Working safely with electricity

1. Introduction

The Electricity at Work Regulations 1989 impose a legal framework specific to electrical safety which is applicable to all work activities with electricity.  There are no voltage limits and the scope of the Regulations extends from the smallest, simplest battery systems such as torches etc, to the national transmission systems. The aim of the Regulations is to prevent injury from whatever source of electrical energy. 

A "Memorandum of Guidance on the Electricity at Work Regulations 1989" - ISBN 0 11 883963 2, and a supplement "Electricity at Work" HSG 85-ISBN 0 11 882081 8 have been produced by the Health and Safety Executive (HSE). These contain the HSE’s interpretation of the Regulations and all persons in control of electrical danger must have access to the Memorandum and supplement, and be aware of their individual responsibilities therein.

This Policy Statement must not be read in isolation. When any electrical work is initiated, and this includes design, the person in control of the work must comply with all relevant legislation, the requirements of relevant University safety policies and all relevant electrical safety standards. Persons involved in design, construction and operation of electrical systems (including purpose-built research apparatus) must be fully aware of the requirements of all relevant legislation and standards to ensure that safe systems can be established and maintained.

The duties are set out in the Electricity at Work Regulations, some of which are absolute and some of which are to be carried out as far as is reasonably practicable, require knowledge of the legislation, clarity as to which level of duty is imposed and the ability to carry out risk assessment. For the latter, there is a need to understand the risk and then with appropriate knowledge, evaluate the measures necessary to control it. This involves weighing the likelihood of injury and severity of injury against the measures needed to avert the danger and, amongst other things, it will be necessary to consider the implications of lone working as part of the process. It must be recognised that in the case of an electrical accident there is often a fine line between a near miss and a fatality. Risk assessments must be suitable and sufficient and commensurate with the risk.

In terms of the Electricity Regulations the legal "duty holder" is clearly defined. The legislation states that where an EMPLOYEE is in CONTROL of electrical danger, the duties imposed on the INDIVIDUAL are equivalent to the duties placed upon the employer and the self-employed.

2. Legal duties

The Electricity at Work Regulations 1989 require heads of departments to ensure that electrical systems and equipment for which they are ultimately responsible are designed, operated, maintained, modified and extended in such in a way which avoids danger.

See Appendix 1 for a synopsis of the requirements of the Regulations.

3. Definitions

An electrical system is a system in which all the electrical equipment is, or may be, electrically connected to a common source of electrical energy.

Electrical equipment includes anything used, intended to be used or installed for use, to generate, provide, transmit, transform, rectify, convert, conduct, distribute, control, store, measure or use electrical energy.

The Person in Control of Electrical Danger is the Duty Holder - this person must be competent by formal training and experience and with sufficient knowledge to avoid electrical danger. The level of competence will differ for different items of work. 

Examples:

(a)  Any person who will be required to inspect or connect a 13 amp plug requires a lower level of technical electrical knowledge than a person who will be required to work on high voltage systems.

(b)  For work on the University's electrical distribution system to be carried out by a University employee, it is likely that the minimum standard would be a person trained and qualified as an approved electrician within an approved training scheme, and up to date with changes in regulations and standards such as BS 7671 (IEE Wiring Regulations 17th Edition 2008). In addition to technical skill, a person must also have knowledge, experience and understanding of the systems to be worked upon, be aware of the hazards which may arise, the safety precautions which need to be taken to avoid risk of injury and must be able to recognise at all times whether it is safe to work. The person must be formally authorised in writing by the Director of Estates. Departments are advised to consult the Director of Estates before employing a person to work in this capacity.

4. Responsibilities

(a)  Heads of departments are legally responsible for all electrical work, systems and equipment except for those systems described in paragraph (b) below as being the responsibility of the Director of Estates. Examples of departmental areas of responsibility are electrical generation, experimental rigs, work activities in electronic and electrical workshops, portable electrical equipment, light fittings and equipment fitted to the fixed electrical systems, such as workshop and kitchen machinery.

Appendix 2 provides further information relating to the safety of portable electrical equipment.

(b)  The Director of Estates is responsible for the design, construction, operation, repair, maintenance, modification and extension of systems as detailed and defined in the University’s Standing Orders for University Functional Buildings and Sites, 2005, commonly known as the ‘Grey Book’.

These are:

(i)  sub-stations, switchrooms and all electrical services (other than those provided by statutory authorities) including mains supplies, lightning conductors, general and special earthing, lighting of roads, car parks, cycle and pedestrian ways

(ii)  the electrical distribution system (in multiphase systems this includes all works up to and including the isolator and in single-phase systems this includes all works up to and including distribution boards) also all subsidiary circuits up to and including socket outlets, fused spurs, ceiling or wall lighting terminations.

The Director of Estates must liaise with departments, particularly with respect to timing, access, isolation of supplies and notification of intended works, so that departments can prepare or co-operate with the Director in preparing risk assessments.

(c)  Departments other than the Estates Services must not carry out, or cause to be carried out, any modification or extension to the systems defined previously as the responsibility of the Director of Estates without the prior knowledge and prior written approval of the Director. In addition, heads of departments have the following responsibilities concerning the electrical distribution systems that are under the control of the Director:

(i)  they must ensure that areas where electrical switchgear is installed are kept clean, tidy and unobstructed. Dedicated switchgear spaces must not be used as storage areas.

