PAT Testing Record Keeping: The Implication Of Regulation 29 (Electricity At Work Regulations)
In any proceedings for an offence consisting of a contravention of the EAWR 1989 Rep 4 (4).5 and 8 to 16 inclusive (i.e. those Regulations requiring "absolute" compliance), regulation 29 states that it shall be a defence for any person to prove that they took all reasonable steps and exercised all due diligence to avoid the commission of that offence. The most effective method for the dutyholder to prove to a Court that he "exercised all due diligence" etc, is to produce proper records of the measures taken to prevent the accident. Hence full and accurate records made at the time of testing become essential, and the managed system designed to achieve this must be in place before the accident.
Step By Step Approach
A step by step approach would include the following:
(a) Conduct a survey to identify all portable and transportable appliances which exist with the duty holder's control.
(b) Each appliance should be marked with a unique identification code, cross referencing test results and inspection details. A register of all equipment should then be created to include the following details:
- Identification number
- Location in which the equipment is kept
- A description of the appliance
- Serial number
- Periods between tests
- Any other details.
Due to the large number of appliances and the details that must be recorded a computer database is likely to be the most effective and efficient method of data collection and storage. A comprehensive software package such as the one used by London PAT Testing will enable the user to set up a detailed database of all items at any particular location easily. By recording the information outlined in above, working documents can be produced which are a useful aid to proficiency and safety. For example a work schedule can be generated grouping products by test date, task sheets can be printed providing the person conducting the tests with a list of all items due for testing, together with their location, identification number etc.
Use Of Advanced Portable Appliance Testers
Where advanced Portable Appliance Testers are used, data can be transferred directly from the instrument to the database providing automatic creation or update of records. In such situations reports of untested appliances and those which failed the tests can be produced and submitted to the dutyholder for the appropriate action to be taken, this insures the investigation is thorough and avoids oversight.
Action On Completion Of Tests
Any equipment found unsafe must immediately be removed from use, labelled with its fault and transferred to the repair facility and the appropriate person informed. On successful completion of the tests a label should be attached to the tested equipment showing:
- The date tested
- The identity of the test person
- The date for re-test
Such information will enable the dutyholder to manage this aspect of the overall safety of the area with his control. A convenient method of labelling equipment may incorporate a bar code. The equipment used by London PAT Testing can be used with a Bar Code Reader and collect Appliance number and test codes without the need for manual data input.
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