GKT GENC REP 0004 r01 Review WorkSafe NZ.pdf

G Kenyon
Technology
Review of technical
decision for WorkSafe
New Zealand
under the Official Information Act 1987
Ref:  GKT-GENC-REP-0004
G Kenyon Technology Ltd
Released
Rev:  01
15 Westmorland Ave,
Thornton-Cleveleys,
Date:  16 February 2026
Lancashire.
t:  +44 (0) 753 985 1252
Author:  Graham Kenyon
FY5 2LX.
w:  www.gkenyontech.com
Status:  Draft
© G Kenyon Technology Ltd 2026.
Purpose:  Review
All rights reserved. No part of this publication may be reproduced in
any form or by any means without prior written permission.
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Document template GKT-CORE-TEM-0004 Rev 07. Template Copyright © G Kenyon Technology Ltd 2015-2020.

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Appendix D Provisions for and prohibitions on switching protective, neutral and PEN
conductors in IEC 60364 series ......................................................................................... 20
Appendix E Provisions for switching the neutral conductor in relevant product standards
referenced in Schedule 4 to the Electrical Safety (Amendment) Regulations 2025 ......... 23

Figures & Tables
1987
Table 2.1 Potential risks associated with the removal of Clauses 2.3.2.1.2 (b) and (c) from
AS/NZS 3000:2018 ............................................................................................................... 10
Table 3.1 Potential mitigation already in place of risks associated with the removal of Clauses
Act
2.3.2.1.2 (b) and (c) from AS/NZS 3000:2018 ......................................................................... 12

Information
Official
the
under
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1  Introduction
1.1  Formal details
1.1.1  This report has been prepared by Graham Harry Kenyon, Managing Director and Principal
Consultant  of  G  Kenyon  Technology  Ltd,  15,  Westmorland  Ave,  Thornton-Cleveleys,
Lancashire, FY5 2LX.
1.1.2  I am a Chartered Engineer, and Member of the Institution of Engineering and Technology
in the United Kingdom, with a career history of over 30 years. I practise as an independent
international  electrical  engineering  consultant  with  relevant  experience  in  electrical
installations, and electrical product assurance and safety, globally. I have been in my
1987
current  position  for  10  years  10  months,  previous  to  which  my  experience  was
engineering  and  technical  assurance,  for  projects  developing  specialist  systems  for
major infrastructure programmes. I have been actively involved with standardization in
the electrotechnical sector for around 20 years, and have held formal qualifications in UK
Act
electrical installation design, installation and verification practice since 1992. I am the
current Chair of joint IET/BSI Committee JPEL/64, which is the UK national committee
responsible  for  a  number  of  standards  including  BS  7671  Requirements  for  Electrical
Installations (IET Wiring Regulations, 18th Edition), and the international IEC 60364 series,
and also the current Chair of UK technical committee GEL/600 responsible for BS 7430
Code of Practice for Earthing. I am the author of an extensive range of electrotechnical
industry guidance and training publications for the UK; a comprehensive list can be found
at: https://www.gkenyontech.com/the-principal/publications/.
Information
1.1.3  I have been engaged by WorkSafe New Zealand to conduct a technical review, which is
outlined in the background to this report (Section 1.2).
1.2  Background
1.2.1  Schedule  2  to  the  New  Zealand  Electricity  (Safety)  Amendment  Regulations  2025
[reference 1]  deletes  Clauses  2.3.2.1.2(b)  and  (c)  from  AS/NZS  3000:2018  (including
Official
Amendments 1, 2 and 3) [reference 2].
1.2.2  The  provisions  of  Clauses  2.3.2.1.2(b)  and  (c)  from  AS/NZS  3000:2018  (including
Amendments  1,  2  and  3)  [reference 2]  relate  to  conditions  for  switching  neutral
the
conductors in electrical installations, and prohibition of switching of protective earthing
conductors  and  combined  protective  earth  and  neutral  (PEN)  conductors.  Specific
provisions of these Clauses are examined in Section 2 of this Report.
1.2.3  The  intent  of  deleting  Clauses  2.3.2.1.2(b)  and  (c)  from  AS/NZS  3000:2018  (including
under
Amendments 1, 2 and 3)  [reference 2]  for  New Zealand  was to  ‘future proof’  the New
Zealand Electricity (Safety) Amendment Regulations 2925 [reference 1], to facilitate:
(a)  Improvements in the integrity of electricity supplies to homes as a result of  power
outages in the distribution network, by permitting switching arrangements to ‘island’
the  installation  to  operate  from  a  source  of  energy  independent  from  the  public
distribution  network  (for  example,  temporary  generators  or  renewable  energy
systems with battery storage); and
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(b)  Permit the future use of protective devices that can operate to disconnect electric
vehicles from all live conductors, and the protective earthing system, in the event of
detection of conditions indicative of a broken PEN conductor upstream of the supply
to  the  electric  vehicle  charging  equipment.  The  Institution  of  Engineering  and
Technology  (IET)  in  the  UK  published  a  standard  for  such  devices,  IET  01:2024
[reference 3].
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2  Risks associated with removal of Clauses 2.3.2.1.2 (b) and (c) from
AS/NZS 3000:2018
2.1  Clauses 2.3.2.1.2 of AS/NZS 3000:2018 [reference 2]
2.1.1  Clause 2.3.2.1.2 of AS/NZS 3000:2018 [reference 2] is as follows (highlights are made for
clarity in later paragraphs of this review report):
2.3.2.1.2 Alternating current systems
Provisions for isolation of conductors in a.c. systems are as follows:
(a)  Active conductors All active conductors of an a.c. circuit shall be capable of being isolated by a
1987
device for isolation.

