17. Other Issues Considered
Residual Current Devices (RCDs)
241. Submissions were made to the review team that residual current devices (RCDs) (which, internationally, are also referred to as residual current circuit breakers, safety switches, earth leakage circuit breakers, or ground fault interrupters) should be made mandatory. Several submitters referred to a particular case of electrocution where an RCD may have prevented a fatal accident. In response to similar calls for making RCDs compulsory, the Office of the Chief Electrical Engineer produced the Report Relating to the Application of Residual Current Devices in New Zealand 1997. This report noted that the use of RCDs in higher risk areas (such as bathrooms) is already a cited means of compliance with safety obligations. The report concluded that widespread mandating of RCDs should not be introduced as this would impose a substantial cost on society (an estimated $300 million) relative to the number of lives that RCDs could be expected to save (an estimated one life per year). Other ways of ensuring safety were thought to offer greater benefits.
242. It should be noted, however, that recent developments in Standards relating to electrical safety have seen an increasing reference to the use of RCDs. As Standards are used as means of compliance, such references will lead to greater use of RCDs.
243. The Standard NZS 3000, which has been published but does not yet have the legislative backing it needs to become compulsory, will result in the installation of RCDs becoming mandatory (instead of just a means of compliance) in damp locations and out of doors. However, it is expected that this will have little practical effect, as RCDs are generally used in these situations already. NZS 3000 is expected to be superceded by a joint Australia-New Zealand Standard, AS/NZS 3000, which will be introduced in late 1999. The development process will consider whether mandatory RCD requirements need to be extended.
244. It should also be noted that the Office of the Chief Electrical Engineer is currently sponsoring a Trans-Tasman project that aims to make recommendations on specific safety provisions for three high risk groups (children, elderly people, and disabled people) by the end of 1999. These recommendations, which may be adopted as a means of compliance, could suggest that RCDs be made mandatory for certain locations, such as schools, kindergartens, and elderly persons' nursing homes.
245. The review team rejects the proposal to make RCDs universally mandatory, but recommends that the Government actively supports projects such as the one referred to above and other industry campaigns aimed at promoting the benefits of RCDs to the public.
Utilities Act
246. One industry group suggested that the way of solving the problems of overlapping legislation was to develop new Utilities Safety legislation and a new Buildings Safety Act which would cover telecommunications, gas, electricity, water, drainage and sewerage.
247. If the review team had started with a clean slate, this proposal would have had considerable appeal. However, we were conscious that there were already sunk costs both in the existing structures and in the familiarity that workers and the public have with the existing safety regime. To radically alter the regime would have required the review team to have had both major concerns about the levels of safety possible under the existing system and compelling evidence that grouping utilities together would be able to deliver higher levels of safety that would offset the costs inherent in such a sweeping change.
248. The review team concluded that the benefits of having utilities grouped together were not sufficient to outweigh the considerable administrative difficulties of setting up and administering legislation that would involve so many agencies, trade and industry groups. It was also felt that such broad legislation could only operate at a general level and would not be able to deal effectively with the very different technical issues and risks involved. For instance, provisions that deal with the safe provision of sewerage are unlikely to deal adequately with electricity. If separate provisions were needed for the different utilities, then any advantage from grouping the utilities together would be lost.
249. The review team's view was that the problems of overlap could be solved more and effectively at present by identifying the main legislation governing safety and then aligning other legislation and resources to that.
250. The review team noted that there is a proposal within central government for a review to be carried out looking at the way in which government agencies address the full range of safety issues. If this review goes ahead it would lead to a more consistent approach across government to the whole spectrum of safety issues. One possible outcome of such a review would be the establishment of a single agency to deal with safety. This could in time lead to unified safety legislation instead of separate legislation for the different kinds of safety as we have at present.
Trans-Tasman Mutual Recognition Arrangement (TTMRA)
251. The Trans-Tasman Mutual Recognition Arrangement (TTMRA) covers equipment, technical standards and worker licensing. Both Australia and New Zealand want mutual understanding and acceptance of qualifications for industries grouped under the Australian "utilities" umbrella, including electricity, electronics, and gas. Unless something specific is agreed, TTMRA will deem people licensed in Australia to be qualified to be licensed in New Zealand and vice versa.
