The Finding
Some items are PAT tested more frequently than strictly necessary e.g copiers. HSE website gives suggested testing frequencies.
Some Context to the Finding
The company, which specialises in supplying paper, had identified all of the items which required Portable Appliance Testing (PAT) but had applied a blanket test frequency of one year against each piece of equipment.
The assessor correctly alerted the client to the fact that the Health & Safety Executive (HSE) website https://www.hse.gov.uk/electricity/faq-portable-appliance-testing.htm highlights the fact that the legislation doesn't actually specify the frequency of testing required:
"The Electricity at Work Regulations 1989 require that any electrical equipment that has the potential to cause injury is maintained in a safe condition. However, the Regulations do not specify what needs to be done, by whom or how frequently (ie they don't make inspection or testing of electrical appliances a legal requirement, nor do they make it a legal requirement to undertake this annually)."
Action taken to address the finding
Instead of assuming that all electrical equipment must be tested at the same interval, the client adopted a risk based approach. Consequently, items such as photocopiers (where the electrical cable has little stress) are scheduled for testing less frequently than items such as kettles or laptops (where cables are more likely to become frayed).
Taking this action ensured legal compliance but also helped to reduce costs, as some items are tested much less frequently.
Lessons to take from this finding
When planning a health and safety management system it is important to understand what legislation applies (clause 6.1.3 is also applicable) and how that actually applies within the context of your own organisation.
With a proper understanding of what legislation applies and how, the organisation can then truly implement an appropriate system of testing that meets legal requirements whilst also helping to minimise expenditure on unecessary tests.
When implementing a health and safety management system, the HSE website is an excellent source of freely available information which typically uses plain English to help interpret the legal requirements.
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