Electrical Safety: Portable Appliances Testing (PAT) at Sports Grounds

An image of portable electrical safety equipment

Concern has been raised with the SGSA that there may be changes to the regulations affecting the approach to inspection/testing of portable electrical appliances used within grounds; moving from a frequency (e.g. annually) to a risk based approach.

In fact there has not been a change to the Electricity at Work Regulations 1989 (Regulations) in respect of the safety, maintenance and inspection of portable and movable appliances, which effectively has always been one based on risk. Over the years there has been a misconception that the law required all portable electrical equipment used in workplaces, sports grounds included, to be independently inspected and PAT tested on a set periodical basis e.g. six monthly, annually, etc., which is not the case (see HSE guidance listed below).

In talking about portable appliance testing and inspection it is important to distinguish this from the fixed electrical installations/systems in sports grounds that in addition to being covered by the Regulations are referenced in Section 17 of the Green Guide, and likely within specific ground General Safety Certificates in respect of maintenance, inspection and testing regimes.

It is important to note that there is absolutely no mention of PAT in the Regulations but stems from the duty holder’s duty under Regulation 4(2) to maintain electrical systems if they can cause danger, neither does the law say how you as a duty holder must do this or how often. The term ‘system’ is broadly defined in the Regulations and includes electrical equipment, some types of which have become known as “portable appliances”.

Essentially, the law is saying that the duty holder should decided the level of maintenance needed in respect of portable or moveable electrical equipment according to the risk of an item becoming faulty, and how the equipment is constructed. Obviously, a duty holder in making such decisions on types and frequency of inspections and test can refer to a competent person and/or electrician.

When deciding on appropriate maintenance plans for inspection, testing and repair of electrical equipment consideration should be given to:

  • increased risks from equipment not being used correctly, not suitable for the job, is used in harsh environments (e.g. outdoors), frequently moved; and
  • the equipment is not double insulated.

This responsibility applies to all electrical equipment that employees use at work, even if it is their own, although this is not advised as something that should be permitted. Duty holders also have a joint responsibility to maintain any equipment used that is either leased or provided by a contractor, but this does not extend to electrical equipment both provided and used by contractors (e.g. TV companies). However, it should be remembered that when a contractor company or indeed self-employed person is working within your ground and using their own electrical equipment, the ground management still have a degree of responsibility to ensure that employee and public safety is not put at risk by visiting contractor’s activities.

A portable or movable electric appliance is any item that can be moved, either connected or disconnected from an electrical supply, and generally such items have a lead (cable) and a plug. Such equipment includes:

  • equipment that can be easily moved around, such as kettles, cleaners, floor polishers, heaters, fans, hairdryers, lamps, UV equipment, small cookers, pitch perimeter advertising units etc.;
  • larger less frequently moved items such as water chillers, fridges, microwaves, vending machines, washing machines, cookers, computers;
  • hand-held items, such as hairdryers, that do not have a plug but have been wire in (or fixed) are still considered to be portable appliances, but large items such as wired in water boilers are not as they are not designed to be moved and would come under the scope of fixed installation maintenance;
  • battery charging equipment plugged into the mains; and
  • extension leads, multi-way adaptors and connection leads.

What is clear is that duty holders/ground management have a responsibility to maintain electrical equipment if it can cause danger. How you ensure safety of electrical equipment through a maintenance plan identifying the appropriate and necessary user checks, visual inspections and portable appliance tests should be determined according to risk. To assist those with the task of ensuring the safety of electrical equipment useful tables are provided within the two guidance documents below that suggest initial intervals for maintenance and checking portable equipment.

  1. Maintaining portable electric equipment in low-risk environments – Leaflet INDG236(rev3)  www.hse.gov.uk/pubns/indg236.htm
  2. Maintaining portable electrical equipment - HSG107 (third edition)  www.hse.gov.uk/pubns/books/hsg107.htm