(b)  Neutral conductor:
Act
(i)  No switch or circuit-breaker shall be inserted in the neutral conductor—
(A)  of consumer mains; or
(B)  where  the  neutral  conductor  is  used  as  a  combined  protective  earthing  and  neutral
(PEN) conductor for protective earthing of any portion of an electrical installation.
NOTE: This requirement applies to situations such as an earth sheath return (ESR) system
or  a  submain  neutral  used  for  earthing  of  an  electrical  installation  in  an  outbuilding  in
accordance with Clause 5.5.3.1.
(ii)  A switch or circuit-breaker may operate in the neutral conductor of circuits other than those
in Item (i) where—
Information
(A)  the neutral pole of a multi-pole switch or circuit-breaker, having an appropriate short-
circuit breaking and making capacity, is linked and arranged to switch substantially
together with all active poles; or
(B)  the switch or circuit-breaker is linked with corresponding switches so that the neutral
contact cannot remain open when the active contacts are closed.
A switched neutral pole shall not open before and shall not close after the active pole(s).
Official
(iii) Where an item of switchgear is required to disconnect all live conductors of a circuit, it shall
be of a type such that the neutral conductor cannot be disconnected or reconnected without
the
the respective active conductors also being disconnected or reconnected.
NOTE:  The  manual  disconnection  and  connection  of  neutral  conductors  should  be  as
follows:
(a)  The active conductors should be disconnected before the neutral conductors.
(b)  The neutral conductors should be connected before the active conductors.
under
Refer to AS/NZS 4836 for safe work practices.
(iv)  A  switch  in  the  control  circuit  of  a  fire  pump  shall  operate  in  the  neutral  conductor  in
accordance with Clause 7.2.5.6.4.
In accordance with Clause 2.5.1.1, no fuse shall be inserted in a neutral conductor.

(c)  Switching  of  earthing  conductor  prohibited  An  earthing  conductor  shall  not  be  isolated  or
switched.
Released
A conductor used as a combined protective earthing and neutral (PEN) conductor shall not be
isolated or switched.

