Submissions: Electrical Safety Act 2002 review - Discussion Paper

Good afternoon,

I have provided feedback for some of the recommendations below.

1. Recommendation 6: That is a definite step in the right direction.
2. Recommendation 15: This is needed within the industry. I have spoken to many electricians who believe that testing is not live work and, therefore, exempt from the code of practice requirements.
3. Recommendation 24: This will help ensure the safety of electrical workers.
4. Recommendation 30: Consultation is essential to electrical safety, often missing in the workplace.
5. Recommendation 38: This is a great idea. Standards are costly, yet essential to ensure work is carried out correctly.
6. Recommendation 43: This would help ensure PCBU takes electrical safety advice seriously. PCBUs and their knowledge regarding electrical safety can help or hinder safety in a business.
7. Recommendation 65: The time to carry out this task should be considered to ensure that it is not a hold point where entities are waiting for an auditor. This should also ensure auditors have an adequate warning to ensure they can schedule upcoming work over the entire year.
8. Recommendation 70: This isn't easy to regulate.

1. After reading the review, summary. I would say no change to Legislation, Option 1 would get my vote.
   regards
   Nigel Gibson
   Electrical worker
    
2. Submission 04B

Good Afternoon,
Please accept my comments regarding the current discussion paper : Review of Queensland’s Electrical Safety Act 2002.
In Section 73 : Work involving electric motor forming part of vehicle (1) A person must not perform work on an electric motor forming part of a vehicle unless— (a) the person is a licensed electrical worker.
I am putting forward that a Technician / suitably qualified person has a training endorsement / Certificate or employs a person with an endorsement /Certificate, or is a Qualified Auto Electrician, from a Registered Training Organisation. 
The requirement of an Electrical Licence is not required.
The Technicians and Organisations I am currently assisting with the VSB14 Approval process (LV1 Code) follow the attached National Standard.
Thank you for providing the opportunity to add feedback to your discussion paper.
Feel free to call me to discuss further.

Attachment 14

To whom it may concern,

This submission is about Escooters, Low priced Ebikes and Electric Unicycles.

As a result of being an owner of all of these products and experiencing a very poorly monitored ACCC mechanical recall, I decided to look more closely at Electrical safety.

I discovered many issues

1. Because of voltage levels, scooters aren't within the scope of EESS with the exception of chargers.
2. They are within the scope of the ACMA and are a medium level hazard which then requires them to have clearly visible RCM triangle and tick image.
3. I have emailed most of the importers of these devices and found that not one responded positively to having a RCM. This leads me to believe that importers of over 300,000 recreational devices of this kind never bothered to look at Electro magnetic certification.
4. I have included a letter from the ACMA that they highlighted, that acknowledges scooters are within their scope. When I complained I was then told that escooters aren't within their scope until I sent their letter back to them. They have now accepted the compliant but have done nothing to date.
5. I asked QFES for data with respect to fires caused by these eproducts and although this information should be freely available, I was told to take out an FOI request.
6. Electric Unicycles, chargers and units comply with no regulations at all, 30% of them on the market are over 120 volts DC.
7. Most of the above mentioned items have no battery compliances at all, not even overseas CE or IEC conformity.
8. When being freighted Lipo batteries are class 9 dangerous goods. Very few fill out dangerous goods declarations for road freight.

In conclusion, if standards are to be lifted with the eproducts mentioned then they need compedant enforcement of one regulatory all encompassing body.

John Holland and I directly are not directly impacted by the solar PV and BESS systems as we are not actively working in the smaller market. We may carry out some projects in the large commercial or grid scale renewable sector.

I support the recommendation the Solar PV and BESS be integrated into the Electrical safety act. There are other sources of electrical energy that may also need to be brought into consideration including hydrogen fuel cells, super capacitors, wind and micro hydro. I recommend the definitions are broad enough to include newer technologies.

Another concern is that off grid may not be adequately captured within the existing electrical safety systems. Domestic systems in particular could be put together by people who want nothing to do with “big electricity” and who believe rules don’t apply to them, especially as they are independent.

There will also need to be consideration of low energy installations so naïve users are not caught up in red tape. This could include Christmas lights powered by solar panels, camping power supplies, ELV battery supplies in remote areas, scientific equipment and monitoring systems, solar arrays on boats and caravans. I think a power/energy threshold may provide safe systems without significant risk. I believe that the 80kW limit is far too high.

With regard to the installation of mechanical protection as electrical work, Queensland is to my knowledge the only jurisdiction that defines this as electrical work, or work that requires direct supervision. I do not see a significant electrical risk in the installation of plastic conduits by non-licenced personnel, and this view is probably supported by the other jurisdictions who are silent on this risk.

Regards

1. Submission 50a
2. Submission 50b

Regarding your Discussion paper I would like to make general comments on each of the three topics highlighted:

• new and emerging technologies,
• the changing landscape of electricity and the workforce and
• understanding, and electrical safety and electric vehicles

Context assumed

There is good reason for the public to be advised about risks that exist with electricity, the devices that use electricity, and exist when repairing these devices.

There are regulations that limit what work can be done on certain electrical circuits and devices. These allow suitably informed, licensed, supervised and/or trained people to perform certain work.

The manufacturers or importers of electrical components or devices should specify the specific regulations that apply to their products. This would impose accountability for consequences should their specification be inappropriate.

Specific Focus

1. new and emerging technologies
   My recommendation for this topic is Option 3.
   I believe it may be worthwhile for domestic and rooftop solar systems to require certification by a professional electrical engineer or electrician. There would need to be training and availability of this expertise at short notice before this was introduced.
2. the changing landscape of electricity and the workforce and understanding,
   My recommendation for this topic is Option 4.
   The changes outlined are likely to be far beyond the capacity of available workforce and their development at a time when worker shortages will grow dramatically.
   With a tail wind we may be able to develop new staff with finely focussed expertise to meet existing needs but over the next ten years we will need to increase workforce by 20-50% annually to keep up with existing demands.
3. Electrical safety and Electric vehicles
   My recommendation for this topic is Option 3.
   Electric vehicles are developing and improving every aspect of EVs at a rate which is beyond any previous experience.
   Any effort to change rules will completely deprive QLD of EV supply. Suggested changes will ignored as it will be years behind developments already underway.
   It may be worthwhile having an ongoing consultation with consumers and academics with expertise on traffic management to prepare for future automation and integration of EVs with traffic management systems.