The missing definition of a “maintenance management system”

On 1 July 2013 the electrical work certification regime underwent significant changes. All electrical work is either prescribed electrical work (‘PEW’) or non-PEW. All PEW is divided into low-risk, general and high-risk work.

General and high-risk PEW cannot be treated as complete until a certified electrician issues a Certificate of Compliance (‘CoC’). One of the exceptions to this requirement is when the owner or operator of the installation has a maintenance management system (‘MMS’) in place for the installation; and that the MMS records key information that would have otherwise been found on a CoC.

One would have thought the MMS has a statutory definition. However, it is not mentioned anywhere in the current Act nor is it defined by the Electricity (Safety) Regulations. There does not appear to be an answer on the website of the Electrical Workers Registration Board, nor does there appear to be an applicable Standard on the making and keeping of an MMS.

There is no way of knowing what form the MMS must take, who must keep the records, who may view it, how long the records must be maintained and so on. The only requirement is that the MMS records what would have been recorded on a CoC. While significant fines and penalties apply if a CoC does not comply with the requirements of the Regulations, it is unclear whether the same penalties apply if the records on the MMS are incorrect.

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