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Thanks to Steve Love for this information
Question: Can a home inspector remove the electrical panels cover during the course of an Inspection?
I wanted to follow up with you regarding your message, the questions the home inspector industry have raised has precipitated a great deal of discussion within ESA, which has impacted the timeliness of my response. As a result, ESA will be providing regulatory direction as to what constitutes “electrical work” in relation to specific activities that are undertaken by home inspectors in single family residential dwelling units in the near future. In the interim please consider the following information for the application of the Ontario Electrical Safety Code in relation to home inspection practices. I have also included information related to the CSA A770 Home Inspection Standard and considerations of the regulatory relationships that need to be understood by the home inspection industry.
In addition to ESA’s response to the attached email I have also addressed issues raised by Bob Tellier in this matter as follows:
Rule 2-032 Damage and Interference
In accordance with the Ontario Electrical Safety Code (OESC) Rule 2-032 (Damage and Interference), it may be interpreted that interacting with electrical equipment, in this example removing a panel cover, could create an unsafe electrical condition.
Based on the OESC requirements, if a home inspector is opening a panel and interacting / interfering with the electrical equipment, it could create an electrical hazard. This would be of concern for ESA.
Please note the following from Rule 2-032 Damage and interference:
- No person shall damage or cause any damage to any electrical installation or electrical equipment.
- No person shall interfere with any electrical installation or electrical equipment in the course of alterations or repairs to non-electrical equipment or structures except where it is necessary to disconnect or move components of an electrical installation, in which event it shall be the responsibility of the person carrying out the alterations or repairs to ensure that the electrical installation is restored to a safe operating condition as soon as the progress of the alterations or repairs permits.
Rule 2-304 Disconnection
The requirements of the Ontario Electrical Safety Code provides for the protection of installations and persons under Rule 2-304 Disconnection which prohibits working on electrical equipment while it is energized unless it is not feasible.
2-304 Disconnection (see Appendix B)
- No repairs or alterations shall be carried out on any live equipment except where complete disconnection of the equipment is not feasible.
- Three-way or four-way switches shall not be considered as disconnecting means.
- Adequate precautions, such as locks on circuit breakers or switches, warning notices, sentries, or other equally effective means, shall be taken to prevent electrical equipment from being electrically charged when work is being done.
Generally the benchmark for feasibility is difficult to achieve. The Appendix B note to Rule 2-304 provides some guidance in regards to activities that may be undertaken on energized equipment as follows;
Examples of tasks that are not feasible when electrical equipment has been completely disconnected are troubleshooting of control circuits, testing, and diagnostics. It is intended by this Rule that persons performing maintenance, adjustment, servicing, or examination of energized electrical equipment adhere to all applicable safe work practices around the energized electrical equipment.
It also directs code users as follows:
See Section 0 for the definition of Qualified person.
From Section 0: Qualified person: one familiar with the construction and operation of the apparatus and the hazards involved.
CSA Z462 provides assistance in determining severity of potential exposure, planning safe work practices, and selecting personal protective equipment (PPE) to protect against shock and arc flash hazards.
When the requirements of Rule 2-304 are considered in context to the information provided by the Appendix B note and the definition of a qualified person one should understand the interaction with electrical equipment represents a level of risk that should be considered in the planning of work. What needs to be understood prior to work planning is the qualification (competency) of the individual in their understanding of the evaluation of hazards present and the risk associated with those hazards which usually relies on evidence of some level of training and certification. To understand the level of risk one must consider the likelihood of an incident occurring and the severity of the event if an incident were to occur. The assessment of likelihood and severity requires an individual to have a knowledge of the electrical equipment and its associated system which includes consideration of installation and maintenance practices, the characteristics of the system and if there are any evidence of potential failure.
The CSA A770 Home Inspection Standard
CSA Standard A770, Home Inspection, does not make considerations of work practices as it is a process standards and does not provide detailed practices for executing home inspections in regards to safety or qualification. The A770 Standard states that it is intended to be a non-invasive as identified in Clause 0.4 Home Inspections. The standard also does not limit the user to its exclusive use in the practice of home inspections. Clause 1.3 Exclusions also states that the standard does not address issues related to competency, qualification or certification of individuals performing home inspections. What should be understood is that other standards and regulations must be referenced in determining qualifications and safe work approaches when using the A770 Standard.
Home Inspection Regime and other jurisdictions
It is important to note that the Ministry of Labour and the Ontario College of Trades play an important role in defining the scope of work for trades and determining who may work on electrical equipment and under what conditions.
ESA recognizes that there may be a number of work practices and scope-of-work considerations of a home inspector that require further contemplation through the upcoming home inspection regime being created by Ministry of Government and Consumer Services. Determining how the upcoming home inspection regime will interact with existing legislation (i.e. ESA, OCOT and MOL jurisdiction) will provide additional clarity on how the ESA and home inspectors can work cooperatively to ensure the safety for the people of Ontario.