Partner Article

Are you paying TOO OFTEN for PAT testing?

News Flash: 2nd May 2012 the Health and Safety Executive announces that “unnecessary electrical safety tests cost office-based businesses an estimated £30 million a year”; they also said that “it’s a myth that every portable appliance in the workplace needs to be tested once a year – and what’s more it’s a costly one. Misleading advice and advertising, often by companies who offer the testing is contributing to low-risk businesses such as offices, shops and hotels paying unnecessarily for the over-the-top maintenance regimes”

The HSE Chair Judith Hacket said, whilst launching the revised guidance on portable appliance testing (PAT); “we know that low-risk companies are being mis-led over what the law requires when it comes to maintaining portable electrical appliances, and many are paying for testing that is not needed. Businesses are responsible for protecting their employees, but they shouldn’t be wasting their money on unnecessary checks that have no real benefit“

Hundreds of companies read this, in all kinds of sectors and presumed it meant “we don’t need to get PAT Testing done anymore”; this was an incorrect assumption. However, it’s understandable it was seen this way, as many PAT Testing companies read it that way too; few realised what was actually being said. It’s actually a very simple and direct message, which honest PAT Testing companies have always said; the frequency of your PAT Testing is determined by your risk assessment.

A high risk environment such as a building site undergoes portable appliance testing every 3 months, usually, and rightly so, but this document doesn’t refer to building sites, or for that matter anything high, or even medium risk. The revised document, INDG236 only refers to “maintaining portable electric equipment in low risk environments“; such as offices, shops and hotels.

It’s understandable that the message was mis-understood; the overview of the document doesn’t mention that the £30 million estimate is what office-based businesses could potentially save by stopping unnecessary yearly testing – annual testing of all appliances in a low risk environment, such as a call centre or office for example is a waste of money; it’s also a waste of time for the PAT Testing company, as the chances of deterioration of the appliances in this time are very slim.

The guidance document INDG236 was revised, on the recommendation of Professor Lofstedt, following his report on health and safety legislation, which said that the legal requirements concerning maintenance of electrical appliances was “applied too widely and disproportionately”; this referred to the inspections of all appliances in an office every year. It’s just not necessary.

The document also doesn’t refer to insurance; your business insurance is ultimately your first port of call when assessing risk; as their requirements for your policy may differ to what you deem necessary timescales for PAT testing intervals.

The Association of British Insurers say this about the testing of portable electrical appliances:

• There is no specific legal requirement for every portable electrical appliance to be tested each year and your insurer will not insist upon this when offering you insurance
• However, as you must maintain this equipment suitably to prevent danger, insurers recommend you follow the guidance published by the HSE, available at www.hse.gov.uk/electricity/index.htm
• For specific guidance, read ‘Maintaining portable electric equipment in low risk environments’, available at www.hse.gov.uk/pubns/indg236.pdf

Whilst that is the view of health and safety, and insurance, you also need to consider the Fire Officer, when they do your fire safety inspections. Their business guidance documents for fire risk assessment (which you can download from https://www.gov.uk/workplace-fire-safety-your-responsibilities/fire-safety-advice-documents) says “i_f portable equipment is used, including items brought into a workplace by staff, when your fire risk assessment should ensure that it is visually inspected and undergoes portable appliance testing (PAT) at intervals suitable for the type of equipment and it’s frequency of use_”.

Are you noticing a pattern yet? Whether we’re talking about insurance, health and safety or fire prevention they all talk about the same thing; “every, all, yearly, etc.“ It’s important to note that despite the presumption that this document was saying businesses didn’t have to get PAT Testing done; quite the opposite is being said – it does, or to be specific, portable appliance testing does.

Let’s just dispel the myth first; you’ll never find an official document referring to PAT Testing, because PAT Testing is a ‘slang’ common term and actually doesn’t make sense; the process of PAT is the portable appliance test; doing the process is portable appliance testing, and the abbreviation is PAT; PAT Testing is the commonly known name which is why PAT companies continue to use it.

Also; the term is not the most clear; as portable doesn’t necessarily mean it’s portable by you, it just means it is portable from the electricity supply; that it can be unplugged and moved (even by a crane).

