The ECA(SA) is also deeply concerned about the failure of the National Regulator for Compulsory Specifications (NRCS) to carry out its mandate of ensuring that all regulated electrical components comply with the relevant safety specifications, and to carry out market surveillance through inspections in order to monitor and enforce compliance. The ECA(SA) says that many non-compliant and potentially dangerous electrical components are getting into the SA market, placing electrical contractors, property owners and the public at risk.

"Unless the DoL and the NRCS take their duties seriously there will rapidly be a deterioration of standards, and the safety and welfare of people and properties will be compromised", said Engelbrecht.

On 4 March 2013 ECA(SA)'s national director, Chris Greager, addressed correspondence to the Chief Inspector at the DoL, Thobile Lamati, and two of his senior staff, requesting a meeting to discuss ten matters of concern to the electrical contracting industry. Despite reminders from the ECA(SA), to date the letter and request remain unanswered.

  

See also "Are Accredited Inspection Authorities toothless?" by Mark Botha, Vector, March 2013, page 3.

The ten issues put to the Department of Labour by the ECA(SA) were:

1. Lack of policing

There appears to be a total lack of policing in the industry, particularly with regard to unregistered electrical contractors, shoddy and dangerous workmanship, and the issuing of invalid electrical certificates of compliance / test reports by some electrical contractors. Many complaints about these issues have been sent to the DoL's Provincial Inspection and Enforcement Services offices for action, but it appears that in most instances nothing is done about them.

2. Correct complaint procedures

The ECA(SA) wishes to establish the correct procedures to be followed when it or members of the public wish to lodge complaints about dangerous or illegal electrical installations, unregistered electrical contractors, etc., in order to put a stop to dangerous installations and pirate electrical contractors.

3. Approved Inspection Authorities (AIAs)

The ECA(SA) requires clarification about Approved Inspection Authorities (AIAs), how many have been accredited by the South African National Accreditation System (SANAS), how many have been approved by the DoL in terms of regulation 3(1) of the Electrical Installation Regulations, and who they are. The ECA(SA) would like to work more closely with AIAs when dealing with complaints from users, but is only aware of two or three accredited AIAs in the whole of South Africa.
 
4. Procedures for AIAs
 
The ECA(SA) wishes to establish the correct procedures to be followed by AIAs, and to whom they are accountable. At a meeting on 6 October 2010 the ECA(SA) was informed that the DoL was preparing a manual setting out the duties, functions and responsibilities of AIAs, but to date this has not been received. Such document is considered essential to understand the role of AIAs and what they can and cannot do.

5. Limitations of AIAs

The ECA(SA) wishes to establish whether individual AIAs are limited by their status as "Registered Persons". For example, can an AIA with only a registered installation electrician in its employ inspect, test and pass comment upon installations in hazardous and/or explosive locations where only registered master installation electricians may carry out such work?

6. Registration of electrical contractors

On 1 September 2012 the DoL took over the annual registration of electrical contactors from the Electrical Contracting Board of South Africa (ECB) which had been carrying out this function on behalf of the Chief Inspector since 1993. Electrical contractors now complain about the current registration processs and registration delays which place them in contravention of regulation 6 of the Electrical Installation Regulations.

7. Assistance by the ECA(SA) with registration of electrical contractors

In order to assist in the registration process and reduce delays, the ECA(SA) has proposed entering into an agreement of co-operation with the DoL to use the Association's seven regional offices as "post offices" to accept electrical contractors' registration documentation and to submit this to the DoL's offices for their necessary attention. No response has been received from the DoL.

8. Access to the DoL database of registered electrical contractors

The ECA(SA) has requested access to the DoL database of registered electrical contractors as it receives many enquiries from municipalities, the National Bargaining Council for the Electrical Industry, estate agents and the general public asking whether electrical contractors are registered with the DoL, as required by legislation. In the past, the ECA(SA) was able to access this information and answer these queries, but can no longer do so, thus preventing the ECA(SA) and the public from establishing whether an electrical contractor is legitimate and properly registered to carry out electrical installation work on their properties.

9. Period of registration of electrical contractors

It appears that most of the DoL's provincial offices are allowing electrical contractors to register for three years at a time, and even for up to seven years in some instances, while regulation 6(2) of the Electrical Installation Regulations prescribes an "annual registration". The ECA(SA) asks what control the DoL has if the licensed electrician of a registered electrical contracting firm resigns, retires, emigrates or dies, in which case the contractor could then operate for years without a registered person in its full-time employ, without anyone being the wiser.

10. Certificates of Compliance for electric fences

Finally, the ECA(SA) expressed the need to discuss the new requirement in terms of regulation 12(4) of the Electrical Machinery Regulations (which came into effect on 1 October 2012), that the user or leassor of an electric fence shall have a certificate of compliance for a new fence, when any addition or alteration is effected to the fence, or when there is a change of ownership of the premises. Such certificate may only be issued by a person registered by the DoL as an "electric fence system installer". The ECA says its supports this requirement, but that training to undertake the necessary skills programme is not currently available countrywide.


The ECA(SA) says it needs answers and progress on all of the above issues. "Everyday electrical installation work is being carried out in thousands of South African homes, offices and factories, but little attention is being given to controlling illegal operators, or in taking action against those who perform dangerous and shoddy work and which is a threat to life and property".

Contact Chris Greager, National Director, ECA(SA)
Tel: 031 312-6313; Email: greager@ecasa.co.za