THE PRINCIPLES AND PRACTICES OF POTENTIALLY ‘BULLETPROOF’ COC DOCUMENTATION

By Anthony Schewitz, ECA Technical Adviser

All too often in our industry, we see contractors issue the bare minimum required when it comes to Certificates of Compliance (CoCs). With the recent revisions to the test report in Edition 3 it is has become crucial for every contractor to understand what documentation and other useful information must be attached to the CoC. Typically, disputes and complaints can be avoided when the documentation and labelling is correct – and, more often than not, it’s better to not only cover the legal requirements but to go the extra mile because, in the long run, it can cover your back …

Normal documentation

When issuing a CoC many contractors have an attitude of ‘it’s just the yellow form then I’m done’ when in reality, it’s so much more than that.

In the updates in SANS 10142-1 Edition 3 in 2020, there are a few notable changes on each document, and comments commonly heard are, for example: “where do we fill in sub distribution boards?” and ‘this seems like much more work than before even though the documentation is easier to complete!”  Clause 8.6.1 in SANS 10142-1 Edition 3 now makes it clear that attaching documents is a required norm.

In Edition 2, the requirements were to only document the worst case in the test report:

8.6.1 General
For cases where multiple tests are required, record the worst-case measurement on the test report.

This was changed in Edition 3 to make sure that all readings are recorded on additional documents:

8.6.1 General
For cases where multiple tests are required, such as earth resistances, protection device ratings, insulation resistances etc, record all those applicable to the installation under test and attach them to the test report.

This means that in almost all cases, you would need to attach a document in one form or another to record these tests, unless you can fit them in the comments or by other means.

So, what can you add to your CoC? Almost anything! In addition to the examples below, there are other options, which may have more relevance in the various sectors of the electrical contracting industry, such as type testing certificates for assemblies and inspection schedules in specialised environments.

Master Installation Electricians are already well-versed when it comes to attaching documents specific to their field with the test report for hazardous locations calling for documents such as Material Safety Data Sheets, Zoning Certificates, IA Certificates and drawings.

What are some common examples of documents that are recommended?

The following documents are recommendations to assist the contractor and is by no means a compulsory list. The requirements that are compulsory are listed in Section 8 of SANS 10142-1 and the Electrical Installation Regulations.

Additional test reports

These come in many standardised forms, which are included in various standards including SANS 10313, which has the Lightning Protection Safety Report; SANS 10142-2 has the Medium Voltage Installation Safety Report, all these forms should be attached to the CoC to cover your installation and ensure that everything has been tested. When dealing with sub-distribution boards, the new layout of the test report intends that a test sheet is issued for each distribution board. These additional reports assist in capturing every detail of the installation, as and when required.

Declaration of Responsibility

As most contractors who have used the new test reports would have noticed, 5.1 to 5.3 have been removed from the test report altogether leaving 5.4 as the new 5, which is the registered person’s responsibility to test and inspect the installation according to the requirements. Annexure 1 states that the CoC requires the following from the Registered Person: I declare that the persons responsible for the design, specification, procurement, construction, commissioning and inspection and test have completed the relevant sections of the test report.’

According to section 10(4) of the Occupational Health and Safety Act of 1993, in order to transfer responsibility, one needs to do so in writing and the person who is going to take liability would agree to take the steps required to ensure safety.

To attach delegations in the same order described in clauses 5.1 to 5.3 of the old test report, you could either user similar wording as in the old clauses (which the respective party would sign) or you could attach the limitations of the person’s responsibility (i.e. the design with a declaration that they accept). Generally, engineers sign an agreement when they design an installation with the client, and this would also fall under this delegation and satisfy the requirements in the Certificate of Compliance. Please note that this is merely a simple guide and there may be other ways of doing this.

Inspection report

Many larger companies have a standard operating procedure or inspection document that assists them in keeping set standards (effectively a standardised sheet of checks and balances) and, with that linked to the information and requirements specific to the CoC, it shows all the results documented at the time of testing and assists in the ‘safe’ declaration.

