Electrical Safety - Use of RCD's as alternative to Testing and Tagging

01/09/2015 13:43

WORKSAFE NZ - Energy Safety Guidance Note - Electrical equipment safety in Aged Care and similar facilities

September 2015

Issue

Energy Safety provides this guidance in response to requests from the Aged Care sector for clarification around the provisions of Regulation 26 of the Electricity (Safety) Regulations (ESRs) as it applies to equipment located in aged care units and similar facilities. The specific issue is related to equipment principally for the use of patrons, but may be provided by the owners of the facilities (including specifically electrically operated beds). It also relates to the use of RCD (30mA) protected supplies as an alternative to the “Test and Tag” regime of AS/NZS 3760 In-service safety inspection and testing  of electrical equipment and the relevance of AS/NZS 3551 Management programmes for electrical equipment.

Clarification has been sought because there are significant cost implications, and different safety methodologies appear to be being promoted by those providing advice and services to the sector. It is also unclear as to what is strictly mandatory.

Comment

The Electrical (Safety) Regulations 2010 are structured principally around risk and the ability to control the electrical infrastructure in networks, consumer installations and electrical appliances. They provide guidance on how the safety of electrical appliances and equipment can be assessed using a recognised Standard (AS/NZS 3760), and recognise how safety in respect to electric shock can also be delivered using RCDs.  These two alternatives are identified in Regulation 26.

Application of AS/NZS 3551

Testing to AS/NZS 3551 is neither relevant nor necessary in aged care facilities unless the equipment is part of a facility that is intended to be used for treatment that specifically requires “Body Protection” or “Cardiac Protection” from electric shock.

Energy Safety notes that it is acceptable to carry out monitoring and diagnostic measurements, and some forms of treatment, using BF and CF rated electrical medical equipment without requiring the location to be configured for BF or CF procedures, and to utilise portable medical rated (10 mA) RCDs for other treatment.

Application of the “Test and Tag” regime of AS/NZS 3760

While there are mandatory Regulatory provisions for the safe use of electricity, because AS/NZS 3760's test and tag regime is recognised by Regulation 26 as a safe method of achieving the general safety requirements for the use of plug-in appliances, in the Regulation’s risk based architecture, it's application is not mandatory, nor does the Standard represent a minimum benchmark by which an alternative safety methodology must be assessed.

The Regulations, through the citation of IEC 60479 – The effects of current on human beings and livestock – recognise that RCDs provide an acceptable methodology of providing protection against electric shock.

Therefore, in Aged Care facilities, the use of RCD protected supplies to provide an alternative to “Test and Tag”, where the RCDs are checked on a regular basis, is not necessarily inadequate for compliance with the Regulations.

The regular checks could be performed using the test feature of the RCD twice yearly at daylight saving adjustments where the disruptions of clocks, etc. would be minimised. An RCD that fails to trip when tested must be replaced.

Review of Regulations

It is expected that clarification of this aspect of safety in aged care and similar facilities will be considered during the next revision of the Regulations.

Guidance Note - Electrical Medical equipment safety when used in domestic “home” or similar installations

Issue

Energy Safety provides this guidance in response to health sector requests for clarification of the Electricity (safety) Regulations regarding the requirements applying to the use of electrical medical equipment for treatment of patients in home environments, particularly (Type 1- not double insulated equipment used for renal peritoneal dialysis equipment and some respiratory humidifiers.

While double insulated, medical-electrical equipment classified as BF or CF, may be used in home locations without specific Residual Current Device (RCD) protection, the provisions of AS/NZS 3003 Electrical installations – Patient areas specify that where Type 1 equipment is being used for an extended period of time a permanently installed RCD is required.

The health sector has noted that the cost of installing an RCD specifically for this purpose is relatively high and requires the treatment to be carried out in only one location within the home unless more than one RCD is installed, and therefore asks whether the continued use of portable RCDs is unacceptable or unsafe.

Comment

The relevant Regulation in this case is Regulation 25, which is structured principally around risk and sets out practices that are recognised as being safe. It is through this Regulation that compliance with AS/NZS 3003 is established for the safe use of electrical medical equipment.

Because compliance with AS/NZS 3003 is a recognised (deemed to be safe) method of achieving the general safety requirements for the use of electrical medical equipment, in the regulation’s risk based approach, its application is not mandatory, nor does the Standard represent a minimum benchmark by which an alternative safety methodology must be assessed.

Regulation 24(5) however sets the minimum requirements for RCDs that provide protection for medical treatment and for portable RCDs.

Response

Therefore, for example, the use of a 10 mA RCD protected supply using a portable RCD, where the users of the equipment (or trained medical staff) perform their own safety checks of the functioning of the RCD on a regular basis, is not necessarily inadequate. The checks could be performed using the test feature that is required to be part of a “safe” RCD.

Review of Regulations

It is expected that this this aspect of home care safety will be considered during the next revision of AS/NZS 3003 and the Regulations. In the short term the NZ experts serving on the Standards committee responsible for AS/NZS 3003 have given their support for this guidance note.