11. Self-Certification
124. Prior to 1992, electrical and gas installation work was controlled through a permit and inspection system operated by the local electricity and gas suppliers. This system was replaced by a self-certification system in the 1992 energy sector reforms with all work that was previously subject to a permit required to be certified by the electrical worker or gasfitter. Electrical appliance repairs and electrical work on supply systems were not covered by the permit system and consequently are not currently covered by the certification regime. The EWRB has, however, introduced a voluntary certification system for appliance repairs in response to industry requests.
125. Certain electrical installation work that has increased safety risks or involves using non-standard practices, must be inspected and certified by a registered electrical inspector in addition to the self-certification by the person doing the work.
126. The review team endorses self-certification by electrical and gas workers because it places clear accountability for safety of the completed work on the worker, who is often in the best position to influence safety. Self-certification helps licensed workers compete against non-licensed workers as the certificates, which are issued exclusively to licensed workers, can be used as a point of differentiation. Self-certification enables consumers to take legal action for unsafe work independent of regulatory intervention by identifying the person who completed work. Consumers can also take action against aspects of work unrelated to safety, such as quality, correct functioning, and cost, under consumer legislation.
127. As certificates are issued to workers by the respective boards, self-certification is also used as a cost recovery mechanism and to provide an audit trail for enforcement purpose. The fees for Certificates of Compliance are prescribed in Regulations. The current fees for electrical Certificates of Compliance are $5 for domestic work, $20 for commercial or industrial work, and $100 for on-going or industrial work. These fees are currently being reviewed by the EWRB. The current cost of a gas Certificate of Compliance is $20.
128. All the electricity and gas industry groups consulted are convinced that self-certification is working and that it has resulted in people placing greater emphasis on the safety of their work. There is anecdotal evidence that the quality of electrical and gas work has improved since the introduction of self-certification. Some workers who believed they were not sufficiently competent in a particular area of work stopped performing that work when self-certification was introduced. Previously they had relied on the inspector to pick up any errors.
129. However, during the consultation process the review team also heard a large amount of anecdotal evidence that suggests Certificates of Compliance are not being issued for a significant amount of work that should be certified. This conclusion, at least as far as it relates to the electrical industry, is supported by a study undertaken by the Office of the Chief Electrical Engineer which showed that approximately 50% of electrical installation, addition, and alteration work was not certified. The level of compliance for new installations is, however, much higher. This reflects the obligation of the electricity supplier to verify that certificates have been completed before supplying electricity.
130. The problem of non-compliance appears to be more widespread with electrical workers than gas workers. There was some concern in the gas industry that self-certification was not being complied with because the number of appliances sold did not match the number of new connections. The PG&D Board carried out a study comparing the number of new meters with the Certificates of Compliance covering installation. It found that some people had a new meter installed but did not have anything connected to it yet. In the few cases where there was connection but no certification, the installation was very new and the certificate was about to be issued.
131. Possible reasons for non-compliance include: the cost of Certificates of Compliance; the level of detail required by Certificates of Compliance (they take too long to complete); consumers do not always ask for them; and circumvention of the audit process. (Only those issuing Certificates of Compliance are subject to audit by the boards at present.)
132. As self-certification is one of the cornerstones of the safety regime, any problems relating to compliance are of concern. Some parties to the review have called for the return of the old inspection regime that applied before the 1992 reforms. However, the review team believes that this would be a retrograde step as inspection would shift accountability for the safety of work away from the worker, who is the person most often in a position to influence safety, and will be substantially more expensive. Estimates of the cost of the previous permit and inspection regime range from $15 million to $30 million. Moreover, the PG&D Board has noted that territorial authorities have found it difficult to meet their current obligations under the PG&D Act to inspect plumbing and drainlaying work because the time and costs involved pose resourcing problems. Industry representatives have also pointed out that local authority inspectors are becoming generalists, rather than specialists and that this could compromise safety if inspection was used in place of self-certification.
133. The review team recommends that self-certification be extended to all electrical work carried out by licensed workers. The costs associated with certificates will need to be reviewed to reflect the significantly increased quantity of certification that will occur. Consideration should also be given to the coverage of the gas self-certification regime.
134. The review team considers that the licensing boards should look at ways of increasing compliance with self-certification, including making Certificates of Compliance more user-friendly and by continuing to educate householders and others who commission work to ask for them. For example, the extension of certification to cover all prescribed electrical work will assist householders who currently cannot easily differentiate work that requires certification from work that does not.
135. During the consultation phase of this review consumer groups suggested that insurance companies be encouraged to push for Certificates of Compliance as a way of reducing their risks. (The idea was that, as with woodburning stoves, if a stove installed without a building permit caught fire the insurance company would not pay out.) While this idea seems to have considerable merit the review team did not think it should be made part of the legislative framework but that it would be best pursued by the industry and the boards.
136. As previously noted, the EWRB has already taken steps to improve both the process and coverage of self-certification. It has introduced a voluntary "Electrical Safety Certificate" scheme for appliance work conducted by licensed workers, which is not currently covered by the legal requirement to issue Certificates of Compliance. The new Electrical Safety Certificate is a self-adhesive sticker that can be attached to the appliance or the invoice.
137. The review team considers that the Certificate of Compliance and the new Electrical Safety Certificate processes should be collapsed into one to avoid confusion.
138. Currently a range of electrical work must be both certified and inspected. This is done when the competence of the person doing the work is critical to safety. With the development of competency units covering many of these areas there is a need to consider whether what is in effect a double certification system is still needed. The review team considers that the current requirement applying to work requiring inspection should be reviewed to reduce the compliance costs associated with it. Given that the safety regulatory environment is performance-based and has recognised methods of compliance, it may be more appropriate for the inspection regime, if retained, to apply only where the recognised practices are not being followed.
139. There are no tasks in gasfitting that must be both self-certified and inspected.
140. When changes to self-certification are made, the processes used for self-certifying electrical and gas work should be made as consistent as possible.
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