4 May 2026
File Ref: 260317
Mark Harris
Vice President, NCEIA
[FYI request #34328 email] Dear Mark,
Thank you for your Official Information Act (the Act) request received on 1 April 2026. You
requested:
•
In a 15 January 2026 letter (WorkSafe reference 260032) WorkSafe stated “our
experts carefully considered the relevant scenarios and both the risks being
addressed and the risks associated with the change”.
▪
Please provide the expert risk assessment scenarios, risk scoring and related
analysis regarding the removal of PEN conductor protections from
AS/NZS3000:201 sections 2.3.2.1.2 (b) and (c) that are referred to in the 15
January 2026 letter (WorkSafe reference 260032).
The recommendation to remove the application of clauses 2.3.2.1.2(b) and (c) of AS/NZS
3000:2018 for New Zealand came about while making detailed recommendations for amending the
regulation subsequent to public consultation about updating references to cited standards in the
Electricity (Safety) Regulations. These recommendations arose from consideration of feedback
from MBIE’s formal consultation, and how best to implement the citation of AS/NZS 3000, as well
as ongoing discussions amongst technical experts about better providing for electrical safety to
address outstanding issues. Specifically, neither AS/NZS 3000:2007 nor AS/NZS 3000:2018 deal
effectively or comprehensively with providing for electrical safety in circumstances where there are
acknowledged weaknesses with the New Zealand MEN system, including those associated with:
•
supply faults occurring during the charging and discharging of electric vehicles; and
•
the resilience of the electricity supply of an installation in the face of a natural disaster.
In the “EV” scenario, interruption of the protective earthing or the neutral (PEN) conductor of an
electrical installation is a foreseeable failure mode for MEN systems. It has the potential to cause
the metal bodywork of a connected EV to become enlivened. Removal of the restriction stated
clause 2.3.2.1.2 (b) and (c) allows for the introduction of techniques which better provide for the
safety of EV charging under foreseeable fault conditions.
In a “resilience” scenario, where an installation has the ability to generate electricity independently
from the grid, removal of this restriction enables solutions in which the installation can be
configured to operate safely if supply from the grid is lost without putting the grid, including
conductors of the grid, and other users, at risk from the grid being re-enlivened inadvertently. The
need to better provide for resilience of electrical installations received added emphasis following
cyclone Gabrielle in 2023, after which WorkSafe issued guidance on how an electrical installation
could be reconfigured for independent operation on a temporary basis.
Noting that there are more general provisions for safety, removing the application of the
prescriptive clauses 2.3.2.1.2 (b) and (c) was proposed as an achievable preparatory step to
better provide for safety in these scenarios. The recommendation anticipated that rules or
guidance, setting out when and how ‘switching’ of these conductors would be permitted to better
provide for safety in specific scenarios, will be promulgated.
PO Box 165, Wellington 6140
It was not intended to permit ‘switching’ of these conductors without introducing substitute
controls to provide for safety.
In any case, removing the application of clauses 2.3.2.1.2 (b) and (c) did not remove all controls
which restrict switching those conductors, nor did it require that switching be installed in any or all
circumstances.
In developing the recommendations, WorkSafe technical experts carefully considered the relevant
scenarios and both the likelihood and consequence of the proposed changes, given the
characteristics of New Zealand’s electricity supply system which relies on multiple earthing of the
neutral conductor (MEN earthing). The scenario and risk analysis considered and compared
realistic failure modes and their likelihood and consequences. This took the history of events which
led to significant consequences into account.
Given the recommendation was proposed as a preparatory step, with the intention that the
restriction would be replaced by specific guidance relevant to each scenario, a formal documented
risk analysis or cost-benefit analysis was not justified or necessary for this specific change which
merely removed a partial control. The anticipated guidance included identification of scenarios in
which ‘switching’ of either the main earth or PEN conductor would be allowed and where it would
not be allowed.
Each item was also considered for consistency with the overall policy mandate for the project to
update references to cited standards to be satisfied that it was:
▪
consistent with overall goal of improving safety, and specifically safety of EV
charging and Government goals of improving EV charging infrastructure;
▪
not inconsistent with the policy mandate;
▪
necessary to address or prepare to address an identified risk that was not
adequately addressed; and
•
did not create additional risk.
Please note, WorkSafe has not identified any documents in scope of your request which record the
discussions or analysis. Accordingly, we have decided to refuse part of your request under section
18(e) of the Act, as the information requested does not exist, or despite reasonable attempts to
locate it, cannot be found.
If you require further assistance, please contact
[email address]. Yours sincerely
Rob Pope
Head of Inspectorate
2