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2.1.2  Clause 2.3.2.1.2 (b) of AS/NZS 3000:2018 [reference 2], highlighted with a blue outline in
paragraph 2.1.1 of this report,  divided into four sub-clauses, numbered  2.3.2.1.2 (b)(i),
2.3.2.1.2  (b)(ii),  2.3.2.1.2  (b)(iii)  and  2.3.2.1.2  (b)(iv).  The  sub-clauses  deal  with
prohibitions on, or switching of, neutral conductors, including PEN conductors, and are
analysed in subsequent Sections of this report as follows:
(a)  Section 2.2 summarizes facts regarding the reasons for deletion of 2.3.2.1.2 (b) and
(c) of AS/NZS 3000:2018 [reference 2].
(b)  Section  2.3  summarizes  facts  regarding  risks  associated  with  switching  a  PEN
conductor that 2.3.2.1.2 (b) (i) and the second paragraph of 2.3.2.1.2 (c)  intend to
prevent.
1987
(c)  Section 2.4 summarizes facts regarding the risks associated with switching a neutral
conductor other than a PEN conductor, without opening the line (active) conductors,
that 2.3.2.1.2 (b) (ii) and (iii) intend to prevent.
Act
2.1.3  Clause 2.3.2.1.2 (c) of AS/NZS 3000:2018 [reference 2], highlighted with a green outline
in paragraph 2.1.1 of this report, prohibits switching of an earthing conductor (protective
conductor  in  IEC  60364  series  and  BS  7671)  including  a  PEN  conductor.  These  are
analysed in subsequent Sections of this report as follows:
(a)  Section  2.3  summarizes  facts  regarding  risks  associated  with  switching  a  PEN
conductor that 2.3.2.1.2 (b) (i) and the second paragraph of 2.3.2.1.2 (c) intend to
prevent.
(b)  Section  2.5  summarizes  facts  regarding  the  risks  associated  with  switching  of  an
Information
earthing conductor that  2.3.2.1.2 (c) of AS/NZS 3000:2018 [reference 2] intends to
prevent.
2.1.4  The deletion of Clause 2.3.2.1.2 (b)(iv) of AS/NZS 3000:2018 [reference 2] was, on review,
considered inconsequential, as it simply makes reference to two other Clauses, 7.2.5.6.4
and  2.5.1.1,  neither  of  which  are  deleted  by  the  Electricity  (Safety)  Amendment
Official
Regulations 2025 [reference 1].
2.2  Reasons for deletion of 2.3.2.1.2 (b) and (c) of AS/NZS 3000:2018
the
[reference 2]
2.2.1  Standards  are  currently  in  development  for  switching  arrangements  for  operation  of
electrical installations in New Zealand in island mode.
2.2.2  Island  mode  is  the  mode  of  operation  of  an  electrical  installation  in  which  is
under
disconnected from the grid, and supplied from a local energy supply, for example a rotary
generator, or inverters supplied by batteries, wind, and/or solar PV.
2.2.3  For safety of those operating on a public supply network, it is known that operation of an
installation  in  island  mode  will  involve  disconnection  of  live  (active  and  neutral)
conductors within the installation from the grid.
2.2.4  A  complicating  factor  is  the  multiple  earthed  neutral  (MEN)  arrangements  can  be
extended  to  other  parts  of  an  installation  such  as  an  outbuilding.  There  are  two  key
Released
aspects  that  might  affect  the  use  of  MEN  arrangements  within  an  installation  with
renewable energy systems in island mode:
(a)  Due to low fault currents associated with renewable technology inverters, RCDs are
often necessary, and these are not compatible with PEN conductors.
(b)  It is generally considered dangerous practice to recombine neutral and protective
(earthing) functions once they are separated. This is prohibited in BS 7671.
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2.2.5  It is not known at this stage precisely how island mode switching arrangements will be
achieved in standards and guidance in New Zealand, especially given the complicating
factors outlined in paragraph 2.2.4.
2.2.6  .  However,  standards  and  guidance  are  already  in  place  for  the  manual  temporary
connection of a generator by licensed electrical workers, see:
(a)  WorkSafe New Zealand Technical Bulletin Connecting a generator to the wiring of a
house or building following an emergency;
(b)  AS/NZS  4509  .1  Stand-alone  power  systems  part  1:  Safety  and  installation
[reference 5].
1987
2.2.7  Consideration was also given to the possible future use of protective devices that can
operate  to  disconnect  electric  vehicles  from  all  live  conductors,  and  the  protective
earthing  system,  in  the  event  of  detection  of  conditions  indicative  of  a  broken  PEN
Act
conductor  upstream  of  the  supply  to  the  electric  vehicle  charging  equipment.  The
Institution of Engineering and Technology (IET) in the UK published a standard for such
devices, IET 01:2024 [reference 3], termed ‘open PEN detection devices’ (OPDDs).
2.2.8  During  a  fault  resulting  from  a  broken  PEN  conductor,  touch-voltages  on  conductive
parts  of  electric  vehicles  connected  to  a  charging  point  can,  under  certain
circumstances, exceed the line-to-Earth voltage if the break in the PEN conductor is in a
three-phase  portion  of  the  distribution  system.  OPDDs  remove  the  danger  by
disconnecting  all  live  (active  and  neutral)  conductors,  and,  at  the  same  time,  the
protective (earthing) conductor to the charging point, which would otherwise continue to
Information
transfer  the  raised  PEN  conductor  potential  to  conductive  parts  of  the  vehicle.  This
necessarily requires switching of the earthing conductor.
2.3  Risks associated with switching a PEN conductor
2.3.1  Sub-clause  2.3.2.1.2  (b)(i)  of  AS/NZS  3000:2018  [reference 2]  prohibits  switching  of  a
neutral conductor of the consumer mains, or a PEN conductor.
Official
2.3.2  The effect of switching a PEN conductor is to remove both protective earthing and neutral
functions  from  exposed-conductive-parts  downstream  of  the  switch.  The  risks
the
associated with switching a PEN conductor depend on whether the circuit (or service)
associated with the PEN conductor is single-phase or three-phase, and whether multiple
earthing (MEN) provisions are available downstream of the disconnected PEN conductor.
2.3.3  It is not desirable to switch a PEN conductor under any circumstances. Not all countries
permit switching of protective conductors in their national wiring codes. The UK is one
under
country that does, but even in the UK, switching of PEN conductors is not permitted (see
Appendix C Section C4).
2.3.4  If a PEN conductor is switched at the same time as the other live conductors:
(a)  The earthing resistances on an MEN distribution network as a whole are changed.
(b)  Touch-voltages  can  develop  between  exposed-conductive-parts,  and  earthing
(protective) conductors, on both sides of the switched conductor.
Released
2.3.5  If a PEN conductor is switched and line (active) conductors are not also disconnected,
the resulting impact depends on the following factors:
(a)  whether the circuit or system is single-phase or three-phase; and
(b)  if  the  PEN  conductor  is  part  of  an  MEN  system,  or  there  is  bonding  or  fortuitous
contact with the Earth either director or indirectly through extraneous-conductive-
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parts, so that there is a PEN return path around the switched PEN conductor due to
low effective earth electrode resistance.
2.3.6  In single-phase  circuits and systems  with PEN  conductors, exposed-conductive-parts
downstream of an open-circuit PEN conductor can have a touch-voltage of up to the line-
to-Earth voltage with respect to the general mass of Earth. This risk can be reduced inside
buildings where main protective bonding is in place.
2.3.7  In  three-phase  circuits  and  systems  with  PEN  conductors,  the  PEN  conductor
downstream of the open-circuit PEN conductor is a neutral, and will assume a voltage
dependent  on  the  balance  of  loads  connected  downstream  of  the  open-circuit  PEN
conductor, which appears as a touch-voltage with respect to the general mass of the
1987
Earth at exposed-conductive-parts  and, if applicable, bonded extraneous-conductive-
parts  downstream  of  the  open-circuit  PEN  conductor.  The  touch-voltage,  in  some
conditions,  can  exceed  the  line-to-Earth  voltage  with  respect  to  the  general  mass  of
Act
Earth, and in rare conditions could approach the line-to-line voltage.
2.3.8  The touch-voltages described in paragraphs 2.3.6 and 2.3.7 can be reduced, to an extent,
