The electricity at work regulations 1989 – Offshore aspects
1 This circular provides guidance on offshore aspects of the Electricity at Work Regulations 1989 (EAWR), which are applied offshore by the Offshore Electricity and Noise Regulations 1997.
2 This guidance should be read in conjunction with the 'Memorandum of guidance on the Electricity at Work Regulations' HS(R)25, the booklet 'Electricity at Work - Safe working practices' HS(G) 85 and OC 480/2.
3 EAWR is mainly aimed at the prevention of electric shock or electrical burns. However regulation 6 includes fire and explosion resulting from electrical failure. The key term in EAWR is 'danger'. This is defined in regulation 2 as the 'risk of injury'. Injury means death or personal injury from electric shock, electrical burn or fire or explosion caused by electricity.
Dutyholder (regulation 3)
4 The dutyholder under EAWR is the employer. Operators and owners may also be employers and will therefore have duties in relation to electrical plant and equipment which is part of the installation. The various dutyholders will need to co-operate and co-ordinate their activities appropriately to the extent these relate to matters under their control.
Live working (regulation 14)
5 Regulation 14 only applies where persons are at work on or near live electrical equipment which may foreseeably give rise to danger. There are absolute duties not to work live unless justified, and where it is justified, to take precautions to prevent injury. The greater the risk of injury, the less live working is likely to be reasonable.
6 The regulation discourages live working, but recognises that there are situations where it may be unreasonable for work to be carried out dead. For example, a variable speed drive controlled by electronic equipment may require potentiometers to be adjusted, which cannot be done with the power off.
7 Where live working is carried out, the dutyholder must address paragraphs (a), (b) and (c) of the regulation. They must demonstrate that it is unreasonable for the conductors to be dead, that it is reasonable for the work to be carried out with the conductor live and that other precautions are taken to prevent injury to the persons involved, such as insulated screens, barriers and training. Any protective equipment provided must be suitable, in accordance with regulation 4(4). The dutyholder will also have to demonstrate that the person carrying out the work is competent in accordance with regulation 16.
8 Live working includes testing to find a fault. If this is not possible with the equipment dead then the same stringent precautions are required. Locating a fault on a circuit that has become dead is the same as working live, since the circuit will be live at the point of fault.
9 An example of where live working offshore may be required is in the diagnostic testing of circuits, for example use of a potential indicator to check for supply voltage, or adjustment of equipment controls. HSR 25 gives further guidance.
10 The design of electrical cabinets and enclosures should provide adequate segregation of the parts of the system that need to be accessed for live work, from other parts which may remain live. Segregation may be by insulation, shrouding or separation. Segregation can be a problem on drill rig equipment supplied from outside the EU. Enforcement action should be considered. The dutyholder must either restrict live work or upgrade the segregation to acceptable standards.
11 EAWR does not specifically require accompanied working. However the guidance in HSR25 recommends accompanied working on or near live conductors.
12 The dutyholder should have appropriate procedures to identify where accompanied working is required, and to determine the necessary precautions. This involves assessing the hazards of the activity, both to the person undertaking the work and to others who might be affected by it. Accompanied working is required if there is danger (risk of injury) to a person or persons and that the risks are such that they can be substantially mitigated by accompanied working.
13 For example, accompanied working will normally be required where:
- supply voltages exceed 50Vac or 100Vdc and exposed live conductors may be encountered, for example during fault diagnosis in cubicles. Exposed live circuits should be protected by permanent or temporary shrouding, but there is always a residual risk of an electrical accident occurring when using test equipment on live circuits,
- supply voltages exceed 50Vac or 100Vdc and exposed live conductors are likely to be encountered in combination with additional hazards, such as high fault level or environmental conditions which could result in severe levels of electric shock from such equipment. Examples are work on UPS battery systems or on equipment in confined conductive (eg damp) spaces, and
- working on HV equipment (voltage >1000 Vac), for example isolating, testing, earthing down, and working on isolated sections of multi-section live switchboards.
14 In all cases the accompanying person should be competent to:
- recognise danger and summon assistance
- switch off, where practicable, whilst maintaining their own safety, and
- render assistance, including first aid as appropriate.
15 The accompanying person need not necessarily be standing-by. They may be employed on an unrelated task in the immediate vicinity. However the person must at all times remain in close visual and aural contact with the person carrying out the electrical work.
Supervision (regulation 16)
16 A person who is not fully competent must be adequately supervised. Whether this requires the continual attendance at the work site by the supervisor depends on the risk.
Application to vessels (regulation 32)
17 EAWR does not apply to the master and crew of sea-going ships in relation to 'normal ship-board activities'. This can have a wide interpretation, and some of the activities on vessels such as mobile drilling units, floating production vessels and heavy-lift vessels (which may from time to time also be installations) can fall into this category. The legal and operational strategy team can advise further.
Further information can be obtained from the OSD Electrical and Control Systems team.