Mark Palmer: (Sparks Magazine)

"IN last month's column, I began an exercise to bring some understanding to Section 5 of SANS 10142-1.
This section continues to cause some debate as to its implementation due to continued lack of adequate training in the electrical contracting industry.
A number of disputes, regarding interpretations the by Gauteng Electrical Inspection Authority (GEIA) on certain electrical installations, have been lodged with the Chief Inspector over the last few months and, as an Approved Inspection Authority, I am pleased with the recent outcomes that indicate the AIAs are not far off in their policing activities.
In determining interpretative differences, it is important for any contractor who disputes the interpretation given by an AIA to submit an interpretation as to why the AIA may be incorrect. The fact that a contractor may not like the current interpretation or that advice given by outside sources may lead to responses to the effect of "well nothing has happened in the past and therefore the particular part of the installation may be deemed to be reasonably safe" does not satisfy the requirements of the Electrical Installation Regulations dispute process. This is of particular importance in ‘existing' installations.
The requirements of the Electrical Installation Regulations (2009), in particular Electrical Installation Regulation 9(2)(b), are as follows:
(2) A registered person may issue a Certificate of Compliance accompanied by the required test report only after having satisfied himself or herself by means of an inspection and test that
(b) an electrical installation, which existed prior to the publication of the current edition of the health and safety standard incorporated into these Regulations in terms of regulation 5(1), complies with the general safety principles of such standard.

The Chief Inspector, in response to a recent dispute, made a discerning statement in the above regard:
"Regulations are based on an electrical installation, which existed prior to the publication of the current edition of the incorporated standard. Therefore, the electrical installation shall comply with the general safety principles of the incorporated standard. Regulation 9(2)(b) of the Electrical Installation Regulations does not necessarily refer to Clause 5 of the incorporated standard."

The above statement lends clarity to the perceived understanding by various sectors of the industry that it is not sufficient just to look at Clause 5 and ignore all other aspects of the electrical installation. It must be taken into account that, at the time of the construction of the basic original installation, there were standards that needed to be complied with. Also, any alterations or modifications would have needed to comply with various other standards that would have been applicable to such alterations or modifications at the time of installation.
The above statement is supported by Fundamental Requirement Clause 5.3 (SANS 10142-1:2009 Ed 1.7) which states:
5.3 Characteristics
5.3.1 The characteristics of the selected equipment shall be appropriate to conditions and parameters on which the design of an installation is based.
The above fundamental requirement, therefore, places an onus on the registered person to ensure that when testing and inspecting an existing installation, the installation complies with the provisions of the standards applicable at the time of installation.
In essence, the requirement for a Certificate of Compliance to be issued on existing installations, as prescribed by the Regulations, is based on the premise that when an installation is sold, all incorrect installations will be put right at that time.
The industry, in general, complains vehemently about the installation of gate motors, pool pumps and motors, geysers, and other electrical installation work done by persons not authorised or qualified to perform such installation work.
In these cases, the ‘user' is responsible for the work that he has contracted. At the time of sale of the installation, however, these issues must be corrected and that is why we have Registered Persons and Registered Electrical Contractors.
I fail to understand how the electrical contracting industry in general, does not grasp this fundamental principle and, instead of continually disputing findings by AIAs, look to their peers for not supporting an effective policing system, which ultimately provides the checks and balances to bring ‘users' in line for utilising all and sundry to do electrical installation work.
As a Registered Person, you may not ignore previous non-compliance by a determination based solely on ‘reasonable safety' and ignoring the ‘prescribed safety' requirements applicable at the time the non-compliance was created.
Next month, I will begin disseminating the interpretations given by the Chief Inspector on various interpretations given by this AIA and disputed by Registered Persons."

mark@geia.co.za