The testing and tagging of portable electrical appliances is one element of electrical safety that has caused confusion since its inception.
The wide spread confusion is concerning when you consider a total of 1037 electric shocks and 4 electricity related deaths were reported in one year alone. Even in the highly regulated mining industry, electric shocks are the third reported accidents and causes of injury.
The lack of understanding may stem from the current OH&S legislation. Each state has differing OH&S legislation, and in some circumstances, there is also Electrical Safety legislation to consider.
For companies with sites in multiple states, deciphering this legislation and the corresponding references to a variety of Australian Standards is a mammoth task.
So, what actually are the obligations for the Hotel Industry? And who is ultimately responsible for OH&S in the growing Serviced Apartment sector?
Beginning with the Australian Standards, the Standard that applies for the majority of the Hotel and Accommodation industry is AS/NZS 3760:2003 In-Service Safety Inspection and Testing of Electrical Equipment.
This standard specifies the safety inspection standards for Australia and provides details of how to comply with state specific OH&S legislation.
AS/NZS 3760:2003 defines an appliance as any portable electrical item that can be plugged into a power point. It recommends that appliances be inspected at regular intervals ranging from six months through to five years.
In order to comply with requirements, all businesses should have the following in place:
- A test tag attached each tem indicating date, item, person performing the test, and status (pass/fail) of test
- An asset register and historical record of all test items and test results
- A record of results including faulty items and repair action
More specifically for the Hotel and accommodation industry, it recommends that all appliances, extension leads and cord sets be inspected at two yearly intervals, and RCD’s be inspected and tested at 6 monthly intervals.
Putting aside the legislation, Appliance Tagging Services firmly views testing and tagging as an investment in your business.
More than 1200 fires every year in Australia are attributed to electrical fault and dozens of people have serious electrical accidents due to poor maintenance of appliances.
In fact, faulty electrical appliances and leads are the main cause of accidental fires in commercial buildings.
Business should look at testing and tagging in the same light as insurance – you never know its value until you really need it.
In the company’s experience of “first round” testing, it finds up to 10% of all electrical items fail the testing procedure. The fact that up to 10% of electrical items in businesses across Australia are accidents waiting to happen is concerning.
In some states, testing and tagging of portable electrical appliances is legislated. While all state regulators have the minimum 'duty of care' requirement for employers and business owners, some of Australia's states have more specific requirements when it comes to testing and tagging.
For example, in Queensland, the legislation covering Testing and Tagging in the Hotel and Accomodation industries is prescribed in the comprehensive Electrical Safety Act 2002 and Electrical Safety Regulations 2002.
The Hotel and Accommodation industries fall under the Class of Service Work (formerly Class 3) and the requirements are simple.
Under the Regulations, Testing and Tagging should be completed on an annual basis for all portable electrical items, or electrical items in a hazardous environment, unless they are ALL connected to a RCD or Safety Switch. The RCD or Safety Switch must also be tested in accordance with AS/NZS 3760.
In South Australia, the Occupational Health Safety and Welfare Regulations 1995 state all portable electrical items whose supply of electricity is through a socket outlet must either be Inspected, Tested and Tagged in or connected to an RCD.
Fixed RCD’s are then to be tested annually, and portable RCD’s tested in accordance with AS/NZS 3760.
The other states are far less specific. The OH&S Regulations may refer to a Duty of Care to provide a safe workplace, or prescribe Testing and Tagging should be completed on portable electrical appliances in a hostile environment.
A hostile environment is an environment where under normal operating conditions there is a likelihood of damage to the portable electrical appliance. For example, an environment exposing the item to moisture, heat, vibration, corrosive substances or dust is likely to result in damage to the electrical appliance.
Recently there has been a lot of publicity surrounding an amendment to the NSW legislation centred on Testing and Tagging. This amendment has not altered any of the actual testing practices, but rather the extent to which appliances should be tested.
The publicity surrounding this amendment was focussed around Risk Assessments and many argue this has simply added another dimension to the confusion.
Risk assessments need to be done annually, and should be completed by a qualified individual, and not just the office manager. Risk assessments also need to be correctly documented and must stand up to scrutiny should the business be the subject of an investigation.
In the company’s experience, the majority of businesses find it easier to out source the management of their electrical appliance safety obligations than worry about managing ongoing internal risk assessments.
It is important to remember, the risk of an Electrical accident and possible fatality is a real and frightening possibility in every workplace in Australia.
This raises the question, should any business take the risk with risk assessments? The answer may be yes, we believe it needs to be carefully thought through.
The NSW Workcover authority highlights a case study where an employee was using a steam-cleaning unit to clean carpets in a restaurant.
The unit was located in a van and the restaurant provided power via an extension cord. Sections of the insulation protection of the power cord were damaged.
The damaged lead came in contact with carpet that had become wet during filling from the water tank in the van. The employee stepped on the carpet and tragically was electrocuted.
In another case, a youth was fatally electrocuted in a franchised retail food chain whilst cleaning a piece of portable electrical equipment.
Under NSW legislation, not only was the franchisee liable for prosecution, the franchisor was also prosecuted.
Recent revisions to the Victorian Occupational Health and Safety Act 2004 have brought the Victorian legislation in line with areas of the NSW legislation.
The revisions highlight the fact that the requirements for providing a safe workplace is something that cannot be delegated or outsourced to another party, it is the responsibility of all involved in the operation, supply or design of the business.
This has a huge impact on the Serviced Apartment industry where many apartments are privately owned and then managed by a larger corporation.
While responsibility for OH&S may lie with the owner of the apartment, responsibility must also lie with the larger corporation whose brand name, apartment design and the like are used by the apartment owner.
Importantly, regardless of your State of operation, there is still no excuse for business should an injury or fatalities occur due to an electrical fault.
A court of law could still bring up the relevant standard as a minimum benchmark of safety, even though the standard may not be written in legislation.
Would not it be cheaper to have one of your employees carry out testing and tagging?
Although you may believe purchasing your own portable appliance test equipment and having in-house staff carry out the testing may be more cost effective, there are several factors to bear in mind.
Firstly, you would need to ensure that the requirement of competence is met, which will undoubtedly involve expenditure in training.
Secondly, you need to purchase the equipment and the software, and gain the expertise in its use.
Appliance Tagging Services finds that many companies who have tried to carry out testing in-house also take more time to do the testing as staffs generally completes this as an “add-on” to their job, and do not have the experience to minimise the disruption factor in shutting down equipment, nor the disciplines to maintain retesting schedules.
Finally, equipment is also required to be calibrated annually and maintained, adding another expense and management task to the employee charged with the “testing and tagging” role. And do not forget, as soon as the trained employee resigns, or moves up through your organisation, you will need to go through the whole training process again.
In the age of outsourcing of everything from training to cleaning, when you add it all up, Appliance Tagging Services has found business to be on average 20% better off financially when outsourcing their testing and tagging.
The financial benefits whilst impressive are no where near as impressive as the professionalism and quality of service as provided by some of the Testing and Tagging companies operating across Australia.
Many operate in all states of Australia, offer a repair or replacement service, and have a team of administrative and operational staff dedicated to manage your data reporting and retesting compliance.