Energy Safety advice 1987
Independent review findings
Act
Information
Official
the
under
Mark Wogan & Scott Collins
March 2026
Released

Today's agenda
1987
Act
01
Context
02
The reviewer
Information
03
Key findings
Official
the
04
Residual risks
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05
Next steps
Released

Context
1987
What changed
Sector concerns
Act
The Electricity (Safety) Amendment Regulations
2025 deleted Clauses 2.3.2.1.2 (b) and (c) from
AS/NZS 3000:2018 - the electrical wiring rules.
Stakeholders raised concerns with WorkSafe
about the regulatory change made by MBIE.
Information
These clauses previously restricted the switching
of neutral, earthing, and PEN conductors.
Concerns centered on the hazards of switching
earthing and PEN conductors - specifically the
Official
The change was made to enable:
risks of electric shock.
•
Island mode operation (homes running the
independently from the grid)
•
Renewable energy and battery storage
systems
under
•
Open-PEN detection devices for EV
charging safety
Released

1987
WorkSafe commissioned an independent review to:
Act
• Test the soundness of the advice given to MBIE
• Identify residual risks
• Respond credibly and transparently to the sector
Information
Official
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under
Released

The reviewer
Independent international expert
1987
Act
30+ years in electrical engineering, infrastructure, installations, safety
and product assurance
Graham
Chartered Engineer and Registered European Engineer (Engineers
Kenyon
Europe)
Information
Chair, UK joint IET/BSI Committee JPEL/64 — responsible for BS 7671 (IET
UK-based
Wiring Regulations, 18th Edition) and IEC 60364 series
Chartered Electrical Engineer
Official
Chair, UK technical committee GEL/600 — responsible for BS 7430
Code of Practice for Earthing
the
Member of the Institution of Engineering and Technology and
Technical Member, Institute of Occupational Safety and Health
under
Released

Key findings
The advice was technical y sound and justified
1987
Act
"The decision to delete the clauses is technically justifiable."
Information
Advice was justified
Change was necessary
Official
The independent reviewer
Retaining the clauses would
found Energy Safety's advice
have blocked the adoption of
the
on removing the restrictions
modern technologies -
from AS/NZS 3000 was sound
renewable generation,
and technically defensible
battery storage, EV charging
under
overal .
protections, and island mode
operation.
Released

Residual risks
Real, known, and manageable
1987
Act
Switching PEN conductors
Island mode operation
Switching neutral conductors
Remains technical y permissible.
PEN conductors should not be
Product standards (IEC 60947, IEC
Guidance needed to prevent this
used in energised parts of
60669) already require neutrals to
Information
- risk to MEN network workers exists.
installations operating in island
make/break with live conductors.
mode.
Further guidance needed.
High priority
Guidance in development
Partially mitigated
Official
Switching earthing conductors
Open-PEN detection devices
the
Diverted neutral currents
(OPDDs)
New standards or guidance
If the MEN neutral is not
No NZ-mandated standard yet. IET
needed — similar to UK provisions
disconnected during islanding,
01:2024 ex
under ists in the UK. Standards
in BS 7671 — to permit switching
network workers may be exposed
work required for EV charging
only alongside live conductors.
to hazardous currents via parallel
safety.
earth paths.
Action required
Action required
Addressed in guidance
Released

Why the risks are manageable
1987
Existing controls already reduce exposure
Act
Licensed workers only
Existing standards apply
Installing switching of this type requires licensed
AS/NZS 4509.1 for stand-alone systems and
electrical workers and inspectors under
WorkSafe's Tech
Information nical Bulletin for temporary
Regulations 13 and 14 of the NZ Electricity
generator connection already address some
(Safety) Regulations.
island mode scenarios.
Official
the
Product standards provide controls
Internationally well-understood
IEC 60947 and IEC 60669 series already include
These risks are not unique to NZ.
under
requirements that replicate many of the deleted
clause provisions for relevant switching
The UK has established solutions addressing
products.
comparable scenarios for OPDDs that can be
adapted for the NZ context.
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Energy Safety’s approach
1987
Act
Evidence-led
Drew on the best available evidence, including
international standards, industry guidance, and
Risk-aware
analysis of specific risks in the NZ context.
Residual risks w
Information ere identified and weighed as part
of the decision. The independent review confirms
this risk analysis was sound.
Balanced
Official
Carefully balanced innovation, emerging risk,
energy resilience, and safety.
Transparent
the
WorkSafe proactively commissioned this
independent review and is releasing the full
findings today.
Stakeholder-responsive
under
Stakeholder concerns raised were considered. The
review found those concerns were addressed
within the risk analysis.
Released

Acknowledging sector concerns 1987
Act
What was raised
How the review addressed this
Critically, Graham Kenyon reviewed sector
Stakeholders formally wrote to WorkSafe raising
concerns after forming his own independent
concerns about the regulatory change.
opinion - not b
Information efore.
Concerns centered on the hazards of switching
This ensured his technical conclusions were not
earthing and PEN conductors - specifical y the
shaped or influenced by the concerns raised.
Official
risks of electric shock.
His assessment: the hazards described are real.
the
They are documented in the review. And they
WorkSafe takes those concerns seriously. They
are addressed within the residual risk analysis.
reflect real risks in this space, and they
deserved a rigorous, independent response.
under
The reviewer concluded sector concerns were
already captured - and that guidance and
standards work will close the remaining gaps.
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Next steps
What Energy Safety wil do now
1987
Act
1
Guidance
Develop and publish guidance on switching arrangements, covering the conditions for switching a PEN
conductor and clearly defining where switching of PEN conductors may not be used.
2
Switching arrangements
Information
Clarify requirements for switching neutral and protective earthing conductors
Official
3
Product standards
Work with standards bodies and sector partne
the rs to develop solutions for emerging technologies, including
open-PEN detection devices (OPDDs). Work on an update to the EV guide is underway.
4
Interim advice
under
Electricians are advised to avoid installing switching or similar devices in earthing or PEN conductors until
further guidance is published.
Released

1987
Act
A link to the
independent
The risks are real.
review report
They are known.
Information
will be emailed
They are
Official
manageable.
to you later
this afternoon
the
under
Released

Ngā mihi nui
1987
Act
Information
Official
the
under
Subscribe to our e-newsletter
Energy Safety Business Update
via worksafe.govt.nz Released

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