Queensland Regulatory Impact Statement for SL 2002 No. 180 Electricity Act 1994 ELECTRICITY AMENDMENT REGULATION (No. 3) 2002 TITLE Proposed Legislation for Safety Switches in Domestic Dwellings. BACKGROUND The “safety switch” is an electrical device that senses electrical current imbalance between the current flowing in the active and neutral conductors of a circuit. If a person comes into contact with the active conductor of an electrical circuit their body can provide a conductive path to earth. The current flowing through the person’s body can cause injury or death. A safety switch senses the imbalance in the active and neutral conductors, causing it to cut off the power. Because safety switches are very sensitive they operate before the current going through a person is able to reach a value that is detrimental to the person and protects them from injury or death due to electrocution. A safety switch will prevent a person receiving an electric shock in circumstances such as where— • a knife is inserted into a toaster to clear bread accidentally comes into contact with the live electrical circuit; • the power lead of an electric saw is accidentally cut during use; • a screw inserted into a wall to hang a picture inadvertently comes into contact with the power circuit wiring; or • a hairdryer is accidentally dropped into a basin of water. From 1991–92 to December 2000 Queensland has had an average of 4 fatalities per year due to consumer related electrocutions that could have 2 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 been prevented if domestic dwellings were fitted with a safety switch to protect power circuits. The summary of the statistics of electrical accidents from the period 1991–92 to December 2000 is included at Attachment 1. Queensland, on a per million population basis, has a poor record in terms of the number of fatalities caused by electrical incidents when compared to other Australian States, refer to Attachment 2. In domestic dwellings, electrocutions from power circuits (fixed wires) are at least 4 times more prevalent than those resulting from lighting circuits. In September 1999, R McGuigan and D Williams were contracted to investigate public safety and other consumer related issues of Queensland. In 2000 an Electricity Safety Taskforce was formed to consider ways of improving the manner in which electrical incidents can be prevented. A key recommendation from both the McGuigan Williams Report on ‘Public Safety’ and the findings of the Electricity Safety Taskforce was mandatory installation of safety switches in all consumer premises with a phasing in period or at point of sale where they are not already fitted. An Electrical Safety Switch Working Group was established by the then Minister for Mines and Energy, the Hon. Tony McGrady MP, to investigate and implement appropriate measures to achieve this goal. The Electrical Safety Switch Working Group conducted an in depth investigation into the implementation of the recommendation to have safety switches installed in domestic dwellings. The investigation included the following— • assessing and updating the statistics of electrical accidents to confirm the level of potential benefits associated with the installation of safety switches; • consultation with the Electricity Safety Office in the Department of Industrial Relations, ENERGEX, Ergon Energy, Department of State Development, Department of Housing and the National Electrical Contractors’ Association; • consideration of the financial impacts on the community of mandatory safety switches and mechanisms to reduce those impacts; and • consideration of alternative options to reduce the unacceptable number of fatalities and injuries as a result of electric shock in domestic dwellings. The reports of the Independent Review of the Electrical Safety Office and the Electrical Safety Taskforce, noted that fixed wiring in domestic 3 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 homes is the third largest contributor to electrical incidents in Queensland over the last 20 years. This accounts for some 25% of total fatalities over this period. The reports recommended— • the installation of safety switches on a least the power circuits in domestic dwellings; and • an electrical inspection of all domestic dwellings at the point of sale. The inspection reports of domestic homes provided by the electrical distributors have identified electrical hazards including lack of maintenance of electrical equipment, faulty and unsafe fixed wiring and do-it-yourself electrical work. Point of sale electrical inspections was identified as one measure that may minimise the risk of electric shock. Queensland requires all domestic dwellings constructed since 1992 to have a safety switch installed. The Electricity Regulation 1994 requires that electrical installations be wired in accordance with the SAA Wiring Rules AS/NZS 3000 (“the Wiring Rules”). The Wiring Rules (1991) required that new houses have a safety switch installed on power circuits. There was no requirement in the rules for houses built prior to these requirements to have safety switches installed. As a result, it has been estimated that approximately 500 000 dwellings in Queensland do not have safety switches installed to protect any circuit. The estimate of 500 000 dwellings was arrived using data collated by the Electricity Development Association of Queensland in their report entitled ‘The Application of Residual Current Devices in the Minimisation of the Frequency and Severity of Electrical Accidents in Queensland 1997’, see Attachment 3. The Wiring Rules were amended on 1 June 2000. This amendment requires safety switches to be installed on power and lighting circuits on new houses from 1 June 2000. The 1 June 2000 amendment is a national standard which also reflects international standards for electrical safety. AUTHORISING LAW An objective of the Queensland Electricity Act 1994 is ‘to promote electricity safety’. This is given effect by the Electricity Regulation 1994, which aims to ensure the electricity safety of electrical workers, other workers, customers and the general public, section 3(a). Section 264 of the Electricity Act 1994 provides the head of power for the making of a regulation. A regulation may be made about matters mentioned in schedule 2, section 264(1), which provides technical, 4 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 operational and safety requirements relating to works and installations. For the purposes of the Act, a domestic dwelling is an electrical installation. POLICY OBJECTIVE The objective of the options outlined in this Regulatory Impact Statement is to prevent fatalities and injuries to the public caused by electric shock in domestic dwellings. The majority of these fatalities and injuries occur because domestic dwelling built prior to 1992 are not required to have safety switches installed on at least power circuits. The potential for death or injury from electric shocks in domestic dwellings if a safety switch has not been installed increases substantially. Over the past 10 years Queensland has had an average of 4 fatalities per year due to electrocution in domestic premises and a total of 1966 injuries reported as a result of electrical incidents. Most of these fatalities and injuries would have been prevented by the installation of a safety switch. If a decision were made not to mandate the installation of safety switches in all Queensland domestic dwellings, an estimated 500 000 houses would remain without safety switch protection. Without the added protection of safety switches on at least power circuits preventable fatalities will continue to occur. While other Australian States have only introduced legislation mandating the installation of safety switches in new domestic dwellings, Victoria and Western Australia are drafting legislation to make the installation of safety switches a requirement at ‘point of sale’ of a domestic dwelling. HOW THE POLICY OBJECTIVE WILL BE ACHIEVED The Electrical Safety Switch Working Group identified and assessed 7 options based around the installation of safety switches in all domestic dwellings to reduce fatalities and injuries caused by electric shocks. Details on the costings in each of the options is available by contacting the department on telephone 3006–4086. The 7 options are as follows— • option 1—No regulatory intervention. Invoke a public awareness program on the benefits to be gained from the protection provided by safety switches installed on electrical circuits; • option 2—Introduce the mandatory installation of safety switches on— 5 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 • both power and lighting circuits, phased in over a 7 year period; and • power circuits, phased in over a 7 year period • option 3—Mandate the installation of safety switches to protect power circuits, at the point of sale of a domestic dwelling; • option 4—Require electricity distributors to install safety switches in domestic dwellings; • option 5—Mandate an immediate requirement for an “electrical safety check” of a domestic dwelling at the point of sale; • option 6—A combination of options 3 and 5. Under this option as well as installing safety switches at the point of sale of a domestic dwelling, the home owner will be required to have electrical safety check at the point of sale of the dwelling. The advantages and disadvantages of these options are examined in the Regulatory Impact Statement. In particular, the costs and benefits associated with the preferred option, option 3, are examined in detail as it imposes a significant cost on part of the community. However, they are deemed necessary in order to reduce the number of fatalities and injuries due to electrocution, which occur in private dwellings in Queensland. While the electricity supply distributors have advertised the benefits of the installation of safety switches, the “take up rate” by existing homeowners has been poor despite advertising and previous rebate schemes. It is currently estimated that 500 000 domestic dwellings in Queensland do not have a safety switch installed. To address the risk of electric shock and reduce the number of fatalities and injuries in domestic dwellings, it is proposed to regulate the mandatory fitting of safety switches to protect power circuits at point of sale of a domestic dwelling. It is considered not only appropriate but also essential, to set a mandatory approach by making subordinate legislation requiring the installation of safety switches on power circuits. Homeowners would also be encouraged to install safety switches to protect lighting circuits in all domestic dwellings. A media campaign will be conducted to raise public awareness of the advantages of having safety switches installed and the impending legislative requirements. 