Test And Tag License Victoria Part 2
Since my article What is a Test and Tag License was published 28 July 2015, I have had a number of emails seeking clarification on who can and can’t test and tag appliances, particularly in 
Victoria where I operate.
I also continue to see a number of posts and articles that unfortunately have omissions, misinterpretations, misrepresentations or factual errors that result in misinformation and confusion.
There is also information that suggests any person who performs testing and tagging and is not a licensed electrician will face problems with their public liability and Workcover policies and any works they perform is invalid. Although this article relates mostly to Victoria, I have also included some information for other states and territories.
Let’s look at the facts:
The key standard used with testing and tagging in Australia is AS/NZS 3760. It defines the who, what, when, where, why and how on testing and tagging.
It also defines the minimum requirement for who can test and tag. It is made up of three core elements;
Clause 2.2 The inspection and testing tasks specified in this Standard shall be carried out by a competent person.
The definition of a competent person is;
Clause 1.4.4 A competent person is one who the responsible person ensures has the necessary practical and theoretical skills, acquired through training, qualification, experience or a combination of these, to correctly undertake the required tasks.
The definition of a responsible person is;
1.4.19 The responsible person shall be considered as: (a) The owner of the premises; or (b) The owner of the electrical equipment; or (c) A person who has a legal responsibility for the safety of electrical equipment within the scope of this Standard. Guidelines to assist a responsible
To go a little bit further, we need to look at the sub-points of Clause 1.4.4. There is one point in particular we need to be aware of;
Note – (1) A competent person is not required to be a registered or licensed electrical practitioner. Requirements for registration vary between jurisdictions.
Therefore as a broad rule-of-thumb or your starting point is you need to be a competent person.
What about Victoria?
Some time back I contacted WorkSafe Victoria and they confirmed they are satisfied if the person performing the testing and tagging is a competent person; they do not have any requirement for them to hold any other qualification or electrical license. I understand this is still the case.
Other States and Territories?
Our research indicates most States and Territories have the same requirements however there have been some changes. Click here for information about different requirements.
What about construction sites?
The Industry Standard – Industry Standard for Electrical Installations on Construction Sites – was published in March 2002. It contains this clause;
4.3 Testing of plant, portable electrical equipment and appliances, and flexible electrical cords. … Inspection and testing should be undertaken by a licensed electrician or electrician supervised (ES or L) prior to its first use, and every 3 calendar months thereafter, while being used on the site.
Some confusion related to the use of the word “should”. Within the context of this document and AS/NZS 3760 the word “should” has a very different meaning to “shall”.
- Should indicate a statement is preferred as indicating good practice but is not mandatory.
- Shall indicates a statement is mandatory to achieve compliance with this Standard.
In this context it means on construction sites it is not compulsory for the person performing the testing and tagging to be a licensed electrician, they can be a competent person and still comply with this Industry Standard. Keep in mind that even if the person is a licensed electrician/practitioner, they must still meet the requirements of a competent person.
Edition 3, January 2011 has since been released and provides greater clarity on this requirement;
4.4 Inspection and testing of plant, appliances and flexible extension cords Plant must be inspected before it is used for the first time and tested every three months for earth continuity, and insulation resistance in accordance with AS/NZS 3760 In-service safety inspection and testing of electrical equipment. Inspection and testing to be undertaken by a: a) licensed electrician, or b) licensed electrical inspector, or c) person who has successfully completed a structured training course and been deemed competent in the use of a pass-fail type portable appliance tester and the visual inspection of electrical equipment. (Refer to Appendix C).
This makes it much clearer on who can test and tag appliances on construction sites in Victoria and the use of a competent person is allowed. Which of these three options they decide to allow or not allow is entirely up to the individual sites to determine.
My experience
I have been doing testing and tagging for over 13 years and I have never heard of any testing and tagging service provider having issues relating to public liability or Workcover policies (in Victoria) due to not being a licensed electrician.
Similarly I have not heard of any verified cases of Worksafe (Vic) failing to recognise testing and tagging performed by a person because they are not a licensed electrician, even on construction and demolition sites.
So for the time being we can dismiss the issue of non-compliance with each of these as false information.
What I am aware of is some construction sites still having the requirement for appliances to only be tested and tagged by a licensed electrician. Generally the bigger the site or the more unionised it is, the more likely this will be the case. Again, it is up to the individual sites to set their requirements, so if that is their requirement, then that is how it is.
In summary;
- To test and tag appliances you must be a competent person
- Some sites may require it only be performed by a licensed electrician
- Requirements do vary between jurisdictions
- Requirements do vary between workplaces
More info
Purchase a copy of AS/NZS 3760 – SaiGlobal or Standards New Zealand
Download a copy of The Industry Standard for Electrical Installations on Construction Sites (Edition 3, January 2011)
An earlier post about Who Can Test and Tag Electrical Appliances
Want to learn how to correctly test and tag electrical appliance – register for a TATSA test and tag course today.
Updated 13/11/2020
