[committee] Fwd: UCC 'test-and-tag'

Mark Tearle mtearle at ucc.asn.au
Thu May 23 16:25:19 AWST 2019 

Hi Tim, et al

Just stepping through the regulations, etc that Maja has quoted. All of these are downloadable from www.legislation.wa.gov.au


*Occupational Safety and Health Regulations 1996**
*

3.59. Electrical installation etc., duties of employer etc. as to 

A person who, at a workplace, is an employer, the main contractor, a self-employed person or a person having control of the workplace must ensure that — (a) all *electrical installations* at the workplace are designed, constructed, installed, protected, maintained and tested so as to minimise the risk of electrical shock or fire; and (b) each connection on a flexible cord that is installed or renewed at the workplace after 1 October 1996 is of either the moulded one part non-rewireable or transparent type. Penalty: the regulation 1.16 penalty. [Regulation 3.59 amended: Gazette 14 Dec 2004 p. 6018.]


The active clause here is a) and the key phrase is "all *electrical installations*"

Part 1 — Preliminary and interpretation Division 1 — Preliminary and definitions 1.3. Terms used ... of the regulations provides that definition:

*electrical installation* has the meaning given in the Electricity (Licensing) Regulations 1991 regulation 3(1);



*Electricity (Licensing) Regulations 1991**
*

Part 1 — 3. Terms used (1) In these regulations, unless the contrary intention appears — ....

*electrical installatio*n means — (a) an installation (as defined in the Electricity Act 1945 section 5(1)); or (b) the network of an exempt operator, other than an exempt operator that is a major network operator; or Electricity (Licensing) Regulations 1991 Preliminary Part 1 r. 3 As at 09 Jan 2019 Version 07-l0-01 page 3 Published on www.legislation.wa.gov.au (c) the network of a person who is a network operator under the Electricity (Network Safety) Regulations 2015 regulation 4(1)(h);


a) being the relevant clause again ...


*Electricity Act 1945 Part I Preliminary s. 5**
*

*installation *includes all wiring, wiring enclosures, switch gear, control and protective gear, appliances, and other components permanently connected to or associated with the wiring, on premises to which electricity is or is intended to be supplied through distribution works, and where electricity is supplied from a private generating plant includes that plant;


The key part here being "permanently connected to or associated with the wiring"



I'm not necessarily sure they are taking a correct interpretation of the legislation and regulations.


Mark
--

Mark Tearle <mtearle at ucc.asn.au>


On Thu, 23 May 2019, at 6:31 AM, Timothy Chapman wrote:
> Hi interested parties,
> 
> This reply of mine missed the committee@ cc, so here's it forwarded.
> 
> Timothy.
> 
> ---------- Forwarded message ---------
> From: *Timothy Chapman* <22483878 at student.uwa.edu.au>
> Date: Thu, 23 May 2019, 12:18 pm
> Subject: Re: [committee] UCC 'test-and-tag'
> To: SOC <soc at guild.uwa.edu.au>
> Cc: Grace Rosario <20483992 at student.uwa.edu.au>, Hinako Shiraishi 19 <soc-president at guild.uwa.edu.au>
> 
> 
> Hi Maja,
> 
> Thank you for your reply. It's very helpful to actually see the regulations you'd like us to comply with. A quick point of clarification that I feel must be made:
> In §3.59 I see the requirement for all electrical equipment to be "tested", however I fail to see why that must specifically refer to 'test-and-tag'.
> 
> If you could elucidate this point it would be much appreciated,
> 
> Timothy.
> 
> On Thu, 23 May 2019 at 11:45, SOC <soc at guild.uwa.edu.au> wrote:
>> Hey UCC,

>> 


>> Thank you for taking such a keen interest in our regulations!
>> 

>> Please see attached WA OCCUPATIONAL SAFETY AND HEALTH REGULATIONS – REGULATION 3.59 which states that “all electrical installations at the workplace are designed, constructed, installed, protected, maintained and *tested* so as to minimize the risk of electrical shock or fire”; and REGULATION 1.16 which outlines the penalties for this.

