PAT testing - where is "portable" defined?

Discussion in 'Electricians' Talk' started by rogerk101, Feb 25, 2021.

  1. rogerk101

    rogerk101 Screwfix Select

    Much is written about Portable Appliance Testing, but I've yet to find a legal definition of the term "Portable" as it relates to PAT testing.

    • Some say if it's got a 3-pin UK plug on it, then it needs to be PAT tested.
    • Others say if it can be 'ported' (carried by a single person), then it's portable, so needs to be tested.

    If the former, then fridges, dishwashers, clothes washers, need to be PAT tested.
    If the latter, then those large bulky white goods do not have to be PAT tested.

    Can anyone point me to legislation which states categorically which is true?

    The reason I ask is that as a landlord I'd love not to have to get involved in PAT testing every year.
    Every tenant I've ever had has brought their own kettle, toaster, coffee machine, vacuum cleaner, bedside lights, etc. Some have even brought their bulky white goods. For these I have no PAT testing to do.
    Others want to use my bulky white goods, so I'm keen to know if I need to PAT test them or not.
  2. Bazza

    Bazza Screwfix Select

  3. Philip Hyde

    Philip Hyde Screwfix Select

  4. Pete Jones

    Pete Jones Active Member

    Read the ISITEE CoP
  5. MGW

    MGW Screwfix Select

    Seem to remember less than 28 pounds or fitted with wheels. So a batching plant which is moved from site to site with 22 articulated units is portable as on wheels. But my dish washer is not as no wheels and over 28 pounds and no carrying handle.

    However PAT testing is a short way to say "The inspection and testing of in-service electrical equipment" the testing does change slightly with hand held, portable etc, but the dish washer still needs PAT testing.

    However as a landlord the new EICR covers all electrical equipment not normally designed to be moved, this has been an argument since in the past an EICR only related to the installation, not the electrical equipment, so anything which came under the inspection and testing of in-service electrical equipment was not covered with the EICR.

    Technically any rented premises are a work place for some one, so the electricity are work act applies, so every item anyone be it tenant or landlord should be inspected and tested, even in a factory this caused problems, some one would bring in a radio, and before use it should be inspected and tested and entered of the equipment register.

    Any new item had to be entered on the equipment register, there was also a register for items in quarantine, and so the electricians workshop/compound needed to be locked and a notice saying quarantine area do not remove any equipment, in real terms we tend not to go to these lengths, but I was pulled up by HSE for leaving the workshop unlocked.

    We were is a way naughty, we would get maintenance contracts for some equipment, we knew full well they did not really maintain the equipment all they did was repair it when called, but in the equipment register it said under maintenance contract and we got away with it.

    HSE did take a reasonable view, in fact "reasonable" appears in the regulations, so the question is if it is reasonable to expect a landlord to do the inspection and testing of in-service electrical equipment owned by the tenant, and many places where I worked the building was owned by the local authority and all they did was collect the rent. So likely something in the agreement to say the tenant was responsible for all electrical equipment, which is reasonable as you can't as the landlord really be expected to keep a equipment register of the tenants equipment.

    With my mother being disabled all the equipment lent to her to assist with her disability was regularly tested, but the stair lift became hers after 5 years, so she had to get it repaired inspected and tested.

    The inspection and testing of in-service electrical equipment has two exams, one for the inspection and testing, and one for the management of the inspection and testing, normally taken one after the other, but two independent qualifications.
  6. MGW

    MGW Screwfix Select

    Don't know where you got that from, but that is not what it says in the IET book. As said
    The "fixed" means items like the immersion heater comes under the EICR which is fair enough, but it also means the boiler is included, but normally the EICR would use the LIM code to allow for that to be under contract to some one else to inspect and test normally some one gas safe.

    There is an IET book on the "The inspection and testing of in-service electrical equipment" and that is normally considered to be the document used when doing The inspection and testing of in-service electrical equipment.

    The name has been cut short in quote The Electricity Safety should say The Electricity Safety, Quality and Continuity Regulations 2002

    So heated towel rail or built in dish washer are intended to be permanently connected so even if fitted with a plug and socket they are part of the EICR not PAT testing.
    Last edited: Feb 25, 2021
  7. Bogle Crag

    Bogle Crag Screwfix Select

    For what it costs my motto is "if in doubt test it"
    spike47 likes this.
  8. Bazza-spark

    Bazza-spark Screwfix Select

    I don't have the 5th edition, but in th 4th, page 13 states:

    What should be maintained?
    All electrical systems and equipment should be maintained if danger would otherwise arise (see Figure 1).

    Other than the fixed installation, which is considered to be the installation from the meter point to the socket-outlet, or fuse connection unit, all electrical equipment in an installation, whether permanently connected or connected by a plug and socket-outlet, should be inspected and tested in accordance with the recommendations contained in this Code of Practice.

    Items of heavy plant, including air handling units (AHUs), heating ventillation and air conditioning (HVAC) systems, and other items of integrated plant and their associated systems, are not covered by this Code of Practice. These types of systems should form part of a specialized maintenance and inspection routine.The connecting cables and junction boxes for integrated plant should be inspected and tested during the electrical installations periodic inspection regime and a report of its condition given in the Electrical Installation Condtion Report.

    Note: Self-contained or two-part air conditioners and climate cotrol units, which are not AHU or HVAC systems, are within the scope of this Code of Practice.

