[AusNOG] Test and tag rules

[Glen Turner]

On 14/11/2011, at 2:02 PM, Rod wrote:

> I don’t think there is a requirement to test and tag in a data centre.

It depends upon the state. The norm is that new equipment in a data centre environment can be inspected, deemed to pass, and be tagged to expire in five years. Then five years later it has to be inspected, tested and tagged to expire in five years.

> The electrical safety regulations came about to protect the public and workers in a hostile environment (eg contruction sites) or users of portable equipment that may be subject to abuse/mistreatment (eg hire equipment). I do not believe a data centre fits the definition of a hostile environment.

A data centre is not a "hostile environment", but not all states exempt equipment outside of hostile environments for test and tag.

> And of course, check your insurance policy for references to test and tag. While you may not have a legal requirement to test and tag, your insurance policy may require it.

Insurance policies don't usually go to that level of detail. They prefer broad exemption terms like

WILFUL ACTS caused by, contributed to by or arising from any actual or alleged: ...(ii) wilful breach of any statute, contract or duty; or ... carried out by You or any person acting with Your knowledge, consent or connivance;

which could then be read to mean that your lack of adherence to the state's test and tag regulations removes your coverage when poor Fred Bloggs is electrocuted by that untagged flexible lead.

Here's the more in-depth answer I sent directly. Since there seems to be some interest in this obscure topic which I have been forced to take a professional interest in I'll copy it here:

> From: Glen Turner
> Date: 14 November 2011 3:02:55 PM ACDT
> To: Bob Woolley
> Subject: Re: [AusNOG] Test and tag rules
> 
> Bob,
> 
> OHAS regulations vary state by state, so there is no substitute for your own research. There is currently a revision of OHAS procedures occurring to prevent this duplication, but that's not of any current help.
> 
> If you are looking for exemption clauses then the things to look for are:
> 1. A computer room is not a "hostile environment". In a few states test and tag regulations only apply to hostile environments.
> 2. The definition for "fixed equipment" or "permanent locations" or "non-portable equipment". In some states this equipment is exempt.
> 
> My experience is that a racked computer is not usually exempt (there are exceptions in some states). The norm is that a flexible cable delivered with new equipment may be inspected by a competent person, deemed passed, and tagged with an expiry five years hence. However, you are required to a meet the particular requirement for the state the equipment is in, so as I wrote above, you need to do your own research.
> 
> A lack of exemption is reasonable: I know of three instances of electrocution in a data centre due to failure of a flexible lead to racked equipment.
> 
> All the states' regulations reference this testing procedure:
>    AS/NZS3760 In-Service Safety Inspection and Testing of Electrical Equipment
> which applies only to AC equipment and only to <600V [1]. It has a table 4 which says
>   Flexible power cord, not subject to flexing, not open to abuse, not hostile environment = test every five years
> 
> Part of AS3760 is to inspect the flexible lead. If you have the older leads without AS/NZS 3112: 2000 insulated pins then you can expect the inspection to fail. Part of AS3760 is to inspect the equipment for cooling operation. If you have excessively dusty equipment or unmaintained dust filters you can expect the inspection to fail.
> 
> Note that none of the above alters the OHAS obligation to manage hazards. Thus if your site has a history of electrocution risks due to cable failures then you would be expected to manage this, not simply refer to the interval in AS3760.  For this reason, hosting sites will usually create a safe working environment for their employees by applying their own test and tag requirements, which may be stricter than the state's regulations.
> 
> From a practical point of view, dual power supplies on equipment and power feeds to racks are well worthwhile to allow for continued operation during electrical inspection and scheduled parts replacement.
> 
> Cheers, Glen
> 
> [1] Equipment outside of this range is not exempt, rather you have to create your own procedures to manage the hazards.