6 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 CONSISTENCY WITH AUTHORISING LAW AND OTHER LEGISLATION The proposed amendment regulation supports the requirements of the Electricity Act 1994, which has as an objective ‘to promote electrical safety’, section 3(c). The proposed amendment also is consistent with the Electricity Regulation 1994 which has as one of its main purposes to ‘Promote electrical safety and to ensure the electrical safety of electrical workers, other workers, customers and the general public’, section 3 (a). The objective of the Workplace Health and Safety Act 1995 is to prevent a person’s death, injury or illness being caused by a workplace, workplace activity or specified high-risk plant. The objective is achieved by preventing or minimising a person’s exposure to the risk of death, injury or illness caused by a workplace, workplace activity or specified high-risk plant. The proposed legislation is no more onerous than the requirements of the Workplace Health and Safety Regulation 1997, which requires all equipment used in a workplace to be connected to a safety switch either at the switchboard or via a lead that must be connected to a portable safety switch. The Workplace Health and Safety Act 1995 and Workplace Health and Safety Regulation 1997 require industrial and commercial installations to have safety switches installed or used in conjunction with appliances. Caravan parks and camping grounds are considered commercial installations and are covered by these requirements. The Electricity Regulation 1994 also requires electrical installations to meet the AS/NZS–AS3000 Wiring Rules. The proposed legislation extends the requirements in the Wiring Rules to include protection for those domestic dwellings built before 1992 that were not previously covered. Options 2, 3, 4, 5 and 6 outline regulatory options that are consistent with the authorising law. 7 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 OPTIONS AND ALTERNATIVES Option 1—No regulatory intervention—Invoke a public awareness campaign Option 1 will maintain the current situation where it is a decision of the owner of a domestic dwelling built before 1992, whether to install a safety switch. Advantages and disadvantages of option 1 An advantage of option 1 is that, while it offers a non-regulatory approach it ensures increased public awareness of the risks associated with the use of electricity and the advantages of safety switches in protecting householders from the risk of electric shock in domestic dwellings. The main disadvantage of option 1 is that it is not in the interest of the safety of Queensland householders. Doing nothing would deny the Queensland householders protection against an average of 4 fatal accidents per year and many injuries. While advertising and promotion may result in an increase in the number of safety switches installed, high impact advertising on television and radio is expensive, and experience to date would tend to indicate that significant numbers of homeowners are not influenced to purchase and install safety switches. The costs associated with a public awareness campaign have been estimated at $3.85m over a 7 year period. Option 2(A)—Mandate the installation of safety switches on both power and lighting circuits Option 2 is a new regulation that would require the owners of all domestic dwellings to install a safety switch on all lighting and power circuits. Homeowners would have 7 years to install the safety switch from the date the regulation is made. 8 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 Advantages and disadvantages of option 2(A) The main advantages of this option are that it would— • significantly reduce the number of fatalities and injuries from electric shock in the estimated 500 000 domestic dwellings that do not have safety switches installed; and • ensure consistency between existing and new homeowners. From 1 June 2000, the Wiring Rules require safety switches to be installed on both power and lighting circuits for new houses. The previous Wiring Rules, which were in place from July 1992 to 2000, required safety switches on power circuits only; and • provide time for the market to manage demand for installation of safety switches through a ‘phase in’ period of 7 years. The main disadvantage of option 2(A) is the cost to homeowners installing safety switches on both power and lighting circuits instead of just power circuits increases from $84.5m to $135m. In addition, as homeowners will have 7 years to install a safety switch there will be the potential for fatalities and injuries as a result of electric shocks until such time as safety switches are installed. Statistics have shown that electrical incidents occur at least 4 times more frequently on power circuits than on lighting circuits. The primary reason for changing the Wiring Rules to require safety switches to be installed on both power and lighting circuits for new houses was that modern house construction is increasingly using metal frames, which substantially increases the chance of lighting circuits developing life threatening faults by conducting electricity. Older housing tends to have timber frames, which significantly reduce the risk of life threatening faults from lighting circuits. The cost of option 2(A) over a 7 year period would be $135m for homeowners and $3.85m for the public awareness campaign. Option 2(B)—Mandate the installation of safety switches on power circuits Option 2(B) is a new regulation that would require the owners of all domestic dwellings to install a safety switch on power circuits within 7 years from the date the regulation was made. 9 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 Advantages and disadvantages of option 2(B) The main advantages of option 2(B) are that it would provide— • protection against electric shock in domestic dwellings by requiring the installation of a safety switch in the estimated 500 000 domestic dwellings that do not have safety switches installed on the power circuits. Power circuits are 4 times more likely to be involved in electrical shocks than lighting circuits; • a transition period, where the mandatory installation of safety switches only applies after the 7 year phase in period ensures the market is in a better position to manage demand for installation of safety switches. The disadvantage of this option is that homeowners will have 7 years to install a safety switch. There will continue to be the potential for fatalities and injuries as a result of electric shocks from power circuits in domestic dwellings until such time as safety switches are installed. However, a public awareness campaign to encourage the installation of safety switches will be timed to coincide with the making of the proposed regulations. The cost to the homeowners of installing safety switches on power circuits is estimated at $84.5m over the 7 year period. The electricity distributors Energex and Ergon currently allow homeowners to pay off the installation of a safety switch by instalments as part of their electricity bill, where they install the safety switch. Energex and Ergon advise that they intend to continue to provide this service to their customers. While this option will mandate safety switch protection of power circuits, homeowners could be encouraged through a promotional campaign to also install safety switch protection on lighting circuits. The cost for the public awareness campaign over a 7 year period would be $3.85m. Option 3—Mandate installation of safety switches to protect power circuits, at the point of sale of domestic dwelling Option 3 is a new regulation that would require the owners of all domestic dwellings to install a safety switch on power circuits at the point they sold the house (point of sale). 10 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 Advantages and disadvantages of option 3 The main advantages of option 3 are that it would provide— • protection against electric shock in domestic dwellings by requiring the installation of a safety switch in the estimated 500 000 domestic dwellings that do not have safety switches installed on the power circuits. Power circuits are 4 times more likely to be involved in electrical shocks than lighting circuits; • a transition period, where the mandatory installation of safety switches only applies at the point of sale of a house ensures the market is in a better position to manage demand for installation of safety switches. The disadvantage of this option is that it is likely to take on average, up to 15 years to install safety switches in most domestic dwellings built prior to 1992. There will continue to be the potential for fatalities and injuries as a result of electric shocks from power circuits in domestic dwellings until such time as safety switches are installed. However, a media campaign to encourage the installation of safety switches will be timed to coincide with the making of the proposed regulations. The cost to homeowners of installing safety switches on power circuits is estimated at $69.8m. The electricity distributors Energex and Ergon currently allow homeowners to pay off the installation of a safety switch by instalments as part of their electricity bill. Energex and Ergon advise that they intend to continue to provide this service to their customers, where they install the safety switch. While this option will mandate safety switch protection of power circuits, homeowners could be encouraged through a promotional campaign to also install safety switch protection on lighting circuits. The cost for the public awareness campaign over a 7 year period would be $3.85m. Option 4—Require electricity distributors to install safety switches Option 4 is a new regulation that would require the distributors of electricity to install safety switches on the power circuits of all customers’ domestic dwellings built before 1992, within 7 years from the date the regulation was made. 11 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 Under the Electricity Act 1994 and the Electricity Regulation 1994 the electricity distributors have responsibility to— • check to confirm that the domestic dwelling is not likely to cause shock or fire; • advise the homeowner and the public on electrical safety; and • promote electrical safety. Advantages and disadvantages of option 4 The advantage of option 4 is that the electricity distributors would ensure the systematic installation of safety switches without the involvement of, or financial cost to homeowners, thereby ensuring protection against electric shock in all domestic dwellings that currently do not have a safety switch installed on the power circuits. The main disadvantage of this option is that it will impose expenditure on the electricity distributors of approximately $84.5m, which can only be raised through increased electricity tariffs. This option would have the effect of requiring the owners of houses built after 1992 (which have a safety switch) and those who have voluntarily installed a safety switch to contribute to the cost of installing safety switches in the estimated 500 000 domestic dwellings without a safety switch. Option 5—Mandate an immediate requirement for an “electrical safety check” of a domestic dwelling at the point of sale Option 5 is a new regulation that would require the owner of a domestic dwelling to have an electrical safety check (inspection) of the dwelling prior to sale to determine compliance with the required electrical standards. Although non-compliance would not prevent the sale of a dwelling, the purchaser would be aware of any identified deficiencies and may seek to have these repaired as a condition of the sale. Advantages and disadvantages of option 5 The advantage of option 5 is that it would identify electrical faults in a domestic dwelling enabling the purchaser to be in an informed position at the time of purchase. Inspection reports of domestic homes provided to the Electrical Safety Taskforce by the electrical distributors reveal a large number of electrical hazards including lack of maintenance of electrical 12 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 equipment, faulty and unsafe fixed wiring and do-it-yourself electrical work. Point of sale electrical inspections are one measure that minimises the potential for electric shocks and they also provide for the independent verification of the installation of a safety switch. The disadvantages of this option are as follows— • this option would identify domestic dwellings requiring electrical work at the point of sale. However, it is unlikely to reduce the number of fatalities in domestic dwellings unless combined with an option requiring the mandatory installation of safety switches; and • safety checks are not necessary on electrical circuits connected through a safety switch. A safety switch will shut off the electricity to a circuit that has a fault or faulty appliance attached making it inoperable. This will reduce the need for a safety check of those circuits. While this is an alternative that could be combined with invoking a public awareness campaign (option 1) and mandating safety switches at point of sale (option 3), the costs associated with this option can not be justified in terms of improved electrical safety performance. The cost to the homeowners of electrical safety checks at the point of sale has been estimated at $155 per inspection or $122m over a 7 year period. This is based on sales of domestic dwellings in Queensland at a cost of $20.6m per annum. Option 6—Installing a safety switch and conduct an electrical safety check at the point of sale of a domestic dwelling Option 6 is