by:
(a)  Provision  of  earth  electrodes  with  very  low  values  earth  electrode  resistances,
connected to the PEN conductor downstream of the disconnection. The values of
earth electrode resistance that reduces the possible touch-voltages to a level that
might be considered generally safe in dry conditions depends on the connected load.
Based on calculations carried out for electric vehicle charging installations supplied
Information
by protective multiple earthing (PME) systems in the UK:
(i)
In single-phase systems, values of earth electrode resistance of less than 1 Ω
would be needed to maintain touch-voltages below 70 V AC for supplies up to
100 A.
(ii)
In  three-phase  systems  the  touch-voltage  developed  depends  on  phase
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unbalance. Similar values of earth electrode resistance would be required to
maintain touch-voltages below 70 V AC for supplies up to 100 A, unless phase
unbalance can be guaranteed to be better than 100 %, 60 %, 37 %.
the
(b)  Inside  buildings,  by  provision  of  main  protective  bonding,  although  note  that
conductive parts connected to the protective bonding, that are accessible outdoors,
will then be subject to a potentially dangerous touch-voltage.
under
2.3.9  In the case of a dangerous touch-voltage described in paragraphs 2.3.6 and 2.3.7, neither
overcurrent  protective  devices  nor  residual  current  devices  (RCDs)  will  operate  to
provide automatic disconnection of the touch-voltage.
2.4  Risks associated with switching a neutral conductor other than a PEN
conductor
2.4.1  Sub-clauses 2.3.2.1.2 (b)(ii),  2.3.2.1.2 (b)(iii)  and 2.3.2.1.2 (b)(iv) of  AS/NZS 3000:2018
[reference 2] relate to conditions that must be satisfied for switching a neutral conductor
Released
(other than a PEN conductor). These can be summarized as follows:
(a)  The neutral is not to be switched without also switching the associated active (line)
conductors.
(b)  When switching all live (active and neutral) conductors, the switching is to be
arranged so that either:
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(i)
all live (active and neutral) poles are linked so that all live contacts make and
break at substantially the same time; or
(ii)
all live (active and neutral) poles are linked so that the neutral contact does
not open before the active (line) contact(s), and the neutral contact does not
close after the active (line) contact(s).
2.4.2  In  single-phase  systems  and  circuits,  disconnecting  a  neutral  conductor  without
switching  the  associated  line  conductors  generally  disconnects  power  from  loads;
however, all live conductors downstream of the disconnected neutral conductor remain
live. This could post a shock risk to anyone maintaining the installation, including removal
of lamps at general lighting service points.
1987
2.4.3  In three-phase systems and circuits, disconnecting a neutral without also disconnecting
the active (line) conductors means that the neutral is ‘floating’ and will assume a voltage,
relative in the phasor world to the live conductors,  based on the balance of the loads
Act
downstream of the disconnected neutral. In this case, the voltage between any line and
neutral could attain a voltage of up to the line-to-line voltage, or in rare cases with non-
unity power factor, exceed the line-to-line voltage.
2.4.4  Undervoltage  is  often  experienced  by  equipment  in  general;  however,  due  to  the
magnitude of overvoltage experienced by single-phase equipment connected between a
line  and  neutral  downstream  of  the  switched  neutral,  serious  overvoltage  can  be
experienced. Overvoltage from broken neutrals in three-phase systems has been known
to not only damage equipment, but also lead to fire. The situation in a real open neutral
situation  is  often  exacerbated  by  the  fact  that,  as  modern  equipment  with  internal
Information
electronic and control circuitry becomes inoperative or is damaged by overvoltage, the
balance of loads is continually shifting.
2.4.5  Where the timing arrangements summarized in Paragraph 2.4.1(b) of this report are not
met, the neutral can be disconnected when the live conductors are connected. This can
lead to the risks described in Paragraphs 2.4.2 to 2.4.4 inclusive; however, in this case,
Official
the risk of fire resulting is generally less because of the short time involved. Damage to
equipment,  however,  can  still  result,  particularly  if  a  three-phase  circuit  is  being
switched.
the
2.5  Risks associated with switching an earthing conductor (protective
conductor) other than a PEN conductor
2.5.1  Clause  2.3.2.1.2  (c)  of  AS/NZS  3000  [reference 2]  effectively  prohibits  switching  or
under
disconnection of the earthing (protective) conductor. Risks associated with switching of
a PEN conductor are summarized in Section 2.3 of this report.
2.5.2  Switching earthing (protective) conductors without switching live conductors is generally
considered dangerous as it removes the protective provision of automatic disconnection
of supply, in a manner that, if a fault were to occur, exposed-conductive-parts would
remain hazardous live.
2.5.3  In  many  installations,  protective  conductor  currents  result  from  electromagnetic
compatibility filters, and if the protective conductor is open-circuit, such currents can
Released
flow  to  Earth  through  someone  in  contact  with  exposed-conductive-parts.  If  the
protective conductor is interrupted to a number of items of equipment, or a number of
circuits, that remain live, the sum of protective conductor currents can, on their own, be
lethal with no electrical fault, unless the protective conductor remains continuous.
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2.5.4  There is concern regarding switching of protective conductors (other than through the
removal and reinsertion of a multi-pole plug and socket-outlet), that if a switching device
has a protective conductor contact, this can, over time, fail. A user may be unaware of
the damage, leading to permanent disconnection of the earthing (protective) conductor.
Such risks can be alleviated by only permitting switching of the protective conductor by
dedicated equipment to an appropriate product standard that includes durability tests,
and/or  where  there  is  monitoring  of  the  earthing  system  through  the  protective
conductor.
2.6  Summary of potential risks associated with the removal of Clauses
2.3.2.1.2 (b) and (c) from AS/NZS 3000:2018
1987
2.6.1  See Table 2.1.
Table 2.1 Potential risks associated with the removal of Clauses 2.3.2.1.2 (b) and (c) from Act
AS/NZS 3000:2018
Removal of
Potential hazard
Cause
For hazard detail,
provision in
see Paragraph
AS/NZS 3000
2.3.2.1.2 (b)(i)
Possible electric
•  Hazardous touch-voltages
2.3.2, 2.3.3, 2.3.6,
and
shock or secondary
between simultaneously-
2.3.7, 2.3.8, 2.3.9
2.3.2.1.2 (c)
effects
accessible exposed-
conductive-parts connected to
different earthing systems (IEC
Information
60364-4-41, Clause 411.3.1.1)
2.3.2.1.2 (b)(i)
Possible electric
•  Change of earthing resistances  2.3.4
and
shock or secondary
in ‘global earthing’ system.
2.3.2.1.2 (c)
effects.
•  Hazardous touch-voltages
between simultaneously
accessible exposed-
conductive-parts connected to
Official
different earthing systems (IEC
60364-4-41, Clause 411.3.1.1)
2.3.2.1.2 (b)
Possible electric
•  Failure to disconnect live
2.4.2, 2.4.3, 2.4.5
the
shock or secondary
conductors on operation of
effects during
devices that ought to provide
maintenance
safe disconnection/isolation
2.3.2.1.2 (b)(ii),
Possible damage to
•  Disconnected neutral in a
2.4.4, 2.4.5
2.3.2.1.2 (b)(iii)
equipment
three-phase system or circuit
under
and 2.3.2.1.2
when active (line) conductors
(b)(iv)
remain connected.
2.3.2.1.2 (b)(ii),
Possible fire/burns
•  Disconnected neutral in a
2.4.4, 2.4.5
2.3.2.1.2 (b)(iii)
three-phase system or circuit
and 2.3.2.1.2
when active (line) conductors
(b)(iv)
remain connected.
2.3.2.1.2 (c)
Possible electric
•  Disconnected protective
2.5.2
shock or secondary
conductor and high protective
effects.
conductor currents.
Released
2.3.2.1.2 (c)
Possible electric
•  Disconnected protective
2.5.3, 2.5.4
shock or secondary
conductor and electrical fault
effects.
that would normally conclude
with automatic disconnection
of supply.