    Fig 1.jpg

    Hope that helps.
    MGW likes this.
  9. rogerk101

    rogerk101 Screwfix Select

    Thanks everyone.
  10. MGW

    MGW Screwfix Select

    Items of heavy plant, including air handling units (AHUs), heating ventilation and air conditioning (HVAC) systems, and other items of integrated plant and their associated systems, are not covered by this Code of Practice. These types of systems should form part of a specialized maintenance and inspection routine.

    Well that covers the boiler and Gas Safe as far as IET goes, which makes sense. But the law is not as clear, but I can't see a court not going by the IET code of practice.
  11. Comlec

    Comlec Screwfix Select

    A slide from a recent webinar COP 5th edition
  12. Tricky Dicky

    Tricky Dicky Active Member

  13. rogerk101

    rogerk101 Screwfix Select

    There certainly is if you're a landlord renting a home to a tenant!
  14. MGW

    MGW Screwfix Select

    The IET in their code of practice when I did the exam gave examples of 3 months to 4 years depending on what was being tested, so an angle grinder likely 3 months but a computer likely 4 years.

    The idea was the computer will likely sit on a desk without moving for 4 years, there was also a split between visual inspection and full testing, and the 2500 volt test was only done after repairing class II equipment to ensure no extra long screw is used, it is not used for a retest.

    There is not requirement to affix labels, one can write a document to simply say 9 items in the room tested, however you need a record of all the serial numbers and date tested and it is easier to use labels than to record all the serial numbers each time tested, the equipment register links the number you have given to item to the serial number.

    The record keeping is a real pain, some one has locked away in their desk the labelling machine, so you have to return for one item, or no one knows where the table lamp is, and it turns out it was broken and replaced and no one told the maintenance department, or it had been transferred to another department. We were forever writing memos this item could not be found when doing the annual PAT testing please bring it to the maintenance department for testing before further use.

    As to if that memo would have been accepted by HSE I don't know, but we had just got fed up with chasing items so it was simply a memo these items should be presented for PAT testing before they are used again.

    The link was interesting, as I have always been told anything to do with health and safety must be in writing, although that does include email and SMS.

    However the electricity at work act is not the same as the legal requirements for landlords, we have seen this with the EICR, as to how, or even who in the local authority polices PAT testing and EICR I don't know, when the Part P started I had the LABC inspector admit he simply did not know what was permitted and he used a private firm to do the electrical inspections for him.

    Not seen many items wrongly passed or failed with PAT testing, I did one time find a mag mount drill where the drill was class II and mag mount was class I and the whole thing had been tested as a class II item, and seen many computer lead sets not tested independently from the computer, but this does not really break rules as there is no need to label.

    The big problem was items like hand driers, they are clearly in service electrical equipment, but screwed to wall and hard wired. Often the isolation was not local, so it required extension leads for the PAT tester so was tested with insulation tester instead. The company I worked for did all inspection and testing of items with a plug using the PAT tester and all others were done at same time as the EICR. But that was permitted under HSE rules, not sure with local council rules.
  15. Bogle Crag

    Bogle Crag Screwfix Select

    Who sets the rules?
  16. Comlec

    Comlec Screwfix Select

    It would help if you could post references to legislation, COPs or guidance that supports this.
  17. Bazza

    Bazza Screwfix Select

    Many landlords (and @rogerk101 perhaps?) are not aware that there are regulations to maintain free standing electrical devices in a safe condition. Namely, the 1989 Electricity at Work Regulation. However, the regulations do not state what needs to be done, by whom, or how frequently. They also do not make it a legal requirement to undertake this annually.
  18. ElecCEng

    ElecCEng Screwfix Select

    Whilst it’s maybe not explicit in the legislation, any HSE, legal or local authority policy is going to circle back to 7671 and using an ACOP. So using the latest edition of the IET code of practice would give you the correct testing intervals and definitions.

    Begs the question why people who don’t have/aren’t familiar with the latest edition of the COP are doing PAT. But then that’s part of the wider issue/debate of doing inspections without an up to date 2391, NIC etc registered members who haven’t done any kind of 18th edition update etc etc
  19. Comlec

    Comlec Screwfix Select

    This does not apply to the provision of equipment to tenants. The home is not a workplace over which the landlord has any responsibility. However, if the landlord is providing equipment in the home to workers eg the Hoover for the cleaner then the EWR will apply.

    According to the ELSCA publication ( a bit out of date but still relevant) -

    The Electrical Equipment (Safety) Regulations 1994 If a landlord provides any electrical appliances as part of a tenancy, the Electrical Equipment (Safety) Regulations require him or her to ensure that the appliances are safe when first supplied. Although there is no specific requirement for portable appliance testing to be carried out in rented accommodation, the landlord is required to take reasonable steps to ensure that appliances such as electric kettles, fridges and washing machines provided as part of the tenancy agreement are safe.
  20. Comlec

    Comlec Screwfix Select

    <rant begin>

    I suspect the millions wasted on unnecessary PAT testing cons over the decades could have been better spent on real improvements to safety. But hey ho, many low skilled jobs have been created, much money made by the testing equipment manufactures and label makers and let's not forget the delight from the jobs-worths throughout the land who revel in their false belief that bureaucracy will keep us safe.

    <rant end>
    rogerk101 and ElecCEng like this.

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