252. Reciprocity arrangements for gas workers have been in place for some time. The PG&D Board assesses applicants and issues reciprocity certificates. Applicants that do not meet New Zealand skill levels are required to upskill through the ITO training system.
253. Reciprocity for electrical worker licensing has been in place for many years between New Zealand and Australian States and Territories and has been supported since 1992 by Federal/State Mutual Recognition Acts. However, there are some differences between what each jurisdiction requires in terms of licensing. Some jurisdictions require licensing for work that does not require licensing in others. A National Electrical Licensing Reference Group involving representatives of employers, unions, associations, regulators and contractors involved in electrical work is aiming to reach agreement within the next year on the removal of these differences.
254. Changes to the existing licensing system and the competencies required for licensing as a result of this review may create new differences between jurisdictions. Any differences can create problems since the 1996 declaration of Australia and New Zealand Mutual Recognition of Vocational Education and Training Qualifications aims to achieve parity by the year 2000. If the New Zealand qualifications are set at a higher level than those in Australia, those who study towards qualifications in New Zealand will bear higher training costs than their Australian counterparts. If New Zealand's qualifications are set too low, New Zealand workers opting to practice in Australia may pose a safety risk to Australian consumers and may soon find themselves the subject of prosecution.
255. The review team recommends that the general recognition of licences and registration be addressed through the TTMRA process, but that the legislation makes provision for explicit recognition of licences and registration systems recognised as sufficiently similar to ours.
Record of Work Done
256. Some of the groups making submissions raised the difficulty of householders not knowing what work had been done by previous occupants of their dwellings or premises. This was seen as a potential hazard as wires could be cut through or pipes dislodged when further work was done.
257. It is noted that under the Building Act the local territorial authority is the "office of record" for documentation in relation to the construction of buildings. Records on electrical and gas installations that are part of work requiring a building consent are kept by the local authority. However, work that is not covered by a building permit is not generally documented and records of it are not kept at local authority offices.
258. The review team considered whether there should be a requirement to keep copies of Certificates of Compliance for electrical and gas work in a central place or deposit them with the relevant local authority. In the case of gas work, copies of all Certificates of Compliance are required to be forwarded to the PG&D Board. The Board's database enables searches to be done if the residential address is known. These gas Certificates of Compliance describe the work and usually include a sketch. Householders can ask the Board for this information if they require it.
259. However, in the case of electricity there are over 100,000 Certificates of Compliance completed each year. The legislation requires the person who certifies the work to keep copies of the Certificates of Compliance issued, but there is no requirement to forward copies to the EWRB. The EWRB considers that because of the volume of Certificates of Compliance, it would not be cost effective to maintain a central record. If the scope of self-certification for electrical work is extended, the volume of Certificates of Compliance would increase significantly.
260. The review team also noted that with electrical work the Certificates of Compliance were likely to state the task carried out (e.g."...installed 3 additional dimmer switches and rewired basement") rather than provide specific information that would be useful to a householder trying to locate exactly where the wires went. Requiring electrical workers to provide full wiring diagrams is seen as too high a compliance cost on the industry which is not justified merely to answer occasional questions from householders.
261. Requiring all Certificates of Compliance to be lodged with the relevant local authority was suggested. However this would have the effect of obliging the local authority to provide a service without giving them any ability to recover the costs of this.
262. It was suggested that householders could keep their own logbook of work done and pass it on to the next owner or they could deposit their own copies of the Certificates of Compliance with their local authority to keep the records on their property complete. The team fully realises that only a minority of householders would do either of these things, but could not see enough justification for imposing any more stringent information requirements on electrical and gas workers than there already are.
263. The alternative to having historic information about work that has been carried out is to check current safety levels. The Electrical Code of Practice
NZECP11 contains provisions for the inspection and testing of an existing installation (e.g. a house). The review team recommends that these provisions be reviewed and a more formal inspection process for checking existing installations be created as a New Zealand Standard which could be used by the public when purchasing a house or other installation.
264. The same effect could possibly be achieved through voluntary means. For example, the Electrical Contractors Association of New Zealand (ECANZ) is promoting the Electrocheck system, which encourages homeowners to have an electrical safety check done on the wiring, outlets, main switchboard, and earthing. This check, plus the provision of a smoke alarm, was offered for $80 at the end of 1998.
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