Line diagrams

These are some of the easiest documents to attach and they certainly add immense value as they identify each part and component. Line drawings can be anything from a rudimentary drawing of an uncomplicated system or alternatively using one of the readily available freeware programs to paid apps such as the AUTOCAD Electrical Diagrams app.

Maintenance sheet

Surprisingly, although this is similar to the ‘additional comments’ section and simple to carry out, it’s not often done. This is where the contractor can include a list of items in the installation that may require maintenance. For example, if the markings on a switch are faded and although not a safety issue, it may be complained about at a later stage. It’s always better to make the user aware of such issues rather than leave such items unmentioned and take the fall later.

Additional tests

In certain installations it may be required to attach additional tests, for example, in telecommunication installations, there may be a DC installation that would have to be tested and those values, which are specific to that environment, would have to be documented. Another example is the DC portion of PV installations.

Quotations

Attaching the quotation indicates exactly what work was carried out by the contractor and is helpful when separating existing and altered work as each has its own requirements when it comes to issuing a CoC, so the quotation adds more proof about the work that was undertaken.

Photo sheets

There is a saying “every picture tells a thousand words” and photos of the work that illustrate the installation characteristics and or the relative conformative nature of the installation at the time of completion and that are attached to the CoC, will prevent a situation where a contractor is held accountable for any subsequent work he did not do.

Manufacturer’s specifications

If you’ve installed prepopulated distribution boards or control panels that came with test certificates, SABS certificates or Letters of Authority, these should be attached to prove the application and installation of these components has been done correctly and according to the manufacturer’s requirements.

Layouts

Layouts are typically used for extensive renovations and building sites where architects are involved and assist with the description of work carried out as well as indicating who carried out the design work of the installation. This helps to document the work done and prove you have gone through the installation with pinpoint accuracy. A layout can simplify inspections by listing where there may be maintenance items, identifying specific points, and indicating isolation points, while adding substance to the documented counts of circuits and points of consumption in section 3. A layout can back up readings by linking readings obtained to the actual appliance or device tested. Remember nothing fancy is required so even a hand drawn layout would suffice, although a digital one looks so much more professional.

Clarifications and/or comments

Basic storytelling can also be helpful especially when there are contentious issues such as the location of isolators. Sometimes it is best to write them down, documenting where you have noted any anomalies and stating that “according to x and y in the standard, the installation is, in fact, reasonably safe”.

Usually, issues like this are noted in the comments section of the test report, but we all know the allocated space is very small and is not adequate when there is a lot to make note of. A good example of this would be the location of a gate motor disconnector when it is not in its conventional “within arm’s reach/within 1.5 m of the device”. Then it should be noted and stated that according to 6.16.5.1.4, it satisfies the requirement.

Conclusion

The documents you attach do not have to be complicated to make an impression or get the message across. They must capture the details of and simply tell a story about the installation so that if you end up in a court of law, you will be able prove you went the extra mile and you will have ‘fire power’. This is why, when issuing CoCs, it’s best to imagine the worst-case scenario and to remember that the more documentation you have the better.

The above list is by no means exhaustive and more can be added – and it is always recommended that you have systems in place to back up your certificate so it’s a good idea to scan or take photos of all the documentation that you add to a CoC so that you have digital proof and keep files like these in the cloud, like a drive that you can access even if your office goes up in flames.

Samples of many of these documents are available at ECA offices and are freely available to members seeking guidance or assistance.

The ECA holds a CoC Refresher course and an Edition 3 Updates course for members and non-members and, for more information, contact your nearest ECA office.

To download this article that appeared in the July-August issue of SA Electrical Contractor click on this link and select the download button.

More info:           Anthony Schewitz on (010) 271 0686

Email:                    anthony@ecasa.co.za

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