So, back to the pattern; all these facilities we listen to; the HSE, ABI and the Fire Brigade are saying we do need PAT, but they’re not saying how often; why is that? Because they don’t determine how often, as they aren’t responsible in the event of an accident or fire – you are. The business owner, person in charge or duty holder writes the risk assessment, and from that they determine the risk of the workplace, from which they determine at what intervals portable appliance should take.

Portable appliance testing shouldn’t replace maintenance

Equipment that has been purchased from a reputable supplier should have a high standard of safety built in, however, it must be maintained so that it stays safe, and does not deteriorate to such an extent that people may be harmed.

You should maintain your appliances; portable appliance testing finds faults but it’s rare to find a PAT company dealing with all your repairs too; they’ll do minor repairs on the job such as repairing a damaged flex or replacing the plug but they’re not the people to fix the operating system on your PC.

How you determine the risk determines the frequency; and that will determine how much often you get the PAT Testing done, and ultimately how much you spend. Of course, you may not know the risks and then it’s good to seek professional advice, be it from a Health and Safety Consultant or even a reputable PAT company, such as DRA PAT Testing. As a standard service we can guide our clients on the best frequency for their workplace, based on the risk, and that ultimately will save them a lot of money; sometimes this can be as high as 75% of their usual costs, over a period of time.

It’s not uncommon to find some office-based businesses that only get PAT done once every 5 years; but it is rare, because these businesses not only have a water-tight risk assessment in place, they’ll also have competent staff doing regular user checks, and maintenance people doing regular visual inspections – there’s more to it than just putting on a form that 5 years is enough.

You also need to be sure that the company you contract to perform your portable appliance testing is doing the job correctly and not simply putting stickers on everything; a series of tests do need to be carried out and an inspection, visually of the appliance. A new group, the PAT Testing Network, is working to try to ensure all businesses get the right service all the time; but that is a slow process, as you can imagine.

The legal requirement for maintenance is designed to ensure that equipment remains safe and is given in various pieces of legislation, the three most important being the Health and Safety at Work Act 1974, which places a duty of care upon the employer to ensure the safety of employees and other persons using the workplace; the Provision and Use of Work Equipment Regulations 1998, which requires work equipment to be maintained in an efficient state, and; the Electricity at Work Regulations 1989 which requires all systems to be maintained to prevent danger.

The HSE document was correct when it said “unnecessary electrical safety tests costs office-based businesses an estimated £30 million a year”; because unnecessary tests happen far too often; and it’s not just how often they happen but the tests that are being conducted. For example the HSE says that a “visual inspection by a competent person is all that’s necessary for a double insulated appliance” (referring to any appliance with no exposed metal parts) yet the vast majority of PAT companies still conduct insulation tests on these appliances even though it’s not a necessary test; a visual inspection by a competent person is sufficient.

Any appliance with a double insulated symbol, and no exposed metal parts, doesn’t require a portable appliance test, but should be inspected by the PAT company at regular intervals to ensure it remains in a safe condition. In a low risk environment for IT Equipment this should be at least every 2 years.

The vast majority of electrical equipment in an office is considered to be Class I; it’s not double insulated and has exposed metal parts – they rely on an earth. These appliances, due to the exposed metal pose a greater risk than double insulated appliances, and so they have to be tested more frequently, but whether that is annual is still determined by risk assessment. The Code of Practice for In Service Inspection and Testing (PAT) recommends that in an ideal environment, IT equipment for example has a visual inspection every 2 years, and a full test every 5 years; this is however the maximum interval based on the perfect environment which is rare to find.

We always recommend to our clients what we feel are the best intervals for their business, posing the least threat, whilst reducing the term from annual thus saving our clients’ money. What the outcome of that is is dependent on the client and their environment; but it is very rare that we recommend our office-based clients to test all their appliances every year.

We as a PAT company can advise our clients on the best course of action, but the decision ultimately resides with the client. We’d recommend any business to seek professional advice before determining the frequency for electrical appliances; not necessarily from a PAT company but from their insurer, or from the many PAT books and HSE guidance documents that are available.

DRA PAT Testing provide via the website a ‘system review’ where businesses can input their information, from which we will review their current process and provide guidance on how and where they can save money by reducing their PAT Testing frequencies whilst remaining compliant for Health and Safety.

This was posted in Bdaily's Members' News section by Richard Ayre .