Ten Unanswered Questions To The Department Of Labour MyZA

What Is Happening About Safety In The Electrical Contracting Industry?

On 4 March 2013 the Electrical Contractors’ Association’s – ECA(SA) – National Director, Chris Greager, addressed an e-mail letter to Department of Labour’s Chief Inspector, Thobile Lamati, and two of his senior staff requesting a meeting to discuss ten matters of concern to the Electrical Contracting Industry. As no response was received a reminder was sent on 14 March enquiring whether he was prepared to meet with a delegation from the ECA(SA). However, the request still remains unanswered.

In his e-mail Chris Greager pointed out that the ECA(SA) represents the majority of employers in the Industry, and that they look to the Association to provide them with answers and up to date information about what is taking place, and to look after their interests. It was essential therefore that their concerns be properly addressed.

On 9 April 2013 Chris Greager sent an e-mail to Dr Laurraine Lotter, the Chairman of the Advisory Council for Occupational Health and Safety (ACOS), informing her of the e-mail to the Chief Inspector and suggesting that a meeting to discuss the points raised should take place before the press conference on 30 April 2013. If such meeting proved to be fruitful and addressed the concerns listed positive results could then be announced.

A response was only received on 23 April indicating that the meeting could take place on 30 April or 2 May, but that the agenda would be restricted to those items relating to registrations and the AIAs and nothing else.

The ten points for discussion were as follows:

Lack of Policing: The total lack of policing in the Industry, particularly with regard to unregistered electrical contractors, shoddy and dangerous workmanship, and the issuing of invalid electrical certificates of compliance/test reports by some electrical contractors. Many complaints about these issues have been sent to the DoL’s Provincial Inspection and Enforcement Services offices for their action, but it appears that in most instances nothing is done about them.
Approved Inspection Authorities: The ECA(SA) requires clarification about Approved Inspection Authorities (AIAs). It had informed the DoL in the past of its support for AIAs, but wished to know how many had been accredited to date by the South African National Accreditation System (SANAS); how many had been approved by the Department in terms of regulation 3(1) of the Electrical Installation Regulations, and who they were. It indicated that it would like to work more closely with the AIAs when dealing with complaints from users, but as far as it could ascertain there are only two or three in the whole of South Africa which rather defeats the object of their existence.
Correct Complaint Procedures: The ECA wishes to establish the correct procedures to be followed when it or members of the public wish to lodge complaints about dangerous or illegal electrical installations, unregistered electrical contractors, etc.
Procedures for AIAs: It also wishes to establish the correct procedures that should be followed by the AIAs, and to whom they are accountable. At a meeting on 6 October 2010 the Association was informed that the DoL was preparing a manual setting out the duties, functions and responsibilities of AIAs. This was again confirmed by a senior official at a meeting on 21 May 2012, but to date it had not been received. Such document is vital so that the Industry can gain a better understanding about what the AIAs can and cannot do.
Limitations of AIAs: The ECA also wishes to establish whether individual AIAs are limited by their registration as “registered persons”. For example, can an AIA with only one installation electrician in its employ inspect, test and pass comment upon installations in hazardous and/or explosive locations despite the fact that only master installation electricians are registered to carry out such work.
Registration of Electrical Contractors: On 1 September 2012 the Department of Labour took over the annual registration of electrical contractors from the Electrical Contracting Board of South Africa (ECB) which has been carrying out such function on behalf of the Chief Inspector since 1993. Since then numerous complaints have been received from electrical contractors about the registration process at some of the DoL’s provincial offices. Documentation that is being posted is at times mislaid or lost, resulting in delays in the contractors’ registration, thus placing them in contravention of regulation 6 of the Electrical Installation Regulations. In addition, many travel to the provincial offices from many kilometres away only to be told that the person carrying out the registrations is not available
Assistance with Registrations: In order to assist in the registration process, the ECA(SA) proposed entering into an agreement of co-operation with the DoL to use the Association’s seven regional offices as “post offices” to accept electrical contractors’ registration documentation and to submit them it to the DoL’s offices for their necessary attention. This would do away with the problems associated with finding parking and then being informed that there are no officials available to deal with the registration.
Access to Database: The ECA(SA) has requested access to the data base of registered electrical contractors. It receives many enquiries from municipalities, the National Bargaining Council for the Electrical Industry, estate agents and the general public asking whether certain businesses are registered. In the past, it was able to access this information but can no longer do so.
Periods of Registration: It appears that most of the Department’s Provincial offices are allowing electrical contractors to register for three years at a time, and there are other examples where contractors have been registered for up to seven years. Regulation 6(2) of the Electrical Installation Regulations prescribes “annual registration”, so the ECA(SA) is puzzled why this requirement is being ignored. It has asked what control the Department will have if a firm’s licensed electrician resigns, dies, retires or emigrates. It could continue operating for long time without a registered person in its full-time employ and no-one would be any wiser.
Certificates of Compliance for Electric Fences: Finally, the ECA(SA) expressed the need to discuss the requirement in terms of regulation 12(4) of the Electrical Machinery Regulations that the user or lessor of an electric fence shall have a certificate of compliance for a new fence, when any addition or alteration is effected to the fence, or when there is a change of ownership of the premises after 1 October 2013. Such certificate may only be issued by a person registered by the DOL as an electric fence system installer. The ECA says its supports this requirement, but that training to undertake the necessary skills programme is not currently available countrywide. Accordingly, the Association proposes that the DoL extend the registration criteria for approximately one year to permit registered installation electricians or master installation electricians to issue the certificates. They would then have time to complete the skills programme.