>> 

>> I believe WA Occupational Safety and Health Regulations would supersede UWA Electrical Safety Guidelines.

>> 

>> It is worth noting that in general, the tags last up to 5 years depending on the type of equipment, so this cost would not annual. Hope this was of help!

>> 

>> 

>> Warmest Regards, 

>> 

>> ***Maja Maric *

>> SOC Communications Committee

>> UWA Student Guild

>> 

>> 

>> 
>> 
>> 
>> *From:* Grace Rosario <20483992 at student.uwa.edu.au>
>> *Sent:* Thursday, May 23, 2019 9:33 AM
>> *To:* Timothy Chapman
>> *Cc:* Hinako Shiraishi 19; SOC; committee
>> *Subject:* Re: [committee] UCC 'test-and-tag' 
>> 
>> Hello SOC,
>> 
>> I'm not sure if this (picture attached) really constitutes a response to our email, since it didn't get sent to the committee, just to one member, and used a personal Facebook account to communicate. So I'm pretty sure, at least, that this is not an official response.
>> 
>> I'm not sure that we were clear enough in our last email, but could somebody please link us to the safety standards of the guild, which are apparently separate from the UWA regulations. I have looked on the guild website and this information is not available to me anywhere that I can see.
>> 
>> The UCC committee would like to view the policy that they are being asked to comply with.
>> 
>> Best regards,
>> Grace Rosario
>> UCC Secretary
>> 
>> 
>> image.png
>> 
>> On Wed, 22 May 2019 at 23:47, Timothy Chapman <22483878 at student.uwa.edu.au> wrote:
>>> Dear SOC,
>>> 
>>>  Speaking on behalf of the UCC committee, we have recently received your request to 'test-and-tag' all of our plugs. We would appreciate it if you could please outline why this is *necessary*.
>>>  UCC has (as you would expect) a very large number of electrical devices, and so, such a requirement is exceptionally onerous for the club — to the tune of several hundred dollars per year.
>>> 
>>>  Examining the UWA Electrical Safety Guidelines <http://www.safety.uwa.edu.au/topics/electrical-safety/testing-tagging-guidelines>, we were able to identity the section of the requirements this seems to be a result of.
>>> 
>>> *"UWA uses a risk management approach to determine where specific testing of electrical equipment is necessary. This is achieved by defining workplaces as hostile or non-hostile electrical environments and then specifying the required frequency of either Visual Inspections or Testing and Tagging"*
>>> 
>>>  While it seems good for the clubs on UWA to follow the UWA safety rules, we note that the regulations split environments into two categories: Hostile and Non-hostile.
>>>  The requirement of "Testing and Tagging" *exclusively* refers to "hostile environments". According to those regulations a *non-*hostile environment is defined as follows:
>>> 
>>> *"This is a workplace that is dry, clean, well organised and free of operating conditions that may result in damage to electrical equipment or the flexible supply cord."*
>>> 
>>>  We are strongly of the impression that UCC firmly fits into the category of *non-hostile*, and as such this requirement seems to be unnecessary.
>>>  >From your request, we can only conclude that you have classified UCC as a hostile environment. 
>>> 
>>>  Would it be possible to get a thorough and well justified explanation for why UCC has been singled out and identified? *(see email from Taco Shiraishi on May 15)* Since if we were to go ahead with the tagging, UCC appears to be expected to pay a significant sum out of pocket for superfluous electrical testing.
>>> 
>>> 
>>> Looking forward to your reply,
>>> 
>>> Timothy Chapman
>>> UCC Ordinary Committee Member
>>> _______________________________________________
>>>  List Archives:  http://lists.ucc.asn.au/pipermail/committee
> 
> 
> -- 
> Yours sincerely,
> Timothy Chapman.
> _______________________________________________
> List Archives: http://lists.ucc.asn.au/pipermail/committee
> 
> *Attachments:*
>  * image.png
>  * Outlook-c4hyp4y4.png
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