Can I veto PAT testing

Ive been asked to install a small CCTV system in a harbour authority's building. Nothing special, all 13A plug-in ELV stuff.

I suspect that there will be one or more jobsworths who insist that all the stuff is PAT-tested before it crosses the threshold etc.

Can anyone advise what the actual "law of the land" is regarding supplying equipment in this manner?

I believe that:
PAT testing "may or may not" be part of an organisation's proprietary operating procedures.

If it is, then a record of equipment which is PAT-tested must be kept.
(I am interested to know how the practicalities of keeping records of individual IEC cables and other cables without identifiable features works)

Any equipment which does not plug directly into mains MUST NOT be PAT-tested. (this including most consumer electronics which operates via external ELV SM or linear PSU)

is any of the above corrrect?

My own operating procedures exclude any PAT testing based mainly on one bad experience when I PAT tested a PC which caused it to never boot again.

Therefore, I want to be able to plug the gear in, check it is operating OK and then sign over ownership of the gear. (at which point they can PAT test it all they like)

also, as the equipment will be permanently installed, screwed down, using tywraps and conduit, does it still classify as "portable" simply because it is using 13A plug-in connectors?

SparkyTris said:

I believe that:
PAT testing "may or may not" be part of an organisation's proprietary operating procedures.

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I believe that too, from the legal point of view but if the organisation you're working for has an in-house procedure then it's up to them not the law how they enforce it. If organisation "X" won't allow me into their venue without procedure "Y" being complied with, there's nothing much I can do about it legally. Perhaps a disclaimer or some kind of written agreement is the way forward?

If it is brand new kit then the HSE say it doesn't need tested, just a visual check.

Source here: http://www.hse.gov.uk/electricity/faq-portable-appliance-testing.htm

SparkyTris said:

I believe that:
PAT testing "may or may not" be part of an organisation's proprietary operating procedures.

Click to expand...

While there is no direct legal requirement to perform in service testing of electrical equipment there is a requitement to take reasonable steps to ensure safety of electrical equipment.

If it is, then a record of equipment which is PAT-tested must be kept.
(I am interested to know how the practicalities of keeping records of individual IEC cables and other cables without identifiable features works)

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I'm not sure if that is strictly true but in practice without keeping records of what equipment you have tested it would be very difficult to make a definitive statement on whether the peice of equipment that had just killed/injured someone had been subject to appropriate testing.

Normally equipment is labelled with numbered stickers and the numbers are referenced in the records.

Any equipment which does not plug directly into mains MUST NOT be PAT-tested. (this including most consumer electronics which operates via external ELV SM or linear PSU)

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Never heard this claimed before, reeks of BS to me.

My own operating procedures exclude any PAT testing

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If (unlikely as it is) someone comes to harm due to your electrical equipment you will find it very hard to defend yourself with a policy like that.

based mainly on one bad experience when I PAT tested a PC which caused it to never boot again.

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This sounds like a typical case of "shooting the messenger". If equipment fails after a correctly conducted PAT test with an IR test at a reasonable voltage (flash tests are a different matter and should not normally be carried out in routine testing) then it almost certainly means that there was a serious fault with it in the first place.

Therefore, I want to be able to plug the gear in, check it is operating OK and then sign over ownership of the gear. (at which point they can PAT test it all they like)

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Either you are worrying unnessacerally or you are installing dangerous sh1t that should never have been imported into the EU in the first place.

also, as the equipment will be permanently installed, screwed down, using tywraps and conduit, does it still classify as "portable" simply because it is using 13A plug-in connectors?

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Not being portable doesn't take away the need to take reasonable steps to ensure the equipment is safe.

From the HSE link John W2 posted

Is Portable Appliance Testing Compulsory?

No. The law simply requires an employer to ensure that their electrical equipment is maintained in order to prevent danger. It does not say how this should be done or how often. Employers should take a risk-based approach, considering the type of equipment and what it is being used for. If it is used regularly and moved a lot e.g. a floor cleaner or a kettle, testing (along with visual checks) can be an important part of an effective maintenance regime giving employers confidence that they are doing what is necessary to help them meet their legal duties. HSE provides guidance on how to maintain equipment including the use of PAT.

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westie101 said:

From the HSE link John W2 posted...

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You appear to have a better memory than I do

Kind Regards, John

No qualification is Required to PAT test so just sign your own labels and stick them on.

OK down to the real world. I was stopped from bringing my own computer into collage because it was not PAT tested.

That night I tested, yes I did go through the motions, my PC and wrote out the certificate and stuck on a label.

Next day asked lecturer who needed to see the certificate. At this point it became plain the idea was just to stop me using my own PC and PAT testing was not required.

In the main it's a jobs worth who wants to show he is doing his job and it's nothing to do with legal requirements. So stick a label on and he is satisfied.

Should there be a real fault on your equipment then it really does not matter label or no label the HSE will want to know why it was in use. So any equipment clearly sub-standard should not be taken on site.

What the HSE require is that equipment is inspected in a manor that will result in sub-standard equipment being taken out of service and are not really worried on how this is achieved as long as it is.

Now PAT testing is a two part system. One is a visual inspection and the other is a instrument test result. So if you generate a form and tick the visual part and fill in a label to show you looked for faults in the main this is good enough.

In real terms 95% of faults can be seen and don't require a test instrument to find them. In the main just common sense.

Clearly if you miss something and some one is injured your up the creak without a paddle. But this is rare.

So in real terms PAT testing is passing the buck. Once done something goes wrong and you have some one to point your finger at.

