Dear WorkSafe New Zealand,

CONTEXT:
WorkSafe has removed the prohibitions against PEN conductor switching through deletion of clauses 2.3.2.1.2 (b) and (c) from AS/NZS3000:2018.

International minimum practice prohibits switching of the PEN conductor (no other countries allow PEN conductor switching, and it is specifically prohibited in Australia, the UK and by the international IEC family of standards).

WorkSafe claims PEN conductor switching is needed for improved safety relating to:
* EV charger protections against the risk of PEN conductor failure.
* Connection of alternative supplies (eg generators) to installations.
* The introduction of new technologies.

New Zealand currently prohibits PEN conductor switching when connecting alternative supplies (eg generators) to installations in clause 7.3.8(a) of AS/NZS3000:2018.

OIA REQUEST:
1) What are the specific benefits/outcomes that can only be achieved by including PEN conductor switching?

2) Why can EV charger protections (ie O-PEN and OPDD), generator connections and inverters with import/export capability all be safely achieved overseas without PEN conductor switching, but cannot be achieved here in New Zealand? This will specific require technical explanations.

3) Specifically how does switching of the PEN conductor lead to safety improvements?

4) Did New Zealand's departure from international minimum practice in allowing PEN conductor switching (something that is prohibited in Australia, the UK and countries using the international IEC standards) trigger any due diligence/sanity checking by WorkSafe?

5) During drafting of its proposed update to the current guidance on connection of generators to installations to replace the current advice (https://www.worksafe.govt.nz/about-us/ne...) WorkSafe proposes PEN conductor switching. Is WorkSafe aware that their proposed is non-compliant? Was the draft proposal document peer reviewed?

Yours faithfully,

Mark Harris
NZEIA Vice President