There is no such thing as annual PAT testing

Few pieces of folklore are as firmly held as the annual PAT test. Organisations budget for it, auditors ask for the certificate, and site inductions state it as law. It is not law. The phrase appears in no regulation.

What is required

Regulation 4(2) of the Electricity at Work Regulations 1989 requires that, as may be necessary to prevent danger, systems are maintained so as to prevent danger so far as is reasonably practicable. That is the whole of it. As HSE puts it, the regulations “do not specify what needs to be done, by whom or how frequently”.

There is no legal requirement to test annually. In many cases there is no requirement to test at all. There is no requirement to label equipment and none to keep records. HSE does say records and labels are useful management tools, which is a different statement from a legal duty, and the two get conflated constantly.

What replaces it

A risk-based maintenance regime with three levels. The famous one is the least important.

User checks. The person about to use the equipment looks at it. Frayed cable, cracked casing, scorch marks, a plug repaired with tape. This costs nothing and catches most faults. It is also the level almost every organisation neglects while paying for the third.

Formal visual inspection. Someone trained looks properly, including inside the plug where that applies. HSE is explicit that visual examination is essential “because some types of electrical safety defect can’t be detected by testing alone”. Read that twice if you have been buying testing on its own.

Combined inspection and testing. Instruments, used by someone trained to interpret what the instrument says. Necessary for some equipment in some environments. Not for everything, everywhere, every twelve months.

Frequency follows risk. What the equipment is, where it is used, how often it moves, how likely it is to be damaged. A 110V transformer dragged around a fabrication shop and a desk lamp in an office do not belong on the same schedule. Putting them there is how organisations spend real money on the lamp while the transformer waits eleven months.

Why it persists

A schedule is easier to buy than a judgement, and a sticker is easier to show an auditor than a maintenance regime. The annual test turns a duty that needs thought into a purchase order, and everyone involved is relieved.

It also discharges the duty only by accident. An organisation with a folder of current test certificates and no user-check habit has bought evidence of testing, not safe equipment. The two come apart at the moment they matter: a damaged lead in month three, on kit tested in month one that nobody will look at again until month thirteen.

What to do about it

Establish which of your equipment is portable and where it is used. Set intervals from that, in writing, with the reasoning recorded. The reasoning is what makes the regime defensible when somebody asks why the interval is what it is. Train users to check before use and give them somewhere to report what they find. Then buy the testing you need, which in most offices is a good deal less than is currently being bought, and in most workshops is targeted instead of universal.

HSE’s HSG107 sets out the approach in full. It is one of the more readable pieces of guidance, and it has been saying this since long before the sticker industry grew up around it.