PAT Testing of Modified imported equipment

[beatts]

Hi,

Just a bit of an odd one. We Supply a lot of small bakeries around the UK with various products and one particular product needs to be kept in a special type of countertop fridge which we but in from Belgium.

Before we supply these fridges to the bakeries we change the plug from the moulded continental type to a screw together UK type.

My question is this

As we are modifying a new piece of equipment, and then supplying to a bakery who is responsible for its PAT testing, us (the supplier) or them the bakery.

Normally I would say end user, but now with this modification I am not so sure!!

Please help

Many thanks

Also if we supply 2nd hand equipment do we need to have it PAT tested?

 

[netblindpaul]

There is no legal requirement for PAT.
The requirement is under EAWR89 & PUWER98, & the LVD generally
However, as you are modifying the equipment, and importing it into the UK, even though this is from another EU country and the equipment is CE marked, it could be argued that your modification defeats teh CE mark.
If you buy enough of these fridges why does the supplier not fit them with the appropriate plugs.
Your requirement will be that of the supplier under EAWR89 & the LVD.
If you meet these and can document your systems etc. you should be OK.
If I were you I would get the maker to fit the correct plugs, they will almost certainly be buying the cord sets in with plugs on so it simply means for them ordering and fitting a different cord set.

Your responsibility for 2nd hand equipment is the same.
You must ensure that it meets EAWR89, the LVD & it fit for purpose, how you do that is up to you.
PAT may be one way.

Remember that under the IET CoP there is no requirement to PAT new equipment, it is best practice as you then trap any manufacturing defects, and you have a bench mark against which to mark any deterioration.
Also, again, as this is not hand held equipment the PAT interval does not need to be annual under the IET CoP or HSE guidance either.

 

[beatts]

Hi,

Many thanks for your invaluable comments. However as we are not a huge buyer of these products, they won't change the cordsets, hence the reason we do it. Unfortunately they are the only supplier of this type of product within the EU and so we can't go elsewhere.

where can I read through EAWR89, the LVD

many thanks

 

[Mr.Ian]

Might be worth it to test each supplied appliance so you know it checks out ok, but once you've supplied it to you customer as far as I know it becomes the resposibility of the purchaser as it's their employees that will be using it, although i'm not sure if it's different on a rental basis ie if they rent the units from you, there's some info here - PAT Testing information directory - frequency of electrical testing

 

[beatts]

Hi,

yes they rent them from us, or rather we supply them FOC till they stop using the product contained within.

 

[netblindpaul]

EAWR89 is statue law and available on the Govt sites.
As is PUWER98.
The LVD is available from the EU legislation website.

PAT intervals are available in the IET CoP & on the HSE website, hse.gov.uk, check the electrical or portable appliances area.

It is better to reference statute law, and official guidance rather than "sales" oriented sites.

 

[netblindpaul]

Oh,
If you are "renting" the unit then you need a contract to decide who is responsible, you may need a contracts engineer or lawyer to draft his up for you.
Even FOC "loan" can be renting.
This could get very complex, and basically both are legally responsible for the safety in this situation.