is likely to take into account the following factors:-
A) The environment - portable appliance equipment installed in a benign environment is likely to suffer less damage than portable appliance equipment in a harsh environment
B) Users - if the users generally report damage to the appliance as and when it becomes known, hazards are likely to be avoided. Conversely, if equipment is likely to receive unreported abuse, more frequent inspection and testing would be called upon.
C) The equipment construction - the safety of a Class 1 portable appliance is depends upon a connection of the electrical installation to earth. If the flexible cable gets damage, the connection with earth can be lost. The safety of Class 2 equipment does not depend upon the fixed electrical installation to earth.
D) The type of equipment - portable appliances which are hand held are generally more likely to get damaged than fixed appliances. If they are a Class 1 appliance, the risk of danger is increased, due to the fact that the safety is dependant upon the continuity of the protective conductor from the plug to the appliance.
Assessment of risk
There is a simple calculation which can provide an estimate of the level of risk of electrical appliances.
Starting with a Base Risk of 0 points, add:
• 2 points if the appliance is to be used in a wet or corrosive environment or uses water or a corrosive substance in its operation. (e.g. Kettle)
• 2 points if the appliance has a flexible supply cord that is subject to flexing or that is subject to harsh treatment.
• 1 point if the appliance has a heating element OR 240V electric motor.
If the total is 2 points or more it is classified as group A, High Risk
If the total is 1 point it is classified as group B, Medium Risk
If the total is 0 points it is classified as group C, Low Risk
This web page deals with in service testing only, which is the routine testing of an electrical appliance to determine whether the appliance is in a satisfactory condition.
In-service testing will involve the following:
(1) Preliminary and visual inspection
(2) Earth continuity tests (for Class 1 equipment)
(3) Insulation testing (Which can sometimes be substituted by earth leakage measurement)
(4) Functional checks.
Portable appliance testing should only be performed by a person who is competent in the safe use of the test equipment and who can interpret the results obtained from the testing. The person must be capable of inspecting the appliance and if necessary, dismantling it in order to check the cable connections.
If the appliance is permanently connected to the fixed installation, for example by a flex outlet or other accessory, the accessory will need to be detached from its box or enclosure so that the connections can be inspected. This should only be carried out by a competent person.
Who should PAT test ?
A quote from the Electricity at Work regulations:
"No person shall be engaged in any work activity where technical knowledge or experience is necessary to prevent danger, or where appropriate, injury, unless he possesses such knowledge or experience, or is under such degree of supervision as may be appropriate having regard to the nature of the work"
The IEE Code of Practice states, that any person carrying out inspection and testing must be competent and have due regard of their own safety and that of others. The danger which is to be prevented, includes not just the danger which may arise to the tester and others during the testing procedure, but also the danger which may arise at a later date as a result of a person using equipment which has not been effectively tested.
The portable appliance tester must have an understanding of the modes of electrical, mechanical or thermal damage to electrical equipment and appliances and their flexes which may be encountered in any environment.
Training of the person responsible for testing must include the identification of equipment and appliance types to determine the test procedures and frequency of inspection and testing for such equipment. Persons involved in testing must be familiar with the testing equipment used and in particular their restrictions and limitations, so as to achieve repeatable results without damaging either the equipment or the appliance.
The results of formal visual inspections should be documented and only be carried out by persons competent to do so.
The following must be considered when carrying out the visual inspection:
Suitability of the equipment and it’s environment
The electrical equipment should be assessed for its suitability for it’s environment or the nature of the work being undertaken. If the work environment is hazardous or harsh, particular care needs to be taken when selecting the equipment and assessing the frequency of inspection and testing of the equipment.
A check should be made to ensure the electrical equipment is installed and is being operated in accordance with the manufacturers instructions. The following are examples of items which should also be checked:
1) Cables located so as to avoid damage
2) Means of disconnection or isolation readily accessible
3) Adequate ventilation for the electrical equipment
4) Drinking cups, plants and work material etc. correctly placed to avoid spillage
5) Equipment positioned to avoid strain on cord
6) Equipment is being operated with all covers in place and any doors are closed
7) Over use of multiway adaptors and/or trailing sockets is avoided
8) No unprotected cables running under carpets
Disconnection of equipment
The means of isolation or disconnection from the electricity supply must be readily accessible to the user, i.e. in normal circumstances it must be possible to reach the plug and socket without to much difficulty.
The condition of the equipment
Prior to the commencement of portable appliance testing, the users should be asked if they are aware of any faults and if the equipment works correctly. The following items need to be inspected:
(a) The flexible cable
(b) The socket outlet (if known)
(c) The appliance
(d) The plug head
Some of the following checks may not be possible for electrical equipment fitted with a non re-wirable plug.
a) Check that any detachable power cords to Class 1 equipment incorporate a CPC
b) Identify any signs of overheating
c) Internal inspection including; cord security, polarity, connections
d) If non re-wirable plug; cord security, any burning odours
e) Correct size fuse fitted, BS marked, ASTA marked
f) Security of plug cover
g) Check the flexible cable connections and anchorage at the equipment, if practical