a new regulation that would combine options 3 and 5. Under this option the owner of a domestic dwelling would have to— • install a safety switch on power circuits at the point they sold the house (point of sale) from the date the regulation was made; and • have an electrical safety check of the dwelling undertaken prior to sale to determine compliance with the required electrical standards. Although non-compliance would not prevent the sale of a dwelling, the purchaser would be aware of any identified deficiencies and may seek to have these repaired as a condition of the sale. 13 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 Advantages and disadvantages of option 6 The advantage of option 6 is that it would identify electrical faults in domestic dwellings enabling the purchaser to be in an informed position at the time of purchase, as well as ensuring the purchaser was afforded the protection of a safety switch to protect against the risk of electrical shock. Point of sale electrical checks would provide an independent verification of the installation of a safety switch. The disadvantage of this option is the cost. In addition to the estimated cost of $68.9m for the installation of safety switches on power circuits, vendors also would be faced with the costs of $122m for the electrical safety checks over a 7 year period. Accordingly, the total cost of this option over a 7 year period is $210.4m. COSTS AND BENEFITS OF OPTION 3 (PREFERRED OPTION) Option 3 Without mandatory installation of safety switches on power circuits in domestic dwellings, at least 4 lives will be lost per year due to preventable electrical incidents in the home. Over a 20 year period the installation of safety switches in domestic dwellings has the potential to save an estimated 80 lives. In addition, there is the potential to reduce costs associated with non-fatal injuries and to prevent fire damage resulting from electrical faults. The cost associated with the installation of a safety switch is a once off cost for the homeowner. Once a safety switch is installed on an electrical circuit the protection is continuous. Unless subjected to unusual damage the switch will not deteriorate and only requires occasional testing. The proposed amendment to the Electricity Regulation 1994 will not require the immediate installation of safety switches to domestic dwellings. However, a safety switch will be mandatory at the point of sale of a dwelling. If it is not installed, the new owner will have to install one within 3 months from the date of purchase. The electricity distributors and/or contractors will verify the installation of a safety switch when electrical work is carried out on a dwelling through a sticker system. The contractor or electricity distributors will place a sticker on the switchboard to alert the owner/occupant as to whether a safety switch has been installed. 14 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 The electricity distributors and/or contractors will verify installation of a safety switch when connecting the electricity for new owners. Where a dwelling has been sold which does not have a safety switch, the electricity distributor or contractor will be prohibited from undertaking electrical work on the dwelling other than connecting the power, unless a safety switch is installed as part of the electrical work. The Electrical Safety Office in the Department of Industrial Relations manages complaints about electrical work for the Electrical Workers and Contractors Board. The Electrical Safety Office will deal with consumer complaints about the installation of safety switches. Once the safety switches are installed the benefit of the protection against electric shocks is ongoing. Once installed and maintained correctly, the safety switch will continue to provide protection in excess of 20 years. Loss of life or a hospitalisation due to electric shock could be prevented for the cost of installing a safety switch. In addition, house fires resulting from electrical faults would be significantly reduced. Costs Since the period 1996–97 to December 1999 the number of domestic consumers has grown from 1 329 811 to 1 382 747. No data is available to indicate the number of safety switches installed during the period. It is estimated that there are at least 500 000 domestic dwellings do not have safety switch protection on power circuits. The estimate of 500 000 dwellings was arrived at using data collated by the Electricity Development Association of Queensland in their entitled ‘The Application of Residual Current Devices in the Minimisation of the Frequency and Severity of Electrical Accidents in Queensland 1997’. The cost of installing safety switch protection on a dwelling for power circuits will depend on the number of circuits installed and whether the household wishes to isolate particular circuits so if a fault occurs, they will not lose power from the remaining circuits. A simple installation would involve a single power circuit. This can be done by using a single safety switch, or by replacing the existing fuse or circuit breaker with a miniature circuit breaker/safety switch combination. The cost for this switchboard modification for protection of a single power circuit would be approximately $200. Once installed, the safety switch does not consume any electricity, as it is purely a protective device. 15 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 The provision of safety switch protection for each circuit of a more complex installation may include 3 phases with multiple power circuits, resulting in considerable escalation of cost if all circuits are to be individually protected. The individual protection of power circuits with a safety switch will not be required by the proposed regulation. The total cost of upgrading 500 000 dwellings requiring the added safety switch protection on power circuits is estimated as $69.8m. The electricity distributors Energex and Ergon currently allow homeowners to pay off the installation of a safety switch by instalments as part of their electricity bill, where they install the safety switch. Energex and Ergon advise that they intend to continue to offer this service to their customers. The other area of impact will be the requirement for electricity distributors and contractors who undertake electrical work on a domestic dwelling to determine if a safety switch has been installed and to place a sticker on the switchboard. The REIQ contract will require revision to include a statement about safety switches. This would be an initial cost to the REIQ and once the form is standardised the REIQ would not incur any additional cost in amending their standard contract. Circuit Cost Based on 500 000 dwellings with no safety switch protection Power circuits 1 per household = $69.8m Appliances Costs covered by and cords power circuits Refrigerators Costs covered by power circuits Total costs $69.8m Benefit Reduced fatalities over 20 years (number of fatalities) Reduced hospitalisation over 20 years (number of hospitalisations) 28 52 Reduced incidents other than fatal of required hospitalisation over 20 years (number of accidents) 2980 48 292 1440 4 30 640 80 372 5060 Source—Office of Energy Queensland Treasury The costs and benefit statistics shown in the above table are estimates only but they can be used as a guide for the order of magnitude of the costs 16 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 and benefits likely to result from the implementation of any project to install safety switches on the electrical circuits. The estimated cost of a hospital bed is $500 per day plus an additional $200 medical fee and an average of two days hospitalisation; the estimated cost saving in hospitalisations is equal to approximately $500 000 over the 20 year period. Incidents that do not require medical attention also impose a cost on the community. These costs relate to investigation costs by the Electrical Safety Office and electricity distributors. A conservative estimate of these costs is $200 per incident. Over the period of 20 years this will amount to approximately $1m. While the direct benefit from the fitting of safety switches is that of saving people from the effects of electric shock, there is also an indirect benefit associated with the operation of the safety switch. If left unchecked, the effects of an electrical fault can result in arcing or overload at the fault which may result in a fire. The electrical fault, which often causes a fire, is caused by a defective electrical termination. Where a sustained arc occurs, the current can in some instances partly or wholly bypass the neutral return path. In such cases a safety switch can quickly extinguish the arc and thus prevent a fire from occurring. Over the past five years there have been 4035 house fires that have been caused by electrical faults. This is an average of approximately 800 per year. Safety switches would not have operated in response to all types of electrical faults that cause a fire, however, if it is assumed that a safety switch operating on a tenth of the faults that have caused a fire, approximately 80 fires per annum could be prevented. Although there is no data available as to the cost of the fires, it can be seen that even at a very conservative estimate of $10 000 per fire (without considering loss of life), the cost is estimated as $800 000 per annum or $16m over 20 year period (source—Energy Division, Queensland Treasury). This gives an order of magnitude to the cost of fires that may be prevented by the installation of safety switches. In terms of commercial benefits, if safety switches have to be installed then the safety switch supplier would benefit from the sale. This is a boost to the suppliers as there would be approximately 500 000 switches required. All of the necessary equipment can be supplied from Queensland sources, providing a boost to local industry. There will be a gain of additional business by contractors and safety switch suppliers over the period of time when the switches are being installed. Contractors would be required to install the safety switches. This would involve labour amounting to approximately 2 million working-hours 17 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 to install the safety switches. This may also provide a temporary boost to local employment. CONSISTENCY PRINCIPLES WITH FUNDAMENTAL LEGISLATIVE The Legislative Standards Act 1992 outlines fundamental legislative principles that require legislation to have sufficient regard to the rights and liberties of individuals and the institution of Parliament. It is considered that the proposed regulation in option 3 has sufficient regard for these principles. The drafting of any legislation about the installation of safety switches would include an assessment of whether the legislation has sufficient regard for fundamental legislative principles. NATIONAL COMPETITION POLICY The Queensland Government is party to the Competition Principles Agreement agreed to by the Council of Australian Governments in 1995 (amended in 2000). The guiding principle of this agreement is that legislation should not restrict competition unless it can be demonstrated that— • the benefits of the restriction to the community as a whole outweigh the costs; and • the objectives of the legislation can only be achieved by restricting competition. Fundamental to the National Competition Policy analysis is whether any of the options under consideration can meet the relevant policy objectives i.e. to protect householders (families) in domestic dwellings from the risk of death or injury due to electric shock. If more than one option can do so, which one does so with the least adverse effect on competition? As all regulatory options are based around the installation of safety switches, each option has a similar effect on competition. The proposed amendment to the regulation does not favour any brand or equipment manufacturer. Any make of safety switch can be used providing it meets approved test standards, which certify that it is capable of performing the required protection function. The installation of the safety switch is not restricted to any electrical contractor or distributing authority. The only requirement is that the installer be licensed to carry out electrical work on a domestic dwelling. The homeowner is free to select any electrical contractor to carry out the installation of safety switch in their dwelling. 