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3  Existing mitigation in place for the risks outlined in Section 2 of this
report
3.1  Introduction
3.1.1  During my investigation, there was evidence that specific risks summarized in Section 2
of this report are mitigated, at least in part, by other provisions already in place.
3.1.2  The mitigation and residual risk are summarized in Table 3.1.

1987
Act
Information
Official
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Table 3.1 Potential mitigation already in place of risks associated with the removal of Clauses 2.3.2.1.2 (b) and (c) from AS/NZS 3000:2018
1987
Removal of
Potential
Cause
For hazard
Mitigations already in place
Residual risk actions
provision in
hazard
detail, see
AS/NZS 3000
Paragraph
Act
2.3.2.1.2
Possible
•  Hazardous touch-
2.3.2, 2.3.3,
Installing this type of switching is highly  1.  Switching of PEN conductors
(b)(i) and
electric
voltages between
2.3.6, 2.3.7,
likely to involve licensed
appears to be permissible.
2.3.2.1.2 (c)
shock or
simultaneously-
2.3.8, 2.3.9
workers/inspectors.
Guidance or standards are
secondary
accessible exposed-
necessary to prevent switching of
effects
conductive-parts
PEN conductors.
connected to different
2.  It is advisable, for the
earthing systems (IEC
implementation of island mode
60364-4-41, Clause
switching, to prohibit MEN/PEN
411.3.1.1)
conductors in parts of electrical
installations that are to be
islanded.
Information
2.3.2.1.2
Possible
•  Change of earthing
2.3.4
Installing this type of switching is highly  3.  Standard arrangements for
(b)(i) and
electric
resistances in ‘global
likely to involve licensed
automatic switching of island
2.3.2.1.2 (c)
shock or
earthing’ system.
workers/inspectors.
mode are yet to be addressed.
secondary
•  Hazardous touch-

effects.
voltages between
4.  In a global market, not all
simultaneously
products meet every country’s
Official
accessible exposed-
national requirements, and
conductive-parts
without industry guidance, other
connected to different
countries have found particular
the
earthing systems (IEC
safety issues associated with
60364-4-41, Clause
islanding.
411.3.1.1)
under
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Removal of
Potential
Cause
For hazard
Mitigations already in place
Residual risk actions
provision in
hazard
detail, see
1987
AS/NZS 3000
Paragraph
2.3.2.1.2
Possible
•  Disconnected neutral
2.4.4, 2.4.5
Installing this type of switching is highly
(b)(ii),
damage to
in a three-phase
likely to involve licensed
Act
2.3.2.1.2
equipment
system or circuit when
workers/inspectors.
(b)(iii) and
active (line) conductors

2.3.2.1.2
remain connected.
Product standards, such as IEC 60947
(b)(iv)
series, IEC 60947-6-1 and IEC 60669
series, contain requirements that
5.  Standards or guidance for other
mimic AS/NZS 3000 Clause 2.3.2.1.2
products and installation
(b)(ii) and (iii)
arrangements, to replace the
2.3.2.1.2
Possible
•  Disconnected neutral
2.4.4, 2.4.5
Installing this type of switching is highly
provision of AS/NZS 3000 Clause
(b)(ii),
fire/burns
in a three-phase
likely to involve licensed
2.3.2.1.2 (b)(ii) and (iii) is
2.3.2.1.2
system or circuit when
workers/inspectors.
necessary.
(b)(iii) and
Information
active (line) conductors

2.3.2.1.2
remain connected.
Product standards, such as IEC 60947
(b)(iv)
series, IEC 60947-6-1 and IEC 60669
series, contain requirements that
mimic AS/NZS 3000 Clause 2.3.2.1.2
(b)(ii) and (iii)
2.3.2.1.2 (c)
Possible
•  Disconnected
2.5.2
Installing this type of switching is highly
Official
electric
protective conductor
likely to involve licensed
shock or
and high protective
workers/inspectors.
secondary
6.  Consider reinstating 2.3.2.1.2 (c),
conductor currents.

the
effects.
For non-automatic arrangements,
or implementing necessary
AS/NZS 4509.1 applies.
requirements similar to BS 7671
(see Appendix C, C5). This will
2.3.2.1.2 (c)
Possible
•  Disconnected
2.5.3, 2.5.4

permit the use of OPDDs as well
electric
protective conductor
as transfer switching that also
shock or
and electrical fault that
transfers the protective (earthing)
secondary
would normally
under
function between sources of
effects.
conclude with
supply.
automatic
disconnection of
supply.
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4  Conclusion
4.1  Changes to the Electricity (Safety) Regulations were necessary to safely implement
renewable technologies, and consider provisions for supply continuity under certain
circumstances.
4.2  The deletion of Clauses 2.3.2.1.2(b) and (c) from AS/NZS 3000:2018 (including
Amendments 1, 2 and 3) [reference 2] for New Zealand was the selected approach to
achieve the aim outlined in paragraph 4.1.
4.3  Table 3.1 outlines specific issues that result from the decision, some of which are
mitigated as identified in the table.
1987
4.4  The residual risks can be summarised as follows:
(a)  Switching of PEN conductors should be prohibited. The reintroduction of 2.3.2.1.2
(b)(i) should be considered, or addressed in subsequent guidance.
Act
(b)  It is recommended that the use of PEN conductors in parts of installations energized
in island mode is strongly discouraged.
(c)  Standards or guidance for manual or automatic island mode switching
arrangements should be provided.
(d)  Not all product standards include timing arrangements for switching neutral
conductors in conjunction with other live conductors. The reintroduction of
2.3.2.1.2 (b)(ii), 2.3.2.1.2 (b)(iii) should be considered, or addressed in subsequent
guidance and/or product standards.
Information

