Tēnā koe Mark

Thank you for your Official Information Act request received by WorkSafe New Zealand on 1 April 2026.

We will respond to your request in accordance with the provisions of the Official Information Act as soon as reasonably practicable and not later than 20 working days.

If we need to extend this timeframe, we will let you know before that date with the reasons why.

Please contact [email address] if you have any questions.

Ngā mihi,

Ministerial Services
8 Willis Street
Wellington
W    worksafe.govt.nz

-----Original Message-----
From: Mark Harris <[FOI #34332 email]>
Sent: Wednesday, 1 April 2026 12:11 pm
To: Ministerial Services – WorkSafe <[email address]>
Subject: Official Information request - Benefits Sought From the Removal of PEN Conductor Protections from AS/NZS3000:2018

[You don't often get email from [FOI #34332 email]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentific... ]

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

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Kia ora Mark, 
 
Please see attached a extension to your Official Information Act request. 
 
Ministerial Services 
8 Willis Street 
Wellington 
W   [1]worksafe.govt.nz  
       
 

[2]www.govt.nz - your guide to finding and using New Zealand government
services

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Any opinions expressed in this message are not necessarily those of
WorkSafe New Zealand. This message and any files transmitted with it are
confidential and solely for the use of the intended recipient. If you are
not the intended recipient or the person responsible for delivery to the
intended recipient, be advised that you have received this message in
error and that any use is strictly prohibited. Please contact the sender
and delete the message and any attachment from your computer.

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