SAFETY OBSERVERS
NSW/ACT BRANCH
AND LVR/CPR – WHAT YOU NEED TO KNOW “Two there should be. No more, no less. One to embody power, the other to crave it.” — Darth Bane, Star Wars Canon
near’ energised electrical equipment will need a safety observer present. Hence the ‘Rule of Two’ comparison.
Once upon a time in a galaxy far, far away, the Rule of Two was a Sith philosophy established by Sith Lord Darth Bane, in order for the Sith to survive and one day gain revenge on the Jedi. The rule mandated that only two Sith Lords could exist at any given time: a master to represent the power of the dark side of the Force, and an apprentice to train under the master and to one day fulfill their role.
At NECA we have been providing complimentary compliance audits for many of our members and we specifically have a question about compliance with safety observer laws. As a result of these audits, we’ve found the majority of electrical contractors are confused with the requirements, and have been undertaking work without safety observers present when there should have been.
Yes, I am not only a safety nerd, but a Star Wars geek as well. However, it occurs to me that the Sith’s survival philosophy is strikingly similar to what electricians need to keep themselves safe. The way safety observers are written into law is basically a ‘Rule of Two’.
Safety risks and triggers
So, what is the law regarding the requirement for Safety Observers? Well, it’s complicated. First, to understand how the regulations work, you need to understand the steps. The steps outlined below are based on the Model WHS Regulations (check your local jurisdiction’s regulations for more specific requirements). Clause 154 prohibits all electrical work on energised electrical equipment. This includes testing, fault finding, testing for dead, verification and anything within 500mm of an exposed live or unverified conductor. Clause 157 provides the four exceptions to the above rule which allows a licensed electrician to undertake this work when needed (which is basically a lot of the time).
What triggers the requirement for a safety observer if you are undertaking testing work? Clause 161 (5) says you don’t need a safety observer when ‘there is no serious risk’, so what are those serious risks? NECA’s safety professionals believe those risk/triggers are: 1. Electrical testing work in an area of reduced mobility. This includes: Awkward positions such as kneeling or laying down. Restricted areas in and around switchboards. Ceiling and roof spaces. Spaces under floors. Ladders, scaffolds, or elevated work platforms. Trenches. Pits or tunnels. Confined spaces.
Clause 161 (1) mandates that any work completed under the four exceptions must be completed by a competent person with a safety observer present (the ‘Rule of Two’).
2. When separation from earth cannot be maintained.
Clause 161 (4) requires the safety observer to be competent in emergency, rescue and resuscitation. Also, the safety observer must have been assessed in the previous twelve months as competent to rescue and resuscitate a person.
Before starting any work, check your surroundings and equipment. Voltages between phases and earth (including metal work, damp situations, other conductive surfaces, and persons nearby) can result in an electric shock.
Clause 161 (5) provides an exemption to the requirement of a safety observer if you have completed a risk assessment that shows that there is no serious risk associated with the proposed work, and the work only consists of testing. Clear as mud right! The best way to summarise it is to say that the majority of the work ‘on or
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3. Work on high fault level equipment and situations, greater than 20kA. Example of the kA (kilo amps) rating on a circuit breaker.
4. Work on exposed energised conductors or live conductive parts. If the above conditions are not present, and the work you are undertaking only consists of testing, then you don’t require a safety observer, as long as you have completed the risk assessment. Based on my experience, these situations will be in the minority.
Choosing a safety observer Electrical apprentices are allowed to undertake cardiopulmonary resuscitation (CPR) and low voltage rescue (LVR) training, which will make them competent to be a safety observer. This works well because not only are apprentices cheaper to send to the training, but apprentices are not permitted to undertake the work themselves, and need to observe the work to learn. A tradesman to test the power, and an apprentice to train under the tradesman and maybe even save the tradesman if needed. This sounds a lot like Darth Bane’s ‘Rule of Two’. Our new NECA Electrical SWMS details the requirements for safety observers. NECA members from ACT, NSW, QLD and TAS (Group States) can download this document for free from TKB at www.bit.ly/tkbswms. Everyone else can purchase this document from our online document store at www.bit.ly/swmsbuy. The electrotechnology industry is one of the most heavily regulated industries in the country. It becomes very easy, when you are focused on quoting, estimating, invoicing, ordering parts, time sheets and keeping schedules, to be blindsided by non-conformances. I have seen businesses brought to their knees because of something simple they forgot, or just weren’t focused on. NECA’s HSEQ compliance audit is a quick thirty-minute audit that helps you focus on the important things, so your business doesn’t fall through the cracks. If you are a NECA member, call us today to book your free HSEQ compliance audit.
Owen Leslie WHS Manager, NECA NSW owen.leslie@neca.asn.au
September 2021