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Appendix A  References and related documents
No.  Reference*
1.  New Zealand Electricity (Safety) Amendment Regulations 2025, last accessed
18 February 2026 from:
https://www.legislation.govt.nz/regulation/public/2025/0225/latest/whole.html
2.  AS/NZS 3000:2018 (including Amendments 1, 2 and 3) Electrical installations “Wiring
Rules”
3.  Institution of Engineering and Technology Standard IET 01:2024 Open combined
protective and neutral (PEN) conductor detection devices (OPDDs) (IET, London,
ISBN 978-1-83953-885-8)
4.  WorkSafe New Zealand Technical Bulletin Connecting a generator to the wiring of a  1987
house or building following an emergency, last accessed 18 February 2026 from:
https://www.worksafe.govt.nz/dmsdocument/57543-technical-bulletin-connecting-a-
generator-to-the-wiring-of-a-house-or-building-following-an-emergency/latest/  Act
5.  AS/NZS 4509.1:2009 stand-alone power systems part 1: Safety and installation
6.  BS 7671:2018+A2:2022+ A3:2024 Requirements for Electrical Installations. IET Wiring
Regulations Eighteenth Edition
7.  BS EN 60947-6-1:2005+A1:2014 Low-voltage switchgear and controlgear – Part 6-1:
Multiple functional equipment – Transfer switching equipment
8.  BS EN IEC 60947-6-1:2023 Low-voltage switchgear and controlgear – Part 6-1:
Multiple functional equipment – Transfer switching equipment
9.  BS EN 60947-1:2007+A2:2014 Low-voltage switchgear and controlgear – Part 1:
General rules
Information
10. BS EN 60947-1:2021 Low-voltage switchgear and controlgear – Part 1: General rules
11. IEC 60364-5-53:2015 (HD 60364-5-57:2017) Electrical installations of buildings –
Part 5-53: Selection and erection of electrical equipment – Isolation, switching and
control
12. Institution of Electrical Engineers General Rules Recommended for Wiring of the
Supply of Electrical Energy, Fourth Edition, 1903
Official
13. Institution of Electrical Engineers Wiring Rules, Seventh Edition 1916
14. Institution of Electrical Engineers Regulations for the Electrical Equipment of
Buildings, Fourteenth Edition 1966
the
15.  linked switch. (n.d.) McGraw-Hill Dictionary of Architecture and Construction. (2003).
Retrieved 17 February 2026 from
https://encyclopedia2.thefreedictionary.com/linked+switch
16. BIPM The International System of Units (SI) 9th Edition 2019 (updated to 2024)
under
17. NIST Special Publication 811 Guide to the International System of Units (SI)
18. NIST Technical Note 1297 Guidelines for Evaluating and Expressing the Uncertainty of
NIST Measurement Results 1994 Edition

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* References which are without a date or revision / version are intended to refer the reader to the latest revision / version.
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Appendix B  Abbreviations and specialist terms
Abbreviations for SI Units, SI Derived Units, and related Non-SI Units are not listed here due to
their widespread use and standard application. Details of these units can be found in
references 16 and 17.
Term
Meaning
AC
Alternating current
Note:  ‘a.c.’ is used in AS/NZS 3000, and in older IEC, CENELEC and British standards. In
the text of this Report, ‘AC’ is used, following current IEC usage, unless quoting
such standards directly.
AS/NZS
Australian Standard/New Zealand Standard (National Standards jointly published by
1987
Standards Australia and Standards New Zealand)
BIPM
Bureau International des Poids et Mesures
(International Bureau of Weights and Measures)
BS
British Standard (UK National Standards)
Act
DC
Direct current
Note:  ‘d.c.’ is used in AS/NZS 3000, and in older IEC, CENELEC and British standards. In
the text of this Report, ‘DC’ is used, following current IEC usage, unless quoting
such standards directly.
EN
Euro-Norm (European Union Regional Standard Standard)
IEC
International Electrotechnical Commission
IET
Institution of Engineering and Technology (formerly the IEE)
IEE
Institution of Electrical Engineers
MEN
Multiple Earthed Neutral
ISO
International Organisation for Standardisation
Information
NIST
National Institute of Standards and Technology (United States of America)
PEN
Protective earth and neutral (combined)
SI
Système Internationale (International System of Units)
UK
United Kingdom

