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Do I have to PAT test?

22-10-2012

Do I have to PAT test?

Do I have to PAT test? How often should I PAT test? How do I know that my portable electrical appliances are safe?

These questions are examples of what I’m regularly asked by managers / business owners who are concerned with regulatory compliance or just want to be sure the electrical appliances on their property aren't going to cause anyone harm.

I’ll try to give a clear answer in this article and will start off by making a few points clear for readers who aren’t sure what PAT is or why it is done.

So, what is ‘PAT’?

PAT stands for Portable Appliance Testing – it refers to an examination of electrical appliances to ensure they are safe (the portable bit basically means any electrical appliance with a plug).

(I say PAT rather than PAT testing throughout this article – that basically means Portable Appliance Testing testing – it’s a bit like saying PIN number when PIN stands for Personal Identification Number.)

Let’s (briefly) mention the law…

The Electricity at Work Regulations 1989 (EAW) require that any electrical equipment that has the potential to cause injury is maintained in a ‘safe condition’.

In the event that you or your company were prosecuted following a possible contravention of these regulations what would your defence be, and how would you prove that you “took all reasonable steps and exercised all due diligence to avoid” committing an offence? We’ll come back to that later.

Is PAT required?

The one word answer is no, however things are rarely that simple – if you don’t PAT, how can you show that you took reasonable steps to prevent danger? User checks (where your employees check the cables, plugs etc. before using an item of equipment) are one alternative but there are a number of issues with this:

  • Will your employees actually carry out these checks?
  • If they do carry out the checks, how much of your employees’ time will be spent doing this?
  • Do your employees really know what they are looking for?
  • How will these checks be recorded?
  • Some issues (for example loss of ‘earth’ or insulation integrity) may not be visible when checking an appliance.

See the bottom of this article for further details on user checks and visual inspections.

What’s the risk?

Ok, so you’re not required to PAT and may be asking why you should. All I will point out is what the Health and Safety Executive states in the relevant guidance i.e. “Nearly a quarter of all reportable electrical accidents involve portable equipment. The vast majority of these accidents result in electric shock.”

How often should I arrange PAT?

Now, I don’t want to sound cynical but who is it that usually tells someone how often they need to test portable electrical appliances? Generally, it’s a company that carries out the testing! So, you could argue that it’s in their interests to visit a business as often as possible to do this work (and invoice for it). Don’t be tricked into carrying out the testing more often than required.

The frequency of testing will depend on your individual circumstances and the use of the appliances – guidance from the HSE gives some examples about how the required frequency varies:

“An example of a high-risk activity is the use of a pressure water cleaner, powered by a 230 V electrical supply, with the cable trailing on the ground where it can be damaged by vehicles and other equipment, and where water is present. Damage to the cable or other parts is likely to expose the operator or others to electric shock.

Similar risks result when electrical equipment such as drills or portable grinders are used in a harsh and sometimes wet environment such as at a construction site, where there is a high probability of mechanical damage.

Lower risks result from floor cleaners or kettles that are generally used in a more benign environment, e.g. offices and hotels. But such equipment can still be subject to intensive use and wear. This can eventually lead to faults that can also result in a shock, burns or, more rarely, a fire.”

-          From HSG 107 Maintaining portable and transportable electrical equipment (free to download at http://www.hse.gov.uk/pubns/priced/hsg107.pdf)

Some examples of recommended frequency of testing are:

  • Business – heavy industrial / high risk of equipment damage
  • User checks – daily
  • Formal visual inspection – weekly
  • Combined inspection and test – 6-12 months
  • Business – light industrial
  • User checks – yes (timed according to your risk assessment)
  • Formal visual inspection – before initial use then 6-monthly
  • Combined inspection and test – 6-12 months
  • Business – office information technology (e.g. computer, photocopier, fax)
  • User checks - no
  • Formal visual inspection – 1-2 years
  • Combined inspection and test – none if double insulated, otherwise up to 5 years
  • Business – earthed (Class 1) equipment (e.g. electric kettles)
  • User checks - yes
  • Formal visual inspection – 6 months to a year
  • Combined inspection and test – 1-2 years

Read HSG 107 for additional examples.

Your insurer may require you to test appliances at a certain frequency – make sure you do this so that you don’t invalidate your insurance! (Don’t forget that there are other insurers out there and you can ‘shop around’ for another provider if you think that your current insurer’s demands aren’t reasonable.)

How much does PAT cost?

If you start getting quotations you can probably expect to receive prices ranging from 70p per appliance up to a few pounds per appliance. There is often a minimum charge that covers a certain number of appliances and then a per item fee on top of that.

So, I can get this carried out cheaply?

Yes, but (there is usually a ‘but’!) you must make sure you are getting a worthwhile service – if someone does quote you 70p per appliance, make sure they:

  • Are competent to carry out the testing
  • Have suitable equipment to carry out the testing
  • Maintain and calibrate their equipment
  • Provide useful feedback on the testing
  • Have suitable liability insurance (don’t forget they are likely to be testing all of your portable appliances and some of them would probably cost you a lot to replace if they are damaged). This insurance point applies to any external contractor you are going to allow onto your premises.

Make sure you check the same things if someone quotes you £2 per appliance as well! (Charging more is not proof of a better service after all!)

I just need those little green stickers on appliances, don’t I?

There’s actually no requirement to have stickers on appliances but this would help to make it clear which appliances have been tested. What’s far more important than the stickers is that the person who carried out the testing was a) competent to do so and b) made you aware of any appliances that failed the testing. If you are told that an appliance has failed you should immediately take it out of use and arrange for it to be repaired or replaced.

There is no strict requirement under EAW to keep maintenance records but these records can be a very useful management tool and (if they are up-to-date) could be valuable evidence in your defence if something does go wrong and someone is injured.

Things to check about the person carrying out PAT for you

As mentioned before, this person should:

  • Be competent
  • Notify you of testing results (especially any failed items)
  • Use suitable testing equipment
  • Ensure their testing equipment has been calibrated appropriately
  • Be suitably insured (if they are not one of your employees)

Can PAT be carried out ‘in-house’?

A one word answer again – yes. But, remember that you should still make sure the person carrying out the testing is competent, has access to suitable testing equipment, knows how to use the equipment and understands the results displayed by the equipment. Consider what training you would arrange for the nominated person and how you would get hold of suitable (and maintained) testing equipment.

Must new equipment be tested?

I’ll give you a one word answer again (even though you know by now that I will add a ‘but’ to this) – no, new equipment, from a reputable supplier, should be supplied in a safe condition but (I did warn you!) – it is still advisable to carry out at least a visual check of the appliance, before use, just to be sure it hasn’t been damaged during shipping or installation. Don’t forget to include the new equipment on your list of appliances so that it is included in your future testing schedule.

User checks and visual inspections

User checks should be carried out before electrical equipment is used, with the equipment disconnected. The user should look for:

  • Damage to the lead (including fraying, cuts or heavy scuffing)
  • Damage to the plug
  • Tape applied to the lead to join leads together
  • Coloured wires visible where the lead joins the plug
  • Damage to the outer cover of the equipment itself
  • Signs of overheating
  • Equipment that has been used or stored in unsuitable conditions
  • Cables trapped under furniture

To carry out a visual inspection you don’t need to be an electrician, but you do need to know what to look for and you must also have suitable knowledge to avoid danger to yourself and others.

For further information, read Maintaining portable electric equipment in low-risk environments: http://www.hse.gov.uk/pubns/indg236.pdf

A free pdf version of this guidance can be downloaded from: http://www.scribd.com/doc/110761750/Guidance-Portable-Appliance-Testing

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