18 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 CONCLUSION The Electrical Safety Taskforce final report A Review of Industry Compliance with Electrical Safety Standards and the Investigation of Serious Electrical Incidents noted that Queensland has the highest fatality rate from electrocution in Australia by a factor of at least 2. The report went on to state that a ‘Comparison with some European countries indicate that Australia overall is proportionally worse. Therefore, Queensland consistently rates among the worst performers in the western world’. It is considered that the benefits derived from consumers having safety switches installed on at least power circuits, greatly outweighs the costs of the installation of the switches. Therefore, mandating of the installation of safety switches on at least the power circuits of domestic dwellings is recommended. At the present time Queensland does not have electrical safety legislation that requires the installation of safety switches in domestic dwellings built before 1991. The Regulatory Impact Statement examines 7 options for achieving a reduction in fatalities and injuries from electric shock in domestic dwellings and has concluded that— • option 1 is not likely to reduce number of fatalities and injuries in the short to medium term; • option 2(A) and (B) will protect householders, but impose additional costs on the community in comparison to option 3; • option 3 imposes significant costs on the community, however, it is considered the most practical option of reducing the human and financial cost associated with electric shocks in domestic dwellings; • option 4 will protect householders, however, it imposes costs on specific sections of the community who have previously installed safety switches; • option 5 is not likely to reduce number of fatalities and injuries in the short to medium term; and • option 6 imposes significant costs on the community that are additional to option 3. In view of this additional cost, option 6 is not considered to be the most effective option for reducing the human and financial cost associated with electric shocks in domestic dwellings; The objective of the proposed amendment to the Electricity Regulation 1994 is to prevent fatalities and injuries to the public caused by electric shock in domestic dwellings. There is no doubt that safety switches 19 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 provide the ability to significantly reduce the number of fatalities and injuries caused by electric shock. 20 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 ATTACHMENT 1 ELECTRICAL FATALITIES 1991–1992 TO 2000–2001 Domestic Probably Commercial Probably Industrial Probably Prevented Prevented Prevented with Safety with Safety with Safety Switch Switch Switch Substations 1 0 Powerlines 9 0 16 0 6 0 Fixed 16 14 12 10 5 5 wiring Flexible 8 8 3 3 1 1 cords and cord fittings Appliances, 17 16 7 5 3 2 handlamps and tools Private 1 1 1 1 plant Total 51 39 38 18 17 9 Source—Electrical Safety Office, Department of Industrial Relations Fatalities per Million Persons 11.00 1995/96 10.00 1996/97 9.00 1997/98 8.00 1998/99 7.00 6.00 1999/00 2000/01 5.00 4.00 3.00 2.00 per Millions Fatalities 1.00 0.00 ACT NSW NT QLD SA Region TAS VIC WA NZ 21 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 ATTACHMENT 2 COMPARISON OF ELECTRICAL STATISTICS IN AUSTRALIA Electrical Accident Fatalities 2000/01 11 10 9 8 7 6 5 4 3 2 1 0 ACT NSW NT QLD SA TAS VIC WA Region Trend of Fatalities per Million Australian and NZ 3.50 Fa tali tie s pe r Mil lio n 3.00 2.50 AUSTRALIA 2.00 NZ Total 1.50 1.00 0.50 0.00 1995/96 1996/97 1997/98 Year 1998/99 1999/00 2000/01 22 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 ATTACHMENT 3 EDAQ THE APPLICATION OF RESIDUAL CURRENT DEVICES IN THE MINIMISATION OF THE FREQUENCY AND SEVERITY OF ELECTRICAL ACCIDENTS IN QUEENSLAND An Electrical Safety Initiative of the Queensland Government R Dunstan EDAQ October 1997 Electrical Development Association of Queensland (Inc.) 23 Electricity Amendment Regulation (No. 3) 2002 TABLE OF CONTENTS SYNOPSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . 3 1.1 Project Brief. . . . . . . . . . . . . . . . . . . . . . . . 3 1.2 Project Background . . . . . . . . . . . . . . . . . . 3 1.3 Project Scope . . . . . . . . . . . . . . . . . . . . . . . 3 1.4 Project Methodology . . . . . . . . . . . . . . . . . 4 1.4.1 Consultation . . . . . . . . . . . . . . . . . . . . . . 4 1.4.2 Analysis. . . . . . . . . . . . . . . . . . . . . . . . . . 5 1.5 Limitations. . . . . . . . . . . . . . . . . . . . . . . . . 5 2.0 FINDINGS. . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 2.1 Consultative Process Feedback . . . . . . . . . . . . 6 2.1.1 Nuisance Tripping. . . . . . . . . . . . . . . . . . 6 2.1.2 Heating Elements . . . . . . . . . . . . . . . . . . 7 2.1.3 Lighting Circuits. . . . . . . . . . . . . . . . . . . 9 2.1.4 Portable Equipment . . . . . . . . . . . . . . . . 9 2.1.5 Power Circuits. . . . . . . . . . . . . . . . . . . . 10 2.1.6 All Circuits . . . . . . . . . . . . . . . . . . . . . . 10 2.1.7 Quasi Domestic Situations . . . . . . . . . . 10 2.1.8 Non Complying Existing Installations . 11 2.1.9 Performance and Reliability . . . . . . . . . 12 2.1.10 How Should RCDs be installed . . . . . .13 2.1.11 AS3000. . . . . . . . . . . . . . . . . . . . . . . . .13 2.1.12 Alternative Approaches. . . . . . . . . . . . .14 No. 180, 2002 24 Electricity Amendment Regulation (No. 3) 2002 2.2 Accident Analysis . . . . . . . . . . . . . . . . . . . . . .14 2.2.1 Power Lines and Service Mains . . . . . . .14 2.2.2 Switchboards and Sub Mains . . . . . . . . .15 2.2.3 Final Circuits, Appliances and Cords . . .16 3.0 COSTS AND BENEFITS . . . . . . . . . . . . . . . .20 3.1 Domestic . . . . . . . . . . . . . . . . . . . . . . . . . .20 3.1.1 Installations pre-1992 . . . . . . . . . . . . . . .24 3.1.2 New installations. . . . . . . . . . . . . . . . . . .25 3.2 Commercial and Industrial . . . . . . . . . . . . . . .26 4.0 CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . . .28 4.1 Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . .28 No. 180, 2002 25 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 SYNOPSIS Queensland recorded 20 electrical fatalities for the financial year ending 30 June 1997, while during the 6 year period studied for this report there were 74 fatalities and 4880 recorded electrical accidents. The focus of this report is to determine what impact residual current devices (“RCDs”) can have on reducing the severity and frequency of electrical accidents in Queensland. RCDs have been successfully used and are widely accepted as a cost effective way to provide both personal and property protection from electrical accidents and faults. They are used world wide in domestic, commercial and industrial installations. The currently available RCD’s performance and reliability is excellent. Their continued improvement has been fostered in part by the environmental requirements of AS3190. While there were concerns raised about their performance, generally they were about earlier products that are no longer available. The performance of RCDs can be affected by a faulty electrical installation or external electrical interference which can cause nuisance tripping. While raised as a reason not to have RCDs installed it does not seem to present a significant problem. Although RCDs offer enhanced electrical safety they do not protect in all situations. The most notable of these are powerlines and service main accidents which account for approximately 36% of all fatal electrical accidents in Queensland. However RCDs are most suitable for protection of sub and final circuits, appliances and cords. Because a switchboard mounted RCD will provide protection for fixed wiring as well as equipment connected via plugs and sockets, this group of accidents account for 62% of all fatalities. Before July 1992 there was no legal requirement to fit RCDs to domestic installations. A survey performed for this report found that approximately 45% of dwellings pre-July 1992 do not have a switchboard mounted RCD installed. These installations are where most of the accidents have occurred therefore a priority should be to encourage upgrading these older domestic installations to at least the current requirements of AS3000. A financial incentive scheme could be an appropriate method to expedite retrofitting older domestics. Anomalies in the current requirements for situations where RCDs are to be installed are also seen as a concern. Loop holes for quasi domestic situations such as hostels, caravan parks and community areas need to be 26 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 addressed as do the omission of requirements for commercial and industrial installations. The added safety provided by RCDs should be afforded in all situations. The future challenges for those setting standards and promulgating legislation is how to ensure electrical safety is appropriate for the future environment. Factors such as changing technologies, cost structures, building materials and methods, building alterations and additions, public expectations and legal liabilities, all contribute to a changing environment. While analysing electrical accidents may give insight into how things could have been done better, what is required is a proactive approach to electrical safety. For new installations RCDs should be used to their maximum potential by protecting the whole installation. 27 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 1.0 INTRODUCTION Electrical safety is a subject that should concern everyone, however it is generally taken for granted until something goes wrong. It is a wonderful servant but the swiftness with which it can kill deserves great respect. Residual current devices are one way to tame its killer instincts. This report explores some of the potential of residual current devices. 1.1 Project brief The EDAQ was engaged by the Electrical Safety Office of the Queensland Government Department of Mines and Energy to investigate the potential to minimise the frequency and severity of electrical accidents in Queensland by the installation of residual current devices (“RCDs”). In Australia, RCDs are also known as safety switches and were previously referred to as earth leakage circuit breakers (“ELCBs”). 1.2 Project background For the 6 years from 1 July 1991 to 30 June 1997 there were 74 fatal electrical accidents and 4880 recorded electrical accidents in Queensland. It could reasonably be expected that the number of unrecorded accidents involving electric shock far exceeds those reported. During the financial year 1996–97 there were 20 electrical fatalities. While RCDs were made compulsory on new domestic installations for General Purpose Outlets (“GPOs”) from July 1992 many other installations had them fitted voluntarily or as a requirement under other legislation (e.g. mines). RCDs were recognised as potentially offering a cost effective way to reduce the incidence and severity of electrical accidents. 1.3 Project scope Through public advertising and direct consultation the views of all stakeholders in the Queensland electricity industry as well as members of the public who wished to contribute were sought. Consultation included relevant State Government departments and agencies, the electrical contracting sector, Queensland electricity distribution corporations, building industry authorities and associations, electrical manufacturers, suppliers and associations, trade unions, tertiary 28 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 education, training bodies and learned societies, Standards Australia, State and Territory regulators. The project report identifies the benefits and costs to the community of the mandatory installation of RCDs in situations not yet covered by Australian Standard AS3000 (“SAA Wiring Rules”) and related Standards. This project has been undertaken in the 3 months July to September 1997. 