ELECTRICAL SYSTEMS
can be instructed to provide support on other issues, including the electrical capacity and resilience of a site supply, increases in electrical capacity for futureproofing, and/or guidance on contractor appointments. As an AE, it is all too easy to be over-critical. However, the ethos of the Eta Projects Authorising Engineering team is to support clients with achieving compliance against a backdrop of ageing equipment, financial constraints, and lack of resources.
Scrutiny from the
Health & Safety Executive Unfortunately, none of the above issues are regarded as excuses by the Health & Safety Executive (HSE) should an electrical incident occur. Organisations including hospitals may be able to ‘get away’ for years with non-compliance issues until an incident eventually occurs – at which point an HSE investigation may take place, and individual prosecutions and suspension notices may follow. As an AE team, we have attended meetings with the HSE in support of clients, and the first question asked tends to be: ‘Do you have an AE, and could we have a copy of their annual audit report?’ The AE may also come under scrutiny during any such investigation, and, as such, their audit report may potentially form part of the evidence in the proceedings. This puts an onus on the AE audit findings to be thorough, and, equally, for any shortfall in operational management to be made clear in the Executive Summary of the audit report and, where necessary, raised as a risk on the organisation’s risk register. We have received queries from clients as to whether COVID-19 could be seen as a defence for falling behind on routine maintenance activities, such as inspections and fixed wiring testing. While everyone understands that the pandemic has caused disruption to regular maintenance, in the event of an incident this cannot be used in mitigation against what are mandatory requirements to maintain safe electrical systems.
Compliance checks
There are several ‘quick-wins’ in achieving compliance, most of which are inexpensive to implement. These include the provision of adequate exterior signage on sub- station and switchroom doors. A compliant sign should display an electrical safety symbol and warning message, a clear indication of the name of the room, and an emergency contact number. We are constantly surprised that inadequate signage is in place, even at large hospitals.
Fundamental compliance requirements
The fundamental requirement for legal compliance is a current Electrical Safety Policy and associated procedures, for both
40 Health Estate Journal January 2022
statement from the contractor stating that anyone they send to site will be a CP. This statement can be filed within the OPM, and puts the onus firmly on the contractor to ensure that only CPs can be put to work on the site.
n Copies of completed and closed Safety Programmes, Isolation and Earthing Diagrams, and cancelled and closed Limitations of Access/Permits to Work/ Sanction to Test.
n System drawings and schematics. n Operational Restrictions or Needers received for electrical equipment on site. In the NHS these are normally issued in the form of an Estates Facility Notification (EFN) from NHS Estates on the receipt of an alert received from the Energy Networks Association (ENA).
A non-IP2X fuse compartment could expose personnel to 440 V DC.
the management and operation of the organisation’s electrical systems. i.e. a Safe System of Work (SSoW). The healthcare facility’s management team must be able to evidence that the policy and procedures are made available to all staff, and that they are applied in practice in the field. All too often during on-site audit inspections – when we come across electrical works in progress – the contractor’s response to our question, ‘What safety documents are you working under?’ is ‘My company’s RAMS (Risk Assessment Statement Methods.’ Unfortunately, in some cases, these are often not supported by a Permit to Work or any supporting safety documentation. We are seeing an increasing number of RAMS presented which are templates prepared as a desktop exercise, and which are irrelevant to the actual work undertaken, and / or the procedures schedule not being followed on site.
Operation Procedures Manuals A good evidence tool is the presence of an Operational Procedures Manual (OPM). The NHS HTM 06-02 and HTM 06-03 guidance documents provide clear guidance on the requirements for, and contents, of an OPM. HTM 06-02/03 guidance schedules 10 items for inclusion within the OPM. These are summarised as: n A copy of the Certificates of appointment issued to the Authorising Engineer, Authorised Persons, and Competent Persons (CPs).
n A Register of the contractor’s Competent Persons. A frequent issue is that a contractor may send someone to site who is not on the register of CPs, but who is suitably competent, qualified, and experienced. Rather than carrying out a last-minute assessment, or not allowing the person to carry out the task, this can be covered by a written
n The healthcare organisation should have a robust procedure in place to review and action all Alerts issued by the ENA and/or HSE.
n All EFNs and associated NEDeRS (National Equipment Defect Reporting Scheme), including any remedial works undertaken, should be filed within the OPM. The AE can assist with this by providing guidance on the actions required, or the implementation of remedial work where national defects are received.
n Demarcation agreements with other organisations such as contractors, and the supplying Distribution Network Operator (DNO). Demarcation agreements are extremely important in the demonstration of HTM compliance. Examples of demarcation agreements with other organisations include where there are shared assets on site, or commonly where a smaller site (such as a community hospital) is electrically supplied via a larger site (rather than by the DNO). Demarcation agreements with contractors should include clarification on provision of sub-station and switchroom keys, completion of maintenance records, and emergency site attendance. Operational agreements with DNOs should be in place to clarify ownership of equipment
In some cases, without proper non- intrusive testing such as thermal imaging or partial discharge, catastrophic failure can occur.
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