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Overview of Step Licensing changes
On September 1st, 2023, the EWRB issued a Gazette notice outlining changes to come into effect for a raft of license classes, including endorsements for work in certain higher risk areas. These are scheduled to come into effect predominantly on September 1st, 2025
On 20th Feburary we met with the EWRB to discuss several key issues that will have direct impact on our members, the wider industry, and beyond, which warrant addressal.
This was a very productive meeting and the board listened to, and were very receptive to our concerns.
Going forward we will be contributing our efforts to help maintain the interests of industry, and electrical workers during this process.
We expect to see a raft of information in the coming months and we will be here to relay this information and advise on how we can all move forward, stay compliant, and safe.
It is imperative that we gather your insights and feedback on these proposed changes to ensure that they align with industry interests and safety standards.
Key issues and concerns.
Limited consultation process
The consultation process, as required by section 88 of the Electricity Act 1992 was primarily conducted through an online survey, potentially restricting the scope of feedback.
We are advised informally that the email went into junk or spam folders meaning that much of the industry did not respond.
We are also not aware of any consultation with industry organisations such as ourselves.
We believe that consultation was entirely inadequate considering the nature, and extensive content of the Gazette notice.
Implementation timeframe and no clear pathways
Information has not yet been provided outlining what pathways are available to show competency for the new endorsed license classes.
The only feasible options are either for recognition of industry-based qualification pertaining to the requisite license class, or an evidence/experience based route.
The new endorsed license classes commencement is scheduled for September 1st, 2025.
As far as we are aware there is currently little to no courses, or training programs available in New Zealand that would cover the specific requirements to show competency in any of the endorsed license classes.
Restriction on certification
Wording in the Gazette notice limits electrical workers to only certify their own work.
In respect of a certificate of compliance, this restriction does not currently exist, and with good reason. There exist many instances where it is more appropriate, or where certification needs to be, completed by someone else.
For example, an installation may be erected by several practitioners. Currently allowance is made for one person to certify that installation. Under new rules each practitioner will need to certify their own piece of work resulting in some cases many certificates being issued for the same installation. This becomes more complex given that it is common for multiple practitioners to work on the same part of an installation.
This also restricts a practitioner certifying prescribed electrical work performed by a trainee holding a limited certificate rendering them unable to complete any work given that trainees are not authorized to certify their own work.
Alteration to the ‘Associated trade person’ licence class
The alteration to the ‘Associated trade person’ license class raises significant concerns regarding the lack of restrictions associated with it. Under the current regulations, licensed plumbers or gas fitters are permitted to undertake prescribed electrical work, provided the electrical rating does not exceed 250 volts and 16 amperes.
While the new rules maintain these voltage and current limitations for plumbers and gas fitters working on appliances, they extend the scope and remove these limitations for both licenced plumbers and gas fitters, and licenced building practitioners working on installations.
This extension without proper restriction could potentially permit work on both single and multi-phase installations, without limitations on current or types of fittings. For instance, a licensed building practitioner might theoretically replace a mains entry box while conducting repairs to a soffit or disconnect and reconnect an entire switchboard while replacing a piece of interior lining. Such scenarios pose serious safety risks and underscore the need for stringent restrictions.
Limitations restricting ability for practitioner to gain endorsements.
Provision has not been made for those seeking endorsement in any of these license classes to work in those areas and gain necessary experience even under supervision.
Wording of the Gazette notice had put a hard limit in place preventing those without the requisite endorsement to perform prescribed electrical work in those areas.
Our proposed solutions and recommendations
During our meeting with the EWRB we proposed the following recommendations to address the identified issues
- That the EWRB enhances consultation efforts in future by engaging directly with industry and stakeholders to gather comprehensive feedback.
- That clear, and concise pathways are presented in a timely fashion. The EWRB has indicated that there will be a ‘grandfathering’ process to allow those who already work in areas affected by the notice to continue working. This must be carefully implemented to avoid misinterpretation or abuse.
- That more consideration be given to implementation timeframes given the complexity for training providers to develop and deliver courses.
- Removal of the restrictive changes being imposed on certification.
- Review and amendment of the changes to the associated tradesperson licence class.
Closing remarks and next steps
Following the consultation process, we will analyse the feedback received and work towards refining our advocacy efforts in response to the proposed ‘Step Licensing’ changes. Updates on next steps and outcomes will be communicated to stakeholders in due course. We will seek further meetings with them to provide more clarity and detail on our position to their gazetted changes, but this will rely heavily on the information we receive from each of you.
We extend our appreciation to all stakeholders for their participation and valuable input in this consultation process. Together, we can ensure that the interests and safety of industry professionals are upheld as we navigate these regulatory changes.