1.4 Project methodology The project consisted of 2 key elements— • the consultative process; and • the analysis phase. From these, conclusions and recommendations have been drawn. 1.4.1 Consultation Consultation was necessary to identify the issues and concerns of stakeholders and the general public. The consultative process consisted of— • advertisements being placed in the major Queensland newspaper plus key regional newspapers, • mail correspondence to the stakeholders and the many potentially interested parties, 78 were sent in total, • follow up contact by phone and visits to key parties, and • follow up correspondence reminding those who had not responded. The consultative process resulted in 38 written responses being received plus telephone responses. An example of the advertisements and letters are included in Appendix 1. 29 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 1.4.2 Analysis The analysis phase consisted of an assessment of the recorded electrical accidents in Queensland for the 6 years, 1991–92 to 1996–97 plus consideration of interstate and overseas data. The Queensland accidents were grouped according to the likely impact of an RCD and the current requirements of AS3000. While the analysis of electrical accidents and significantly the fatalities provides insight into where the accidents have occurred in the past and what can be done to prevent repeat occurrences, it is essentially a reactive process (i.e. we wait for a fatality, then assess what could be done to prevent it recurring.) It can be argued that a proactive approach to electrical safety is warranted. Those responsible for setting safety standards need to critically assess the impact that the changing environment is having on what is considered an acceptable level of risk. Factors that should be considered include; changes to building materials and techniques, available technology and public expectations of safety. Finally, the options for increased application of RCDs have been considered in the framework of a cost benefit analysis. This included a professional survey to estimate the number of RCDs installed in houses built before July 1992 when RCD protection of domestic GPOs was mandated. 1.5 Limitations While it is necessary to have an appreciation of the technical performance and limitations of RCDs and the affects of electric current on the human body, this project did not undertake a technical review of RCDs or the affects of electric current on the human body. Rather it builds upon research and design work carried out by academics, manufacturers and medical practitioners and seeks to apply it to the benefit of the community through improved electrical safety. Very good information is available from manufacturers and suppliers of RCDs as to their operation and the effects of electric current on the human body. Some examples are included in Appendix 2 for further reading. 30 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 2.0 FINDINGS 2.1 Consultative process feedback Through advertising, letters and direct contact, the views of stakeholders, interested parties and the general public were sought as to the benefits and costs to the community of installing RCDs in situations not yet covered by AS3000 and related standards. The letters seeking comments contained a series of suggested areas that the respondent may wish to comment on. While many respondents addressed those issues specifically, some replied in a more ad hoc manner, while phone responses tended to be more off the cuff. The issues raised through this process have been tabulated in Attachment 1 with examples of typical comments. When reviewing the issues, it should be considered that each issue listed is not mutually exclusive but that issues overlap and ideas and concepts weave their way across several issue points. Some responses are based on electrical accident records, some on personal experience, while others use logical argument. Whatever the argument, most respondents considered that it is time to progress electrical safety initiatives and that RCDs are a product that could and should be used more widely. As with all arguments, counter arguments were raised, which are also included in Attachment 1. Some issues raised by the respondents deserve special mention and are discussed below. 2.1.1 Nuisance tripping Customer satisfaction is often the make or break of a product. When considering the further application of RCDs, the satisfaction and acceptance of RCDs by the electricity consumers must not be overlooked. Nuisance tripping is one factor that can have negative effects on customer acceptance. None of us like to loose power unnecessarily. There are 2 types of nuisance tripping, “nuisance tripping” and “pseudo nuisance tripping”. Firstly, the genuine nuisance tripping occurs when there is no electrical fault and therefore no hazardous situation but the RCD trips off the circuit. 31 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 This could possibly be caused by installation contrary to the manufactures recommendations or electrical interference from an external source. The current standard for RCDs specifically addresses performance and reliability issues which are further discussed in section 2.1.9 below. Secondly, there is the pseudo nuisance tripping. This occurs when there is a fault or an accumulation of small faults causing sufficient leakage to earth to cause the RCD to trip. It is referred to as a nuisance trip because when it occurs, the user is unaware of the fault, because at that instant the fault is not causing a life threatening situation, e.g. they are not hanging onto the faulty appliance and receiving an electric shock. It can be argued that pseudo nuisance trips cause customer dissatisfaction, however, are these pseudo nuisance tripping a legitimate reason not to fit an RCD to the circuit? We have a device which is like a safety watch dog saying, ‘There is a potential hazardous situation developing on this installation—do something about it!’ and yet they are labelled nuisance tripping. To some, just the possibility of nuisance tripping is reason enough not to fit an RCD. However, correct installation practices including thorough pre-installation tests, training of electricians and adequate maintenance of electrical equipment will ensure a high level of satisfaction. If there is a valid case against the performance of RCDs then this should be addressed through the appropriate design standard. With regard to nuisance tripping, heating elements deserve special mention and are discussed below. 2.1.2 Heating elements The issue of heating elements was raised by a number of respondents as causing nuisance tripping when used on circuits protected by an RCD (hot water, stoves, dryers, refrigerators, etc.) Tubular heating elements as used in devices such as dishwashers, clothes dryers, water heaters, stoves and refrigerators (e.g. defrost elements) are prone to electrical leakage to their outer sheath. Tubular heating elements are manufactured by suspending a heating element in an insulating material inside a metal tube. The insulating material usually used is magnesium oxide (MgO). MgO is a hydroscopic material which can absorb moisture which effects its insulating properties. On lower temperature elements, up to about 450 to 500°C, the ends of the tube can be hermetically sealed to prevent the ingress of moisture. On elements operating in excess of about 500°C they need to be able to breath to prevent the element failing. 32 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 The problem arises when an element is energised after a prolonged period of no use. Moisture that has been absorbed into the element is driven out towards the cold ends of the element at which time there may be sufficient leakage to earth (assuming that the element has a satisfactory earth) to cause an RCD to trip. This phenomenon was apparently a problem with clothes dryers and refrigerators. However, the problem has been virtually eliminated by the addition of additives to the MgO and/or fitting slow breather seals to the end of the elements plus the use of ceramic insulating materials. Hot water elements are usually sealed with an epoxy based resin and are therefore not a problem. However, as was explained by an element manufacturer, how they fail is of interest to the RCD debate. Hot water elements are sheathed in a copper tube which after a period of time can corrode resulting in holes and subsequent moisture ingress into the element. The element will eventually break and burn back towards the terminals with the water completing the conductive path instead of the wire element. How much the element burns away depends on the conductivity of the water. In extreme cases the wire can burn back to the point where arcing at the terminals can occur and either blow the fuse or trip the circuit breaker as fitted. During such fault conditions, the installation is maintained in an electrically safe state by the effectiveness of the earthing system. If there is not an effective earth, then exposed metal may become energised. While the significance of having an effective earthing system is understood by electricians at the time of installation, there are many factors over the life of the hot water system that can have a detrimental impact on the effectiveness of the earthing, such as corrosion or alterations by unqualified persons. The increased use of plastic piping and nylon ferrels in plumbing has increased the likelihood of having non-contiguous conductive plumbing which is not effectively earthed. An RCD on hot water would provide essential backup protection. This leaves high temperature stove elements. It should be noted that stove elements are only a problem if left unused for long periods of time with sufficient humidity to absorb moisture. The minor nature of the problem can be appreciated by the fact that there are many examples of older installations where the whole house is on one RCD. The fact that these are still in operation after a long period of time indicates that they are not a significant problem. However, it is an area where manufacturers need time to implement cost effective changes to manufacturing techniques. 33 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 2.1.3 Lighting circuits Lighting circuits are not required under AS3000 to be protected by an RCD, however they contributed 17% of domestic electrical fatalities and 16% of all electrical fatalities in Queensland during the period studied. (Or 21% of the domestic fatalities that can be influenced by an RCD.) The arguments against including lighting circuits centre around the possibility of nuisance (non life threatening) RCD tripping and their consequences. Older light fittings especially fluorescents with power factor correction can have leaky electrical components which may cause an RCD to trip (as it should). It is argued that plunging a premises into darkness may create a dangerous situation, i.e. someone may fall down the stairs and injure themselves in the dark, etc. This is an interesting argument because the electricity supply corporations can not guarantee 100% supply availability and blackouts do occur. When blackouts occur people either use torches or have emergency back up lights if they are deemed necessary. Clearly emergency lighting is an elegant solution as it provides back up lighting in all circumstances including fire. Secondly, if more than one light circuit is used, (as is the case in most newer installations) the circuits can be protected by separate RCDs (MCB/RCDs are ideal for this). If there is a trip then only the lights on the effected circuit will go out. The argument against putting lights on RCDs seems rather weak when compared with the potential to save lives. 2.1.4 Portable equipment When compared with lights, as discussed above, there is little counter argument against using RCDs for added protection of portable equipment. The benefits were recognised by Standards Australia releasing AS3000 in 1991, and subsequently by other legislation. when With the benefit of RCD protection for portable equipment being so well accepted, why then is it not a requirement for commercial and industrial situations? This issue is discussed further in the sections on commercial and industrial in the data analysis section. A total of 32% of all fatalities were associated with appliances and cords. 