OIA (251173) – Questions from Mr Thornton and WorkSafe responses
o
2.1 Question 1:
MBIE was to respond to this question as agreed in
response plan. No WorkSafe response needed.
Traditionally, paper copies of critical documents like standards,
procedures, and manuals would be amended by providing replacement
pages for a bound copy, or instructing the user to hand-write
modifications in the margins.
Given paper copies of standards are no longer commonplace, and all
digital copies of the Standards with ESAR “modifications” are:
•
Subject to copyright
•
Copy protected (cannot be readily annotated or marked-up)
•
Available with official amendments pre-applied (e.g. AS/NZS
3000:2018+A3)
What is the plan to ensure copies of the Installation Standards with the
ESAR 2025 “modifications” pre-applied are readily available to Electrical
Workers and other users, and/or allow users to apply these
modifications themselves?
o
2.2 Question 2:
As agreed with MBIE, WSNZ to respond, but MBIE
noted that they may have some relevant records.
IANZ/NATA and equivalent accredited test houses are required to
undertake product testing to the product Standards as written.
WorkSafe interprets this question as being related to specific
What work has occurred with IANZ/NATA to ensure that the product standards referred to in Schedule 4, rather
“modifications” to product standards within ESAR 2025 will:
than standards in Schedule 2, which are not product
•
Be enforced when testing product intended for the New Zealand standards.
market
•
Be referred to on test certificates in a distinct manner from There is no need to work with IANZ or NATA regarding
unmodified versions of the standards
modifications to product standards specified in Schedule 4 of
•
Not invalidate the testing for other jurisdictions using unmodified the Electricity (Safety) Reg
Released under the Official Information Act 1982 ulations.
versions of the standards
•
Be compatible with the remainder of the Standard, without The principle of applying modifications is well established and
introducing contradictions or unintended consequences
is applied internationally. Most modifications are consistent
with the modifications already present in the regulations prior
to the November 2025 amendments.
Both test houses and CABs, which are responsible for product
certification, are expected to apply modifications
as appropriate for the markets for which product is
intended. It is expected that CABs and test houses are
familiar with relevant requirements for the markets they
serve.
o
2.3 Question 3:
As agreed with MBIE, WSNZ to respond.
Given New Zealand is a small place that is subject to the same physics WorkSafe interprets this question as being related to the New
and international standards availability as the rest of the world, what is Zealand standards referred to in Schedule 2 as these are the
the basis for requiring bespoke New Zealand specific standards and only New Zealand specific standards cited in these
rules?
regulations.
Please provide any available analysis of the cost effectiveness and/or
benefits of these bespoke requirements, particularly regarding concerns The regulations cite very few New Zealand specific standards.
that it could:
Only three of the more than 400 standards cited in the
• Unnecessarily result in "New Zealand only” or “not for New Zealand” Electricity (Safety) Regulations are New Zealand only (NZS)
equipment that increases cost and diminishes choice for New standards:
Zealanders
• Cause test certificates issued by New Zealand providers to not be • NZS 6115 for mobile medical facilities
accepted in other jurisdictions
• Require expensive and unnecessary double-testing
• NZS 6116 for meat processing
• NZS 7901 for safety management systems for gas and
electrical networks.
These are not product standards so they will not create an
impediment to product certification or availability.
Released under the Official Information Act 1982
In each case there is not a relevant international or joint
standard that could apply. In any case, with some limited
exceptions, the scope of recent amendments
was strictly limited to updating references to currently cited
standards.
o
2.4 Question 4:
As agreed with MBIE, WSNZ to respond.
Given the choice to regulate prescribed electrical work and electrical The use of international and joint standards is successful in
products using Standards as a vehicle rather than using secondary providing for internationally consistent detailed requirements
legislation directly (e.g. ECPs and SWIs), why was the Standards or means of compliance. It should not be judged by
development process insufficient to ensure the Standards were suitable the relatively few instances where modifications are necessary
without further modification?
to ensure consistency with New Zealand systems or
requirements, or to clarify the purpose for which the standard
is cited for New Zealand.
That said, New Zealand’s interests are best served by the
standards process when it has strong and effective expert
representation across the range of relevant industry
interests, as well as regulatory interests, that can focus on
ensuring consistency with New Zealand systems and
requirements.
Released under the Official Information Act 1982
