Kia ora Andrew McGregor,
 
On behalf of the Ministry of Business, Innovation and Employment I
acknowledge your email of 26/08/2025 requesting, under the Official
Information Act 1982, the following:
 
Dear Ministry of Business, Innovation & Employment,

The new endorsed licence classes for electrical workers came into effect 4
August 2025 (Gazette Notice SL4191 issued 1 August 2025).

This includes qty 12x major classes of registration (electrician,
electrical inspector etc), each may have up to five endorsements
(supervision, hazardous areas etc) for a total of qty 41x individual
classes of registration and thousands when taken in combination. Likely a
world-record number for any occupational licensing regime.

Schedule 2 “Minimum Standards for Registration Prescribed by the Board” is
in effect now.

NZEIA is concerned regarding possible perverse effects and outcomes
arising from what appear to be arbitrary criteria (‘…satisfactory to the
Board…’) in these minimum standards.

This concern is real. NZEIA has members who have recently lost the ability
to work on PEW that now requires an endorsement, and have been declined.
NZEIA would have expected these member’s competence and experience to have
proven satisfactory.
Conversely, we have seen people issued with endorsements that appear to
have neither suitable competence nor experience. Examples of such may
include MBIE/EWRB’s own staff.

Question 1: What are the currently approved courses of study for each of
the 41 registration classes?

NZEIA notes that experience thresholds will be applied. In order to be
consistent, just, and to not appear to be ‘arbitrary’ or ‘malicious’ the
threshold criteria be applied needs to be  transparent.

Question 2: What are the actual threshold criteria for the minimum
experience requirement that will be applied for each of the 41
registration classes?

NZEIA is concerned that the current requirement relevant competence are
‘half-baked’ resulting in them being logically unachievable. This is
consistent with the botched earlier Gazette Notice SL4075 what was hastily
(but not promptly – that would have been early in 2024 when issues were
first notified to the EWRB) replaced with SL4191.
Specifically PEW on endorsement class 3 Electrical Inspector (Endorsed
Hazardous Areas) requires “completed not less that one year of practical
experience in a hazardous area or substantially similar practical
experience…”, however doing so without the required endorsement is an
offense.

Question 3:  Given it an offense to undertake PEW in Hazardous-Areas
without the required endorsement how does the EWRB expect electrical
workers to obtain the required Hazardous Areas experience?

Presently electrical design, including design of hazardous areas and
medical patient treatment areas and the like is not prescribed electrical
work (PEW) as defined in Schedule 1 of the Electrical (Safety)
Regulations.
Anyone, regardless of their qualification, training and competence may
undertake electrical design in these areas (NZEIA believes this is a
significant omission must be fixed and soon – but is off-topic for this
OIA request).
In requiring electrical workers to have micro-credentials that include a
significant design component (ie not just component selection to the
requirements of the appropriate mandatory standards) the EWRB is stepping
beyond their current authority to regulate PEW.

Question 4: Are micro-credentials that include significant electrical
design content (eg EEHA, mains-parallel/solar) going to be mandatory
requirements for obtaining any endorsed classes of registration?

The vast number of registration classes now required by the EWRB will
newly create scarcity or total absence of appropriately registered
electrical workers, particularly in regional New Zealand.

Question 5: What is the current number of licenced workers for each of the
41 registration classes?

Question 6: What is the current number of licenced workers for each of the
41 registration classes in each of the regions in New Zealand?

Question 7: Does the EWRB have plans (contingency or otherwise) regarding
the increased risk (ie unintended consequences) arising from having no
suitably licenced workers available in much of the country? If so, what
are they?

Within Schedule 1 of Gazette Notice SL4191 the Board is careful to limit
the allowable prescribed electrical work (PEW) to less than the full range
defined in Schedule 1 of the Electrical (Safety) Regulations.  The result
appears to be that PEW that is not on/in works, installations and/or
appliances presently cannot be undertaken.
An example is the installation of electrical cables in a building under
construction that is not, but is intended to become, an installation. This
is not accidental as:
•       NZEIA advised the EWRB of this issue multiple times, including in
feedback of the draft consultation document that would become SL4191.
•       A exemption exists for conductors being installed on yet-to-be
lines that will later become works.

Question 8: Which of the 41 registration classes is authorised to
undertake PEW that is not on/in works, installations and/or appliances? If
none, what is the EWRB’s plan for fixing this?
 
We will endeavour to respond to your request as soon as possible, and no
later than 23/09/2025, being 20 working days after the day your request
was received. If we are unable to respond to your request by then, we will
notify you of an extension of that timeframe. If you have any enquiries
regarding your request feel free to contact us via email to
[1][MBIE request email].
 
Nāku noa, nā
Ministerial Services
Strategy and Assurance
Ministry of Business, Innovation & Employment
15 Stout Street, Wellington 6011 |  P O Box 1473 Wellington 6140

References

Visible links
1. mailto:[MBIE request email]

Kia ora Andrew
 
Please see attached our response to your request for information under the
Official Information Act 1982.

Ngā mihi nui,

Ministerial Services
Ministry of Business, Innovation and Employment

15 Stout Street, Wellington 6011 | PO Box 1473, Wellington 6140