Issues have been raised by operators in the aged care sector around the provisions of Regulation 26 of the Electricity (Safety) Regulations (ESRs) as it applies to their equipment. We have clarified the issue here.


WorkSafe provides this guidance in response to requests from the Aged Care sector for clarification around the provisions of Regulation 26 of the Electricity (Safety) Regulations (ESRs) as it applies to equipment located in aged care units and similar facilities. The specific issue is related to equipment principally for the use of patrons, but may be provided by the owners of the facilities (including specifically electrically operated beds). It also relates to the use of RCD (30mA) protected supplies as an alternative to the “Test and Tag” regime of AS/NZS 3760 In-service safety inspection and testing of electrical equipment and the relevance of AS/NZS 3551 Management programmes for electrical equipment.

Clarification has been sought because there are significant cost implications, and different safety methodologies appear to be being promoted by those providing advice and services to the sector. It is also unclear as to what is strictly mandatory.


The Electrical (Safety) Regulations 2010 are structured principally around risk and the ability to control the electrical infrastructure in networks, consumer installations and electrical appliances. They provide guidance on how the safety of electrical appliances and equipment can be assessed using a recognised Standard (AS/NZS 3760), and recognise how safety in respect to electric shock can also be delivered using RCDs. These two alternatives are identified in Regulation 26.

Application of AS/NZS 3551

Testing to AS/NZS 3551 is neither relevant nor necessary in aged care facilities unless the equipment is part of a facility that is intended to be used for treatment that specifically requires “Body Protection” or “Cardiac Protection” from electric shock.

Energy Safety notes that it is acceptable to carry out monitoring and diagnostic measurements, and some forms of treatment, using BF and CF rated electrical medical equipment without requiring the location to be configured for BF or CF procedures, and to utilise portable medical rated (10 mA) RCDs for other treatment.

Application of the “Test and Tag” regime of AS/NZS 3760

While there are mandatory Regulatory provisions for the safe use of electricity, because AS/NZS 3760's test and tag regime is recognised by Regulation 26 as a safe method of achieving the general safety requirements for the use of plug-in appliances, in the Regulation’s risk based architecture, it's application is not mandatory, nor does the Standard represent a minimum benchmark by which an alternative safety methodology must be assessed.

The Regulations, through the citation of IEC 60479 – The effects of current on human beings and livestock – recognise that RCDs provide an acceptable methodology of providing protection against electric shock.

Therefore, in Aged Care facilities, the use of RCD protected supplies to provide an alternative to “Test and Tag”, where the RCDs are checked on a regular basis, is not necessarily inadequate for compliance with the Regulations.

The regular checks could be performed using the test feature of the RCD twice yearly at daylight saving adjustments where the disruptions of clocks, etc. would be minimised. An RCD that fails to trip when tested must be replaced.

Review of Regulations

It is expected that clarification of this aspect of safety in aged care and similar facilities will be considered during the next revision of the Regulations.