34 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 2.1.5 Power circuits Support to protect all power circuits by RCDs is very strong judging by the number of respondents that commented on this issue. It was raised more than any other issue. Comments specifically identifying and questioning how the loop holes in the current rules can be justified. The requirements for RCDs should be the same for all situations—domestic, commercial and industrial with all power circuits in all situations protected. Accident records provide strong support for this argument as 16% of all fatalities were on power circuits and a further 32% were on appliances and cords which are obviously connected to power points. Therefore, combining them together accounts for 48% of all fatalities. 2.1.6 All circuits After considering various situations not currently required to be protected by RCDs the next logical step is to cover every circuit and this is what many of the respondents suggest. By the proponents, it is seen as the next logical step in electrical safety that is overdue. They question the need for different pieces of legislation to cover different situations ie domestic, commercial, industrial, caravan parks, mines and construction sites and would like to see uniformity. It was also found that the public was under the misapprehension that their installation was completely protected by their switchboard mounted RCD which in fact was only covering their GPOs. There is a public expectation that if the technology is available then all circuits should be protected. By not protecting the whole installation, the increased safety afforded by RCDs is diminished. 2.1.7 Quasi domestic situations (including caravans) The idea of “loop holes” in the current requirements has already been noted. However, the quasi domestic situations are the largest concern. This includes commercial enterprises that are domestic in nature, such as hotels, motels, caravan parks (new caravan parks are only required to have RCDs on outlets for caravans), hostels, community areas in units, etc. Due to the competitive nature of the building industry, RCDs are often omitted from these areas. 35 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 Clearly these quasi domestic situations are as important as the traditional domestic situations and need to be addressed. A broader view of the quasi domestic situation includes all areas accessible to the general public such as, show grounds, community schools, child care centre, public facilities in parks, public areas in shops, waiting rooms, etc. 2.1.8 Non-complying existing installations Comments received on this issue mostly focused on older domestic installations and bringing them up to the current requirements of AS3000. However concerns were raised regarding commercial and industrial installations which are not up to the same standard as required for domestic installations. Achieving uniformity in the safety standard across all installations was considered important for both RCD protection and the overall installation quality. Deteriorated wiring, ineffective earthing, and rewireable fuses were some of the issues mentioned. As a minimum, domestic installations prior to July 1992 when the changes to AS3000 came into effect in Queensland, should be brought up to current safety standards with respect to RCDs. The fitting of multiple RCDs to cover other circuits such as lights which also provides segregation should tripping occur would be highly recommended. The process of retro-fitting installations is not something new. Spurred on by advertising and public awareness campaigns, it has been taking place ever since RCDs first became available. Market forces have ensured that it is not a major logistical problem. For older style switchboards with fuses, surface mounted modules which take standard RCDs are available. For switchboards with DIN rail mounted circuit breakers or commercial, industrial boards with Moulded Case Circuit Breakers (“MCCBs”), RCD units that fit straight in are available. As one electrical contractor put it: ‘I have never come across a situation where a safety switch could not be fitted’. The cost effectiveness of retro-fitting is discussed under section 3.0. However, fitting of RCDs to older installations can have its problems. Potentially hazardous situations that have been lying dormant may cause RCD tripping. If correct procedures are not followed, the unscrupulous installer either disconnects the part of the circuit causing trouble and therefore compromises safety, or leaves the customer with a frustrating problem of “nuisance” tripping, rather than finding the fault. There is no 36 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 simple solution to this type of behaviour. Possibly a consumer awareness program may help. 2.1.9 Performance and reliability Concerns were raised regarding the reliability and performance of RCDs. In 1989 the Electricity Regulatory Services of SECWA conducted a survey to assess the reliability of RCDs installed in Western Australia. The survey found an unacceptably high proportion failed to operate under test conditions 14%. For one particular brand 83% failed. (Note—the brand with the high failure rate had been approved prior to amendments made to AS3190 in 1980 and has subsequently been withdrawn from the market. AS3190 is the Australian Standard for RCD performance.) While this must have been a disappointing result for those conducting the survey, they must have been encouraged by the apparent impact that RCDs had made on electrical safety. Seventy-nine percent of those surveyed had known their RCD to have operated under various fault conditions. The Queensland survey conducted for this report found that of those dwellings constructed before July 1992 with an RCD installed, 63% had been known to have tripped, with 68% of these for a known safety reason. The real impact that RCDs have had on electrical safety can only be imagined. Concerned with reliability and unwanted tripping, Standards Australia reviewed and subsequently amended AS3190 in 1990 to reduce the likelihood of unsafe or unreliable RCDs reaching the market place. The subsequent mandatory use of RCDs in new domestic installations and RCDs becoming a prescribed item which must comply with the relevant Standards, has seen the removal of some products from the market but has also resulted in an increasing variety of high quality products being available. Another survey to determine the in-situ performance conducted in Tasmania. At the time of printing the available, however it is understood that one approximately 250 tested. A result possibly reflecting in RCDs since the survey conducted in 1989. of RCDs is being results were not had failed in the improvement The natural market forces such as the risk of litigation if a fatality occurred due to a faulty RCD and the subsequent loss of market share from any bad publicity will continue to exert pressure on RCD manufactures and 37 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 suppliers to develop quality innovative products. However those who set standards and regulations must ensure that their requirements are socially and economically responsible and in line with public expectations. The ability of RCDs to correctly function in the presence of DC and other external electrical interference was one issue raised by respondents during the consultative phase of this project. The RCD of today has improved substantially from the early ELCBs of the 1960s. It is recognised throughout the world as a reliable device offering a cost effective way to increase electrical safety and property protection. A comment typical of those received on this issue sums it up nicely. ‘High reliability. Few limitations. Can be seen as essential equipment.’ 2.1.10 How should RCDs be installed How the RCD is installed can affect the customer satisfaction. From a value for money point of view, the aim would be to put as much of the installation onto one RCD as possible, i.e. maximum protection least cost. There are however some draw backs in doing this. There is the possibility that cumulative leakage and capacitive current can cause unwarranted tripping, and if any tripping occurs then all circuits protected by the one RCD will be switched off which can adversely affect customer satisfaction. A much improved installation arrangement is to have a separate RCD for each circuit (MCCB/RCD combination being ideal for this) or at least multiple RCDs covering zones or combinations of circuits. This reduces the likelihood and impact of an RCD tripping. While it is recognised by many that improved installation practices would raise customer satisfaction (see Attachment 1), it was acknowledged that the competitive nature of the market drives installation practices to the absolute minimum. However, as the number of circuits protected by RCDs increases, the necessity to ensure that the installation is fit for the purpose also increases. While it may be contractual matter, a lead may be necessary in legislation to encourage multiple RCDs. 2.1.11 AS3000 While some respondents considered the current requirements of AS3000 to be adequate, most considered some change necessary to incorporate their suggestions. The specific comments that were received mostly centred 38 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 around the need to extend the current requirements to include industrial and commercial installations. Probably the comment that sums it up best is that ‘alterations should be made to reflect the changing environment’. Those setting standards need to consider the shifting environment and their responsibility to recognise future trends brought about by different building construction practices, changing; technology, manufacturing, costs and public expectations. 2.1.12 Alternative approaches Alternative approaches to electrical safety can not be dismissed just because an RCD is installed. Good installation practices, maintenance and common sense should still prevail. One approach that is sometimes seen as an alternative to fitting RCDs is to bond ever piece of conductive material to the earthing system. With modern construction methods and materials, a requirement such as this would be expensive, time consuming and difficult to enforce. 2.2 ACCIDENT ANALYSIS The approach taken to analysing electrical accidents has been discussed in the section on project methodology. The following section goes on to interpret the findings. Attachment 2 contains a tabulated summary of all the electrical accidents in Queensland for the period 1 July 1991 to 30 June 1997. The electrical accidents have been grouped into three main categories— • power lines and service mains; • switchboard and sub-mains; • sub circuits, appliances and cords. These are discussed below. 2.2.1 Powerlines and service mains These are accidents involving the distribution of electricity up to the point of connection to the premises. The type of accidents that occur in this category are not preventable by an RCD. Typical accidents included in this category are— 39 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 • contact with overhead power lines, e.g. irrigation or harvesting equipment, cranes, and boat masts being driven into overhead power lines; • electricity supply system maintenance accidents; • contact with fallen power lines, e.g. as a result of a storm or road accident; • contact with service mains and point of entry connections, e.g. painters painting fascias of buildings contacting damaged service connections, or plumbers accidentally touching service lines with conductive material such as roofing iron or guttering. A sub set of power lines and service mains are incidents involving service neutrals. Although they have not in the past significantly contributed to fatalities, they are the single most reported cause of electric shocks in Queensland. Most electric shocks being received from earthed plumbing, which due to a faulty service neutral connection has become the neutral return path to the distribution system. Powerlines and service mains represent over one-third of all electrical accidents and accordingly need to be addressed by increased public awareness and improved performance by the electricity distributors. 