No you don't, the item was fine when i tested it…… said the tester, how do you prove it wasn't ?


DS

SparkyTris said:

Any equipment which does not plug directly into mains MUST NOT be PAT-tested. (this including most consumer electronics which operates via external ELV SM or linear PSU)

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This makes sense. The idea or an insulation test at 500v on a piece of 12v equipment is horrifying. Anyway much ELV equipment has one side of the supply connected to the case.

You do of course PAT the wall wart supplying it but not with said wall wart connected to the equipment.

Portable Appliance Testing is merely a procedure used to indicate that there are systems in place to maintain the safety of the electrical equipment used in the workplace (or in rented accommodation where that equipment is provided by the landlord). As has been stated, most faults will be obvious on visual inspection, but, as a PAT Tester, I have found any number of cheap and nasty Chinese import IEC leads (usually C5, but not always) which cannot achieve a sufficiently low earth bond value to pass. These leads are clearly marked 0.75mm². If the individual cables are bigger than 0.25mm², then I'm a Dutchman! It is cases like this where someone could get a nasty belt (at best) that Portable Appliance Testing should (!) pick up.

I print the test results on the PAT label, (e.g. 40mΩ/>20MΩ/0.12mA for Earth Bond, Insulation and Leakage Tests) so in the event of query, the previous test result can be viewed without referring to the "register".

A comment was made regarding recording the testing of IEC leads. It is clearly impractical to give each lead an individual identification, so I lump them all together (by IEC connector type), and note the equipment the lead is used with. As I print the test result on the label, it can be cross referenced with the entries in the database.

I also test new equipment (see comment above re: IEC leads!) to be sure that my back is well and truly covered!

PUWER

SparkyTris said:

I believe that:
PAT testing "may or may not" be part of an organisation's proprietary operating procedures.

Click to expand...

As the electrical engineer it was up to me to ensure all items on site were either in quarantine or safe to use.

Some one bring an item on site which was not safe, it was up to me to show I took reasonable measures to ensure this did not happen.

If it was a contractor then it is reasonable to assume labels showing the items had been PAT tested that they were safe. However should I find this not to be the case then it would be expected that I then took little notice of the labels and did something else instead.

Remember I am watching my back. So I could decide to do random tests on contractors equipment or test every piece of contractors equipment. If I fail in my duty of care then not only the contractor ends up in court so do I. The site was under my care.

This is a problem with all sites. I have had the roles reversed and working for a construction company we had all our equipment PAT tested by the electrical installation company working on the same site. If they found an item which was faulty they removed it from service and would dump them in my quarantine area. This is where it all gets messy once any piece of equipment is repaired if needs PAT testing before being returned to service so for example a worker will come in with a rotor brooch wanting repair at 1 am I repair and test and enter the results on my records. I give it a 3 month ticket.

However the electrical firm who should test it will have it on their records it needs re-testing in 1 month. It happened that we both used top of range Robin testers so every week my floppy disk would be given to the electrical firm which in seconds then updated their records showing I had tested the item.

But for that to work they needed all the info on me and had all my qualifications on their data base. They had to trust me as if I did the job wrong not only me in court but also them.

Now were hear the phrase "Let the court decide" this means some one in the court will in the case of it all going wrong will decide who was to blame. It is not always who one expects. In the Emma Shaw case it was not the tester found guilty or the person causing the fault but the foremen who it was decided used labour who were not trained to the level required to do the work.

It of course only ends up in court when something goes really wrong.

I was involved in a case where a mechanic had a personal extension lead in his locker, another worker stole this lead to run a space heater which I as the electrical engineer on site had said was unsuitable for the area and had requested the buyers to get a 110 volt model. The worker had opened up a panel to get access to the socket used for running the laptop when altering the PLC program and was using the extension lead to run the space heater he had taken from another department.

The extension lead was faulty and a separate worker got a shock. He was automatically taken to hospital for tests who automatically informed HSE who arrived on site.

To my mind the worker who had stole the extension lead was at fault. However this is not what the HSE thought. They blamed the mechanic for bringing the lead on site. I tried to argue with HSE that taking the lead from a locked locker was the same as taking it from my quarantine area. However since there was no sign saying quarantine area do not remove any equipment they insisted the mechanic was at fault for having the lead on site. However he was in the end only give a warning and not fined. The HSE did accept it was not reasonable for the mechanic to expect some one to steal from his locker but felt he had lied and he had told the worker he could use the leads.

I also got in trouble for leaving keys in electrical panels which although nothing dangerous in that panel, could be removed and used to open another panel allowing the worker access to a 13A socket.

Returning to PAT testing when one PAT tests any item you log where it was when tested. So find a table lamp in an office and PAT test would likely last a year, but take the same lamp and put it on the fitters bench then test would likely be for 3 months. So really bringing equipment on to site with a PAT test label means nothing it needs to be tested in respect to the working environment.

Clearly if you hire a kango from a tool hire shop they expect it to be used in a harsh environment and it would only have a 3 month ticket. But an IEC lead set could have a test anywhere from 3 months to 4 years depending where used. I had a big problem with C7 IEC 60320 lead set (figure of eight) used on radios. In the Office not a problem but on the factory floor these could be unplugged and left dangling in pools of water. On the factory floor the lead needed to be fixed to the radio not a lead set.

On every site some one is the manager and is responsible for ensuring site safety. It is down to him to decide how he is going to do this. With for example a small shop some one may come in and test everything on same day and write out a report without using any labels on any equipment. It is up to the site manager everyone else has to do as they are told.