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Appendix C  Provisions for and prohibitions on switching protective, neutral
and PEN conductors in BS 7671
C1  General
C1-1  The  current  national  electrical  installation  standard  in  the  United  Kingdom  is
BS 7671:2018+A2:2022+A3:2024 [reference 6].
C2  Supply transfer arrangements
C2-1  The selection of switching and earthing arrangements for supply changeover, whether
automatic  or  manual,  is  specifically  covered  by  Regulation  537.1.5  of  BS  7671
[reference 6] which has the following provisions:
1987
537.1.5 Where an installation is supplied from more than one source of energy, one of which requires
a  means  of  earthing  independent  of  the  means  of  earthing of  other  sources  and  it  is  necessary  to
provide that not more than one means of earthing is applied at any time, a switching device may be
Act
inserted in the  connection between the  neutral point and the  means of earthing, provided that  the
device is:
(i) a multipole, linked switching device arranged to disconnect and connect the earthing conductor
for the appropriate source at substantially the same time as the related live conductors, or
(ii) a switching device interlocked with a multipole, linked switching device inserted in the related
live conductors such that the earthing conductor for the appropriate source shall not be interrupted
before the related live conductors and shall be re-established not later than when the live conductors
are reconnected.
Information
Switching devices provided in accordance with (i) and (ii) shall meet the requirements of Chapter 46
for a device for isolation.
C3  Switching of the neutral conductor
C3-1  Regulation 132.14.2 is a general requirement of BS 7671 [reference 6] and contains the
provision that only linked switches or circuit-breakers, either of which also breaks the
Official
line conductors, may be used in the neutral conductor:
132.14.2 No switch or circuit-breaker, except where linked, or fuse, shall be inserted in an earthed
the
neutral conductor. Any linked switch or linked circuit-breaker inserted in an earthed neutral conductor
shall be arranged to break all the related line conductors.
C4  Prohibition on switching a PEN conductor
C4-1  BS  7671  [reference 6]  does  not  permit  switching  of  a  PEN  conductor,  see  Regulation
411.4.3:  under
411.4.3 In a fixed installation, a single conductor may serve both as a protective conductor and as a
neutral conductor (PEN conductor) provided that the requirements of Regulation 543.4 are satisfied.
No switching or isolating device shall be inserted in the PEN conductor.
NOTE:  Regulation 8(4) of the Electricity Safety, Quality and Continuity Regulations prohibits the
use of PEN conductors in consumers’ installations.
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C5  Prohibition on forming a PEN conductor from separate neutral and protective
conductors
C5-1  BS 7671 [reference 6] does not permit the recombining of separate neutral and protective
conductors to re-establish a PEN conductor, see Regulation 543.4.3:
543.4.3 If, from any point of the installation, the neutral and protective functions are provided by
separate conductors, those conductors shall not then be reconnected together beyond that point. At
the point of separation, separate terminals or bars shall be provided for the protective and neutral
conductors. The PEN conductor shall be connected to the terminals or bar intended for the protective
earthing conductor and the neutral conductor. The conductance of the terminal link or bar shall be not
less than that specified in Regulation 543.4.5.
1987
C6  Switching of the protective conductor (other than a PEN conductor)
C6-1  Regulation 543.3.3.101 of BS 7671 [reference 6] contains the following provisions:
Act
543.3.3.101 No switching device shall be inserted in a protective conductor, except:
(i) as permitted by Regulation 537.1.5
(ii) a multipole, linked switching device in which the protective conductor circuit is not interrupted
before  the  live  conductors  and  is  re-established  not  later  than  when  the  live  conductors  are
reconnected
(iii)  a  switching  device  interlocked  with  a  multipole,  linked  switching  device  inserted  in  the  live
conductors  such  that  the  protective  conductor  circuit  shall  not  be  interrupted  before  the  live
conductors and shall be re-established not later than when the live conductors are reconnected, or
Information
(iv) a multipole plug-in device in which the protective conductor circuit shall not be interrupted before
the live conductors and shall be re-established not later than when the live conductors are reconnected.
Switching devices provided in accordance with (i), (ii), (iii) and (iv) shall meet the requirements of
Chapter 46 and Section 537 for a device for isolation.
Official
Joints  for  test  purposes  that  can  be  disconnected  only  by  the  use  of  a  tool  may  be  inserted  in  a
protective conductor.
C6-2  Switching of a protective conductor (including an earthing conductor) is by a single-pole
the
switching device inserted in the conductor, interlocked with a multipole linked switch
that operates to disconnect live conductors, is therefore clearly permitted by  BS 7671
[reference 6], using the options in:
(a)  indent (i) to Regulation 534.3.3.101, via the option in indent (ii) to Regulation 537.1.3;
under
or
(b)  indent (iii) to Regulation 534.3.3.101.
C7  Meaning of the term ‘linked switch’ in BS 7671
C7-1  The  term  linked  switch  has  been  used  in  BS  7671,  and  the  predecessor  UK  industry
standard commonly known as the ‘IEE Wiring Regulations’, published by the Institution
of Electrical Engineers (IEE) for a period exceeding 120 years. A definition for the term
first  appeared  in  Regulation  100  of  the  Fourth  Edition  of  the  IEE  Wiring  Regulations
Released
[reference 12] which was published in 1903:
100.  Linked  switches.–  Linked  switches  are  single-pole  switches  fixed  on  conductors  of  different
polarity linked together mechanically so as to operate simultaneously.
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C7-2  The definition cited in paragraph C7-1 remained in use in subsequent Editions of the IEE
Wiring Regulations, from the Fourth to the Sixth, until the Seventh Edition [reference 13]
was published in 1916, which contained the following definition introducing a ‘definite
sequence’ of operation:
Switch, linked. A switch the blades of which are so linked mechanically as to make or break all poles
simultaneously or in a definite sequence.
The definition remained unchanged until the Fourteenth Edition [reference 14] published
in 1966 (see paragraph C7-3).
C7-3  The current definition in Part 2 of BS 7671:2018+A2:2022+A3:2024 [reference 6] is:  1987
Switch,  linked.  A  switch  the  contacts  of  which  are  so  arranged  as  to  make  or  break  all  poles
simultaneously or in a definite sequence.
Act
This  definition  has  not  changed  since  the  Fourteenth  Edition  of  the  IEE  Wiring
Regulations, first published in 1966 [reference 14].
C7-4  There is no definitive statement in the current edition of BS 7671 [reference 6] that the
poles of a ‘linked switch’ are required to be mechanically linked; however the following
ought to be considered:
(a)  It  is  generally  considered  in  the  industry  that  the  term  ‘linked  switch’  refers  to  a
multipole switch in which the linkages are mechanical in nature. For example, the
McGraw-Hill Dictionary of Architecture and Construction [reference 15] defines the
Information
term ‘linked switch’ as:
Two or more electric switches which are mechanically connected by operating arms or levers, so as
to operate at the same time or in a desired sequence;
and
(b)  BS 7671 [reference 6] uses the term ‘interlocked’ in relation to electrical linking in
Official
indent (ii) of Regulation 537.1.5, and indent (iii) of Regulation 543.3.3.101;
and
the
(c)  BS  7671  [reference 6]  implements  the  technical  intent  of  the  HD  60364  series
published by CENELEC, as listed in the Preface. The facts regarding the technical
intent  in  respect  of  multipole  switching  devices  being  required  be  mechanically
linked are presented in Appendix D, D7 of this report.
under
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Appendix D  Provisions for and prohibitions on switching protective, neutral
and PEN conductors in IEC 60364 series
D1  General
D1-1  Relationship with AS/NZS 3000
D1-1-1
The preface to AS/NZS 3000:2018 [reference 2] states that one of the objectives of
the revision from AS/NZS 3000:2007 was to ‘maintain alignment with IEC 60364, Low
voltage electrical installations (series)’.
D1-2  Relationship with BS 7671
D1-2-1