(ii)  when work is taking place on the electrical distribution system, heads of departments must exercise their responsibilities as the persons in general control of the workplace, to ensure that in-house personnel and contractors are provided with a (general) safe working area, suitable induction training, and are given sufficient information of any known hazards or risks to health and safety to enable them to work safely.

(iii)  they must ensure that neither they, nor members of their departments, give instructions to any contractor concerning any work on the electrical distribution system.

(d)  Heads of department must ensure, for systems for which they are responsible, that there are competent persons in place to control electrical dangers in their departments and that all appropriate risk assessments are carried out before electrical work is undertaken. There must be records of the significant findings of assessment and any groups of persons identified by the assessment as being especially at risk.

(e)  Heads of departments must ensure that electrical systems and equipment, for example portable appliances, are properly maintained. Appendix 2 provides additional guidance.

(f)  Heads of departments must ensure that the electrical contractors they wish to employ are competent. The Director of Estates has an approved list of competent contractors. Contractors must be monitored and assessed on an ongoing basis. University Policy Statement (UPS) S6/08 discusses the selection and control of contractors in more detail.

5. Live work and live testing

It is University policy that live work on electrical systems should not be carried out, with the specific exception of testing and diagnostic work. In these cases, Regulation 14 of the Electricity at Work Regulations 1989 requires the person in control of danger to:

(a)  determine in each case that it is unreasonable in all the circumstances to work on conductors which are dead

(b)  carry out a risk assessment to assess the risks and methods of controlling them

(c)  decide whether it is reasonable to work live.

6. Purchase or disposal of electrical equipment

Equipment purchased from outside the EC must always be verified as electrically safe by the importer or supplier and CE marked. Departments themselves may be the importer or supplier, and in such cases would be responsible for ensuring compliance with the electrical principles stipulated in the Electrical Equipment (Safety) Regulations 1994. These Regulations require electrical equipment to be safe and constructed in accordance with good engineering practice. 

Electrical equipment that is to be sold on, or which is to be donated by a department, must also be safe and meet legal safety requirements in relation to its design and construction, and this must be verified before being offered for sale, or donated. Written instructions for safe operation of the equipment must also be provided for the intended recipient. Electrical equipment that is hired out is also within the scope of the Regulations.

End of life disposals of electrical equipment must be in accordance with the EU’s Waste Electrical and Electronic Equipment Directive (WEEE Directive). This minimises the impact on the environment, by re-using, recycling and reducing the amount of WEEE going to landfill. Hazardous WEEE should be disposed of via the Safety Office hazardous waste disposal service, and departments should make suitable arrangements for non-hazardous WEEE disposals via a supplier compliance scheme, if appropriate, or a reputable waste contractor. Further information is provided in Safety Office Policy S5/11.

7. Teaching and research activities

The Electricity at Work Regulations (see Appendix 1 for a synopsis) must be taken into account in the risk assessments for teaching and research activities. Particular attention must be paid to the competent supervision of students and others involved in electrical work. Adequate forethought must be given to the safety of other persons who might be affected by the activities.

The Regulations are specific in that no persons may be engaged in any work activity where technical knowledge or experience is necessary to prevent electrical danger, or injury, unless he/she possesses such knowledge or experience, or is under such a degree of supervision as may be appropriate in relation to the nature of the work.

The supervisors of academic and similar work must be aware of these requirements and compliance must be ensured.

8. Design and construction of electrical systems and equipment (other than those which are the responsibility of the Director of Estates)

Without detracting from the duty of the person in control of danger, departmental designs for apparatus that are to use electricity should be verified by the Electrical Safety Supervisor before construction. Verification should ensure that all procedures set out in this policy statement have been observed. The Electrical Safety Supervisor should also check the safety of departmentally designed equipment before is put into use.

The "Electrical Safety Supervisor" is an employee who should be appointed, in writing, by the Head of Department to advise the Departmental Safety Officer on all matters relating to electrical safety. This person should be conversant with legislative and other requirements.

9. Users of electrical equipment

Heads of departments must ensure that users of electrical equipment understand the normal operational parameters of their work equipment.  Risks can arise if a properly designed and constructed item is used outside the conditions for which it was designed and constructed.  Particular examples of high-risk conditions are potentially explosive atmospheres, oxygen enriched atmospheres and wet or damp atmospheres.  Consideration of the conditions of use is part of the risk assessment process and must be undertaken before work begins.

(There are specific University requirements concerning the use of electrophoresis equipment - see UPS S11/07)

10. Posters

The Memorandum of Guidance on the Electricity at Work Regulations 1989 recommends that a poster containing emergency resuscitation procedures is placed at locations where workers may be at greater than average risk of electric shock. This includes locations for electricity supply, generation, transmission and utilisation, and areas designated for electrical testing.

THIS STATEMENT FORMS PART OF THE UNIVERSITY’S SAFETY POLICY. UNIVERSITY POLICY NOTE S 1/00 IS SUPERSEDED.  PLEASE AMEND THE INDEX.

March 2010