2.2.2 Switchboards and sub mains This category was formed because it represents a group of accidents which for the purpose of RCD protection are not as clear cut as either power lines and service mains. In the first instance RCDs are quite inappropriate where as for sub circuits they can be very effective. Switchboards and sub mains are the grey areas in between. At the risk of generalising there are probably two types of situations in the switchboards and sub circuit group where RCDs may have impact. Firstly if there was an RCD fitted to the switchboard for the protection of the sub circuit and the accident happened on the load side of the RCD or secondly if the whole switchboard or sub mains was protected by an RCD, then, provided it wasn't a phase to phase or phase to neutral accident, an RCD could influence the outcome of the accident. For most of the electrical accidents in this category, it is difficult to determine the exact situation involved, however a reasonable assessment has been made for the 2 fatalities involved and it is considered that one incident would have benefited from an RCD, the other it is uncertain. Therefore, this group represents accidents that may be assisted by an RCD 40 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 but it is often difficult to determine the exact impact on the information available. These are situations where MCB/RCD main switches may have a significant impact. MCB/RCD main switches were raised by respondents and are a common requirement overseas providing the increased benefit of reduced property damage (e.g. caused by fire) should a electrical fault occur. QUEENSLANDS' FATAL ELECTRICAL ACCIDENTS 1991/92 TO 1996/97 FIXED WIRING 25 20 fridge (where specifically identified) 15 lights & fans (where specifically identified) 10 other sub crts & final circuits 5 switch bd & sub mains - Incidences DOMESTIC Fatal Electrical Incidences COMMERCIAL Fatal Electrical Incidences Fatal INDUSTRIAL Electrical TOTAL Incidences Fatal Electrical POTENTIAL IMPACT OF RCD'S ON QUEENSLANDS' FATAL ELECTRICAL ACCIDENTS 1991/92 TO 1996/97 80 70 APPLIANCES & CORDS 60 50 SUB CIRCUITS & FINAL CIRCUITS 40 30 SWITCH BOARD & SUB MAINS 20 POWER LINES & SERVICE MAINS 10 - TOTAL installed Incidences installed Incidences installed Incidences DOMESTIC installed Incidences INDUSTRIAL if anbeen COMMERCIAL Fatalities if anbeen Fatalities if anbeen if anbeen Fatal ElectricalFatalities RCD had Fatal Electrical RCD had Fatal Electrical RCD had Fatal ElectricalFatalities RCD had 41 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 2.2.3 Final circuits, appliances and cords This category represents those accidents where an RCD is most likely to have an impact on the outcome of an electrical accident. They account for 55% of all reported accidents, 66% of hospitalisations and 62% of fatalities. Typical accidents included in this category are— • fixed wiring accidents such as penetrations of wiring by a nail or screw, contact with broken switches, tampering with an installation with the power still on, faulty and/or incorrect wiring connections, and • accidents involving appliances and cords such as damaged extension leads and portable equipment, incorrect connection of extension leads and appliances. It is interesting to note that in this category, 31% of domestic fatalities or 18% of all fatalities are caused by unauthorised or work carried out by untrained persons. Also in this category the AS3000 Wiring Rules requirement for the installation of RCDs on domestic GPOs comes into play. This requirement became effective in Queensland on all new domestic installations from 1 July 1992. Accordingly, the sub categories within this group have been chosen to reflect situations not yet required to be protected by RCDs under AS3000. While it was the intention to isolate all accidents that have occurred on say refrigerators circuits (refrigerators are not required to be protected by an RCD under AS3000) it may not have been possible. Many of the accident records give no specific indication of the circuit. Therefore there may be some accidents that should have been allocated to a subgroup but have remained in the general group of final circuits. Accordingly, some care needs to be exercised in drawing conclusions from the subgroups, lights and fans, hot water, refrigerator and stove as they may be understated. Now that the precautionary comments are out of the way, what can be learnt from the accident records? Without a doubt this is the area where RCDs really come into play. They have tremendous potential to reduce the severity and frequency of electrical accidents here. Each fatality has been carefully assessed as to the potential impact an RCD may have had in that specific situation. As shown below RCDs can have a material impact on the electrical fatalities in Queensland and it is in this category where the gains are to be made. 42 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 If RCDs are fitted to final circuits (by mounting in the switchboard) they not only provide protection for accidents occurring on appliances and cords, but also the fixed wiring accidents which occur on those circuits protected. If functional RCDs had been installed on all final sub-circuits, of the 46 fatal electrical accidents studied under final sub-circuits, appliances and cords, 42 may have been avoided. (RCDs cannot protect in all circumstances, accidents occurring on the secondary side of electric welders are a concern in this regard.) The significant impact that RCDs offer for electrical safety is obvious. If the community is serious about reducing unnecessary fatalities then all final circuits should be RCD protected. However, as shown during consultation, the area of debate is whether exceptions for certain circuits or situations should be made including what allowances for older installations which do not meet current safety standards can be tolerated. Electrical accident records can be used as a guide for determining which areas should be addressed. Using the number of electrical fatalities, hospitalisations or recorded accidents, the priority order is essentially the same and would be— 1. Appliances and cords; 2. Final sub circuits (power circuits); 3. Lights and fans. (Note, the fans included with lights are ceiling fans which are often connected onto a light circuit). However, the order for the smaller groups is a little more volatile depending on what measure (fatalities, hospitalisation or recorded accidents) is used. If an installation is divided into enough small sections then the number of accidents occurring on any particular section is reduced when compared with the number of accidents occurring on the aggregate of the sections, i.e. the most aggregated areas will have the highest number of accidents although the probability of an accident occurring say per outlet may be the same. Accordingly, by separating small areas such as fridges, hot water and stoves from the remaining aggregated power circuits, the number of accidents must be less due to their relative size. To argue that these areas do not need RCD protection because there has been insufficient accidents is like saying that one brand of car is much safer than the others because it has been involved in less accidents than all the other cars combined. Care 43 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 needs to be exercised when accessing results from different population sizes. 44 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 3.0 COSTS AND BENEFITS A policy decision on electrical safety has its greatest impact not on those making the decision but on others. One approach to assist the decision makers is to weigh up the benefits and compare them with the costs of implementing the decisions. While this sounds straight forward enough, matters concerning the well being of human society such as electrical safety can be difficult to quantify. Measuring the social benefits and costs, quantifying human feelings and expressing the choices of people, makes the process less determinate. An example is putting a value on the trauma associated with an accident or valuing life itself. In Australia, transport authorities typically use a value of about $625 000 for a fatality while a New Zealand study which adds up all the social costs associated with road accident fatalities estimates it to be about $2.5m AUS. The legal fraternity often view it differently again, sometimes awarding huge amounts in damages. A recent case in America where a baby was killed due to a fault in a car, the judge awarded damages in the order of $30m. This report attempts to list and quantify the costs and benefits where possible. The final decision as to whether this is an appropriate way to reduce electrical accidents must be left up to the conscience of the decision maker. Up to this point, the accidents have mostly been considered on the basis of domestic, commercial and industrial combined into one group. Because the three types of electrical installations present different cost structures and installation logistics, they are now addressed separately. Domestic accidents representing 49% of fatalities are addressed first followed by commercial and industrial. 3.1 Domestic The Census of Population and Housing 1996 revealed that there were 1.3 million domestic dwellings in Queensland, the majority of them being constructed prior to July 1992 when it became compulsory to fit RCDs to GPOs in new domestic installations. To estimate the number of pre-1992 dwellings with RCDs fitted, a professional survey was commissioned. From this, it is estimated that there are 0.5 million domestic dwellings without RCDs fitted to their switchboards. (No attempt was made to estimate market penetration into commercial or industrial situations due to the diversity of installation options and configurations). 45 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 Referring also to Attachment 2, the current position in Queensland is shown below. Queensland domestic situation Total Queensland dwellings— census data 1996 1 329 811 growth 18.6%, say 3.7% per annum 1991 1 120 941 Estimated dwellings for analysis 1997 1 379 413 1992 1 162 715 say 1 379 000 say 1 163 000 or 84% Number of RCDs installed in Queensland dwellings constructed pre-July 1992—survey data Survey results Estimated total dwellings Assume worst case ie all “can’t say” are “no” RCD? Yes 55% 1 163 000 x 0.55 = 640 000 No 31% 523 000 Can’t say 14% RCD tripped? Yes 63% 640 000 x 0.63 = 403 000 No 35% Can’t say 2% Tripping safety related? Safety 68% 403 000 x 0.68 = 274 000 Accidental 27% Can’t say 5% 46 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 Recorded electrical accidents over 6 years— 1991–92 to 1996–97— Appliances and cords Circuit Fatal 10 Amp GPOs (< ‘92) 12 86% Other 2 14% Total 14 100% Hospitalised (prorata) 73 12 85 It can be assumed that the 12 fatalities on GPOs were on dwellings pre-July 1992 without RCDs, that is approximately 523 000 dwellings. Or putting it another way, in the 6 year period studied, approximately 1 in every 44 000 dwellings without RCDs on GPOs had an fatality on an appliance or cord. Of the other two fatalities one was on a 3-phase outlet (which could have been prevented had there been an RCD fitted, but is not compulsory under AS3000) the other was not preventable by an RCD. Pre-July 1992 Post-July 1992 Total Sub and final circuits (fixed wiring) Fatal Hospitalised 5 13 1 3 6 16 Of the six fatalities, one was on a GPO circuit, which probably makes it a pre-1992 dwelling. However for the others there is insufficient information to determine which circuit the accident occurred on. Because these accidents were caused by fixed wiring faults and not all circuits are required to be protected under AS3000 there is no way of estimating the age of the installation and another method is required. Accordingly the number of Queensland dwellings have been used to pro-rata accidents into pre and post 1992 installations. Lights Pre-July 1992 Post-July 1992 Total Fatal 5 1 6 Hospitalised 15 3 18 47 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 Lights, not being compulsory, have been allocated pro-rata according to domestic dwelling numbers as per sub and final circuits above. Refrigerators Pre-July 1992 Post-July 1992 Total Hot water Pre-July 1992 Post-July 1992 Total Stoves Pre-July 1992 Post-July 1992 Total Refrigerators, hot water and stoves Fatal Hospitalised 1 4 0 1 1 5 – – – 3 1 4 – – – 5 1 6 Using the same argument as above, these are allocated according to the number of dwellings. Although the numbers are not as large as in the other areas above, as previously discussed a pertinent question to ask is. Why are small areas of the installation segregated off as not requiring an RCD? The strategy for domestic installations must address 2 issues— • how to reduce the alarming number of accidents in dwellings without RCDs constructed before the current requirements of AS3000 came into effect in July 1992; and • how to ensure appropriate safety for new installations in light of changing building techniques, technology and public expectations. Retro-fitting pre-1992 installations is discussed below followed by new installations. 