BS 7671:2018+A2:2022+ A3:2024 [reference 6] implements the technical intent of 1987
CENELEC harmonized documents (HDs) as shown in the Preface to the standard.
HD 60364 series implements IEC 60364 series in CENELEC.
Act
D2  Supply transfer arrangements
D2-1  IEC 60364 series appears to leave supply transfer switching to IEC 60947-6-1. It is not
clear what conditions pertain when switching between supplies that have different, and
separate, earthing arrangements.
D2-2  IEC 60364-1:2025 defines a ‘system referencing conductor’ to enable earthing of a live
conductor to be established, preventing the need to switch a protective conductor, see
Clause 1.8.4:
1.8.4 System-referencing-conductors
Information
A  system-referencing-conductor  (SRC)  is  a  conductor  between  a  live  part  and  an  earthing
arrangement, enabling the live part to be substantially at the potential of the earthing arrangement.
The SRC is neither a neutral conductor nor a protective conductor.
NOTE The application of SRC, shown in Figure 9, Figure 10, Figure 11, Figure 12 and Figure 13, is
given to help define the characteristic behaviour of the electric systems.
Official
D3  Switching of the neutral conductor
D3-1  Clause  530.3.2  of  IEC  60364-5-53:2015  prohibits  switching  of  the  neutral  conductor
unless the associated line (active) conductors are also switched:
the
530.3.2    Except  as  provided  in  536.2.2.7,  in  multiphase  circuits,  single-pole  devices  shall  not  be
inserted in the neutral conductor.
In single-phase circuits single-pole devices shall not be inserted in the neutral conductor, unless a
residual current device complying with the rules of 413.1 of IEC 60364-4-41 is provided on the supply
under
side.
D4  Prohibition on switching a PEN conductor
D4-1  IEC 60364-4-41:2005+A1:2017 does not permit the switching of a PEN conductor, see
Clause 411.4.3:
411.4.3 In fixed installations, a single conductor may serve both as a protective conductor and as a
neutral conductor (PEN conductor) provided that the requirements of 543.4 of IEC 60364-5-54 are
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satisfied. No switching or isolating device shall be inserted in the PEN conductor.
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D5  Switching of the protective conductor (other than a PEN conductor)
D5-1  IEC  60364-5-54:2011+AMD1:2021  does  not  permit  the  switching  of  a  protective
conductor, see Clause 543.3.3.
NOTE:  Some countries, including the United Kingdom, permit switching of the
protective conductor under specified conditions.
543.3.3 No switching device shall be inserted in the protective conductor, but joints which can be
disconnected for test purposes by use of a tool may be provided.
D5-2  Similarly, IEC 60364-1, Clause 1.8.3, prohibits switching protective conductors:
1.8.3 Protective conductors
1987
1.8.3.1 General
Protective conductors are those conductors used for protective purposes. Protective conductors
Act
are classified into:
– protective earthing conductors;
– protective bonding conductors.
In a protective conductor the electrical continuity shall be maintained. Accordingly, no switching
device shall be inserted.
D5-3  A distinction that needs to be raised in respect of paragraph D5-2, is that switching of a
Information
protective  conductor  need  not  occur,  if  the  connection  of  a  live  conductor  of  the
installation to Earth is not classified as a protective conductor, and a the term system
referencing conductor is defined. See Section D2 of this Appendix.
D6  Prohibition on forming a PEN conductor from separate neutral and protective
conductors
Official
D6-1  IEC 60364-6-54:2011+AMD1:2021 does not permit the does not permit the recombining
of  separate  neutral  and  protective  conductors  to  re-establish  a  PEN  conductor,  see
Clause 543.4.3:
the
543.4.3 If, from any point of the installation, the neutral/mid-point/line and protective functions are
provided by separate conductors, it is not permitted to connect the neutral/mid-point/line conductor
to  any  other  earthed  part  of  the  installation.  However,  it  is  permitted  to  form  more  than  one
neutral/mid-point/line conductor and more than one protective conductor from the PEN, PEL or PEM
conductor respectively.
under
D7  Requirements for linked switching in IEC 60364-5-53:2015
D7-1  Section 530.3 contains the following provisions:
530.3 General and common requirements
This  part  of  IEC  60364  shall  provide  compliance  with  the  measures  of  protection  for  safety,  the
requirements  for  proper  functioning  for  intended  use  of  the  installation,  and  the  requirements
appropriate to the external influences foreseen. Every item of equipment shall be selected and erected
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so as to allow compliance with the rules stated in the following clauses of this part and the relevant
rules in other parts of this standard.
The requirements of this part are supplementary to the common rules given in IEC 60364-5-51.
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530.3.1 The moving contacts of all poles of multipole devices shall be so coupled mechanically that
they make and break substantially together, except that contacts solely intended for the neutral may
close before and open after the other contacts.
530.3.2 Except as provided in 536.2.2.7, in multiphase circuits, single-pole devices shall not be
inserted in the neutral conductor.
In single-phase circuits single-pole devices shall not be inserted in the neutral conductor, unless a
residual current device complying with the rules of 413.1 of IEC 60364-4-41 is provided on the supply
side.
530.3.3 Devices embodying more than one function shall comply with all the requirements of this
part appropriate to each separate function.
1987
Act
Information
Official
the
under
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Ref: GKT-GENC-REP-0004
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Appendix E  Provisions for switching the neutral conductor in relevant
product standards referenced in Schedule 4 to the Electrical
Safety (Amendment) Regulations 2025
E1  IEC 60947-1
E1-1  Clause  8.1.9  of  BS  EN  IEC  60947-1:2021  (IEC  60947-1:2020)  [reference 10]  has  the
following provisions in respect of the neutral pole:
8.1.9 Additional requirements for equipment provided with a neutral pole
When an equipment is provided with a pole intended only for connecting the neutral conductor, this
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pole shall be clearly identified to that effect by the letter "N" (see 8.1.8.4).
A switched neutral pole shall break not before and shall make not after the other poles.
Act
If a pole having an appropriate short-circuit breaking and making capacity (see 3.7.14 and 3.7.15) is
used as a neutral pole, then all poles, including the neutral pole, may operate substantially together.
The neutral pole may be fitted with an overcurrent release.
For equipment having a value of conventional thermal current (free air or enclosed, see 5.3.2.1 and
5.3.2.2) not exceeding 63 A, this value shall be identical for all poles.
For higher conventional thermal current values, the neutral pole may have a value of conventional
thermal  current  different  from  that  of  the  other  poles,  but  not  less  than  half  that  value  or  63  A,
whichever is the higher.
Information

E2  IEC 60947-6-1
E2-1  BS EN IEC 60947-6-1:2023 [reference 8] includes a clear, normative, requirement for the
live  conductor  poles  (lines  and  neutral)  of  multipole  transfer  switches  to  be
mechanically coupled
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8.1.5 Opening and closing of main contacts
the
The main moving contacts of all phase poles of the switching device of a multipole TSE shall be so
mechanically coupled that they make and break substantially together, whether operated manually,
remotely, or automatically.
The manual actuator of the TSE shall be insulated. The requirements of 8.1.5.1 of IEC 60947-1:2020
applies.  under
There shall be no path or opening which allows incandescent particles to be discharged from the area
of the manual operating means.
For TSE equipped with neutral poles, 8.1.9 of IEC 60947-1:2020 applies.
For any TSE with manual operating means intended for on-load use, opening and closing of the main
contacts shall be independent of the speed with which the manual operating means is operated.
If the manual means is intended only for off-load use with all sources de-energized and is so marked
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according to Table 2 item 1.3, this requirement does not apply.

Ref: GKT-GENC-REP-0004
© G Kenyon Technology Ltd 2026  Page 23
of 23
Rev: 01
Commercial in Confidence

Draft for Review