Who can test and tag in New Zealand?

This question usually arrives in one of two forms. Either someone has been told they need an electrician and is bracing for the invoice, or someone has been told anyone can do it and is wondering whether that can possibly be right.

Both are half right.

The short version

There is no licence to test and tag in New Zealand. There is no registration, no register, and no legal qualification. The requirement is competence, and competence is something you have to be able to demonstrate rather than produce a card for.

That is a lower bar than most people expect and a higher one than most people meet.

What WorkSafe actually says

WorkSafe's guidance is direct on this point:

It also says the choice is yours as a PCBU: get the testing equipment and train up a worker, or hire a third party. Both are legitimate.

Note what is absent. No qualification is named. No course is mandated. No body issues a ticket. That is deliberate — the duty under the Health and Safety at Work Act 2015 is to manage the risk so far as is reasonably practicable, and the law does not care how you staff it as long as the work is done properly.

Which means the accountability sits with you, not with a certificate.

What "competent" means in practice

If you had to defend your programme after an incident, competence is one of the first things you would be asked about. Here is what it actually consists of.

Understanding the standard, not just the machine. AS/NZS 3760 sets out how in-service inspection and testing is done and what the results mean. A person who can operate a tester but cannot explain why a Class I appliance gets an earth continuity test and a Class II one does not is not competent — they are trained on a button.

Being able to do the visual inspection properly. This is the part that catches most real faults and the part most often rushed. Damaged cords, cracked plugs, missing pins, strain reliefs pulled out, casings gone brittle near heat, gear that has obviously been wet. No instrument finds these. A person walking past at speed does not either.

Knowing what the readings mean. A tester gives you a number and a pass light. Competence is knowing when the pass light is lying to you — a long lead giving a marginal earth reading, an appliance with a filter that skews insulation resistance, a reading that is fine today and trending badly against last year's.

Knowing where your competence stops. Recognising an item that needs a registered electrical worker, and stopping there.

Being able to record it defensibly. The test is not the deliverable. The record is. Item, location, date, result, tester, next due date, and the reasoning behind the interval.

The repair line you cannot cross

This is the hard boundary, and it is the one that catches well-meaning businesses out.

Testing is not electrical work. Repairing is.

A competent tester can inspect an appliance, test it, fail it, tag it out and remove it from service. What they cannot do — unless they are a registered electrical worker — is open it up and fix it. Replacing a damaged plug, repairing a lead, replacing an element, re-terminating anything: that is electrical work under New Zealand law and it needs a registered person.

In practice this means every testing programme needs a relationship with a registered electrical worker sitting behind it. If your provider tests but has no answer for what happens to the failures, you have half a service. We cover the process in what happens when an appliance fails a test and tag.

Should you train someone in-house?

We do this work for a living, so treat what follows accordingly — but the honest answer is that in-house works well for some businesses and badly for others, and the deciding factor is not cost.

In-house tends to work when:

• You have a genuinely large item count and one site
• There is a maintenance or facilities person whose job description can actually absorb it
• Equipment moves around constantly, so testing needs to happen continuously rather than annually
• Someone in the business wants to own it

In-house tends to fail when:

• It becomes the fourth priority of someone already at capacity
• The person trained leaves, taking the competence and often the login with them
• The tester goes uncalibrated for years because nobody owns that either
• Nobody wants to fail the boss's equipment

That last one is worth sitting with. Independence has a quiet value. It is much easier for an outsider to condemn the ancient heater in the manager's office than for the person who reports to him.

If you go in-house, budget for the course, the tester, its calibration, the current edition of the standard, and the software or register to hold the records. The equipment is the cheap part.

What to ask a provider before you sign

If you are hiring instead, these five questions separate the professionals from the sticker merchants. All of them are reasonable and none of them should cause hesitation.

1. Which edition of AS/NZS 3760 do you work to? The current edition is 2022. If the answer is 2010, ask why — see which version of AS/NZS 3760 applies.
2. When was your test instrument last calibrated, and can I see the certificate? An uncalibrated tester produces numbers, not evidence.
3. What do I get besides tags? If the answer is a summary sheet, you do not have a register. You want per-item records you can hand to an auditor, an insurer or the next facilities manager.
4. What happens to failures? Who repairs them, on what timeframe, and how does the repair get recorded and re-tested?
5. How did you arrive at my interval? If the answer is "everyone gets twelve months", they have not done a risk assessment — they have applied a default. See how often you should test and tag.

The uncomfortable truth underneath all of this is that competence is invisible until it is tested, usually at the worst possible moment. A tag tells you an item passed. It tells you nothing about whether the person holding the tester knew what they were looking at.

That is why we would rather be asked these questions than not.