48 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 3.1.1 Installations pre-July 1992 Expected outcomes The table below shows the expected outcomes over a 12 year period for including different circuits (assuming a rapid take up rate for retro fitting). Although 12 years has been chosen the expected life of a RCD and therefore benefits far exceeds this. For supply and fit the costs are for the minimum requirement for 523 000 dwellings to be retro fitted based on an average installation. Costs used are $150 for power circuits, plus $125 for any additional RCDs fitted at the same time. Dwellings constructed pre-July 1992 Circuit Cost Benefit for 523 000 Reduced fatalities Reduced dwellings (12 years) hospitalisations (12 years) Final circuits and $39.225m 10 26 power circuits* Refrigerators** – 2 8 Appliances and $39.225m 24 146 cords* All dwellings Circuit Cost Benefit for 1.31 million Reduced fatalities Reduced dwellings (12 years) hospitalisations (12 years) Lights & fans $120.0m 12 36 Hot water $120.0m – 8 Refrigerators** – 2 10 Stoves $120.0m – 12 Note— * Costs are shared equally. ** Connecting a refrigerator onto an existing RCD it is assumed the costs are not material. Because there has been a low installation rate for lights, hot water and stove, it is assumed that 95% of existing dwellings (1.31 million) would 49 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 require retro fitting to include those circuits. For costing it is assumed that for good installation practice two additional RCDs would be required to cover the whole installation. (Although it could be done with less.) Suggested combinations could be either— • power and stove or light and power; or • light and hot water; or • hot water, stove and power. Present metering requirements by some electricity supply corporations may necessitate a separate RCD for hot water tariffs. The costs of extra RCDs have been shared equally across the 3 circuits. From the above, the best “value for money” can be achieved by bringing pre-1992 dwellings up to the current requirements of AS3000 with all power circuits included. It is recommended that this be undertaken with an appropriate monetary incentive scheme. Every endeavour should be made to encourage RCDs to be used on other circuits, particularly lights. This could be included as on aspect of an electrical safety campaign. Suggested minimum action Upgrade to all power circuits ie current requirements of AS3000 plus refrigerators and all socketed outlets. 3.1.2 New installations Looking forward, what should be done about future installations? Using the accident records as a precedent, it is clear that lights and all power circuits (including refrigerators and all other sockets outlets) should be included in future installations. However as discussed in section 2.2 using the number of occurrences in a small population and then comparing the number of occurrences from a large population (in this case the population size is the size and number of selected circuit installation types) can be misleading. To compare the probability of an accident occurring on a particular circuit the data should be standardised. However as this is practically impossible from electrical accident records and installation type and size, it is left to informed judgement. On a new installation the cost of extra safety is the incremental cost of extra RCDs or preferably RCD/MCB combinations. The list price for DIN 50 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 mounted RCDs or RCD/MCBs are similar ranging from about $75 to $110. (Actual buying prices are much lower than this, down to about $35 each). To include all circuits using three RCDs on an average house would add approximately $150 to the installation cost (On a $100 000 house that is 0.15%). If RCD/MCBs were being used an additional cost of about $300 may be expected. A very small price for the extra protection offered by RCDs. When the proven effectiveness of RCDs is taken into account and the small cost of including them at the time of installation, the question is not how to justify increasing their application but how can responsible behaviour exclude certain parts of an installation? All areas are becoming increasingly at risk with changing building methods and materials plus the popularity of alterations and additions including such things as extra cabling for cable television, computers, and security systems. An alternative and very costly method would be to ensure all conductive materials used in construction are bonded to the earthing system. This would have a negative spin off effect for service neutral failures where even more of a building could become alive and potentially dangerous. Steps should be taken to encourage total installation protection by RCDs. Setting it as a requirement may be necessary to create a level playing field for competitive job quoting. 3.2 Commercial and industrial There is a perception that the number if commercial and industrial accidents do not pose as big a problem as domestic installations. After all they have the benefit of other safety methods such as test and tag programs. However if they are compared on a similar basis the results look quite different. (This is the same argument raised in other parts of the report that the data needs to be standardised to cope with different population sizes.) One way to compare their performance is to plot the number of accidents against the number of electricity supply corporation customers in each class as shown below. As can be seen commercial and industrial customers do present more than their fair share of electrical fatalities which need to be addressed. RCD installation presents a one off up front cost to provide continued protection for many years. The difficulties arise when allocating costs and benefits to the diverse size and nature of installations used in commercial and industrial application. The average installation would not be representative enough to 51 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 truly represent anything. However discussions with manufactures and suppliers indicates that an average additional cost per switch board pole would be about $100. Equating this to a building cost it works out similar to domestic being less than 0.15% While there may be arguments as to the apparent safety of commercial and industrial situations, aren’t all people entitled no matter where they are, to the added safety offered by RCDs? Power circuits (including sub circuits, appliances and cords) account for 45% of all commercial and industrial fatalities or 94% of all the accidents where an RCD could reasonably be expected to have an impact. Of the fatalities on power circuits 82% could have reasonably been expected to have been prevented if a functioning RCD had been installed. It is recommended that as a minimum future power circuits be protected by RCDs in commercial and industrial situations. 52 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 4.0 CONCLUSIONS During 1995 in Queensland there were 43 accidental drownings, 464 fatal motor vehicle accidents, and 32 fatalities caused by fire. Compared to these other causes of death, electrocutions are quite few in number. However electrical fatalities are still significant. 4.1 Conclusion This report has explored the potential to reduce electrical accidents in Queensland by the increased application of RCDs. The conclusions are— • The use of correctly functioning RCDs provides a cost effective way to reduce the number and severity of electrical accidents in Queensland. • The performance and reliability of RCDs are generally excellent. They have improved significantly from early models due in part to the continuing work of Standards Australia in promulgating performance and reliability standards. • While an effective tool to assist in electrical safety they can not prevent all electrical accidents. Accidents involving power lines and service mains can not be prevented by RCDs, similarly for phase to phase or phase to neutral accidents. • Loop holes in the current requirements for RCDs are a concern. Loop holes identified include— • Areas of domestic installations which are not required under AS3000 to have a safety switch fitted. • Quasi domestic situations such as—hotels, motels, hostels, caravans and parts of caravan parks etc. • Public places. • Commercial and some industrial situations. • The most significant impact on electrical accidents can be achieved by retrofitting dwellings constructed before July 1992 to the current requirements of AS3000 with all power circuits included. An incentive scheme would be an effective way to achieve this. • Commercial and industrial installations do contribute to electrical accidents. RCDs should be used to protect all power circuits on new installations. 53 Electricity Amendment Regulation (No. 3) 2002 • No. 180, 2002 A proactive approach to electrical safety is need by the regulatory authorities and standard setting bodies to cope with changing technologies, building and construction trends and public expectations. Consultative feedback As outlined in the report, the consultative process involved advertising throughout the State in addition to individual letters sent to stakeholders. These stakehoders included electricity distributors, state electricity regulators, the Housing Industry Association, electrical equipment manufacturers, consumer groups, and other interested government departments including Workplace Health and Safety. 54 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 RECOMMENDATIONS The recommendations resulting from this project are— Domestic installations pre-July 1992 Upgrade to all power circuits ie current requirements of AS3000 including all other socketed outlets. An incentive scheme as detailed in the appendix should be used to ensure rapid retrofitting of those dwellings. Future new domestic installations The total installation should be protected by RCDs. Preferably multiple RCDs as required to achieve reasonable fitness for purpose. For stoves a 1 year lead time should be provided for element manufactures to improve their products. Quasi domestic situations The current definition of a domestic installation should be broadened to include quasi domestic situations regardless of their commercial intent. Future commercial and industrial installations RCD protection of all power circuits as per current requirements of AS3000 for domestic plus all other socketed outlets. Safety campaign A public awareness campaign to reinforce electrical safety particularly regarding overhead powerlines and service mains. Service neutrals The electricity supply corporations address the high level of faulty service neutrals and the resulting electrical accidents. 55 Electricity Amendment Regulation (No. 3) 2002 No. 180, 2002 Uniform legislation The requirements for the use of RCDs should be simplified and standardised across all applications. 1. 2. ENDNOTES Laid before the Legislative Assembly on . . . The administering agency is the Department of Industrial Relations. © State of Queensland 2002
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