The Portable Appliance Testing (PAT) Question
It’s almost a controversial subject around repair cafes, is Portable Appliance Testing (PAT), so we decided to at least put a policy in place. There’s often a lot of inflexible assumptions and opinions on the essential requirement for PAT at repair cafes, and certainly it doesn’t hurt to do it. But it’s not as clear cut as those assumptions often make it sound.
TL;DR
Our approach to PAT at the repair cafe prioritises competence, practical risk assessment, and context awareness over blanket machine testing and stickers. PAT is not a legal requirement for our community setting, and applying stickers can create unnecessary liability. Instead, we focus on visual inspections, operational testing, and internal training to ensure safety without over-promising on long-term reliability. We avoid stickers because we can only certify the item as safe at the time and place of testing – not once it’s back home or in a different environment.
What is PAT?
PAT (Portable Appliance Testing) is the process of inspecting and testing electrical appliances to ensure they’re safe to use. The acronym PAT stands for Portable Appliance Testing, so it’s technically redundant to say PAT testing (like saying PIN number). However, the term PAT testing is widely used and generally accepted, so you may hear it used interchangeably.
Legal Requirements for PAT
- No Specific Legal Requirement:
- There is no legal obligation for repair cafes in the UK to carry out PAT on the items they fix. However, there is a general duty under the Health and Safety at Work etc. Act 1974 and the Electricity at Work Regulations 1989 to ensure that any electrical equipment you handle is safe to use, if the activity could be considered work. While a repair cafe is a community event and not a workplace, it’s still good practice to follow these guidelines for the safety of volunteers and visitors.
- Risk-Based Approach:
- These regulations require that electrical equipment is maintained in a safe condition, which usually involves regular inspection and testing, but this is based largely on a risk assessment, not a quick buzz on a PAT machine.
- Competence:
- The person carrying out PAT must be competent, but this does not require a formal qualification. Volunteers can be trained internally as long as their training covers the basics of electrical safety, risk assessment, and the correct use of any PAT equipment, as well as understanding the specific limitations of PAT within the repair cafe environment.
The Three Key Elements of PAT
1. Visual Inspection
- This is a critical part of PAT and should be carried out even if no further tests are performed. Common checks include:
- Frayed or damaged cables
- Cracked or broken plugs
- Exposed wires
- Signs of overheating, burning, or arcing
- Loose or missing screws or components
2. Operational Test
Where practical, it’s good practice to power up the appliance to ensure it functions as expected after repair.
- Check for unusual noises, overheating, intermittent faults, etc.
3. Risk Assessment and Context-Dependence
PAT is context-dependent – an item that is safe in one environment may not be safe in another.
For example, an item used in a damp house, garage, or workshop has a completely different risk profile than one used in a dry, low-risk repair cafe with electrical experts present.
This context is critical. A successful PAT result at the repair cafe only certifies that the item was safe at that moment, in that place. This significantly limits the long-term value of any test, which we can look at more closely in the next section.
The Validity of any PAT
Point 3 above is critical here, especially for repair cafes, and is one of the main arguments that contradicts the usual assumptions around the value of testing everying with PAT equipment. Let’s look at it a little more closely.
PAT is context-dependent – an item that’s safe in one environment may not be safe in another. A critical part of PAT is the risk assessment, which considers the environment in which the appliance will be used, the likelihood of damage, and the potential for misuse.
At a repair cafe, we can only assess an item’s safety in the context of the environment it’s tested in – typically a dry, indoor, low-risk space with experts present. Once the item leaves the cafe, we have no control over where it will be used or the conditions it will be exposed to (e.g., a damp shed, a poorly wired garage, or an outdoor workshop, damage on the return journey home, etc).
Limitations of PAT in a Repair Cafe Setting
Here’s the big one: Because we can’t assess the risk in the item’s final location, a successful PAT result at the repair cafe only certifies that the item was safe at that moment, in that place. This significantly limits the long-term value of the test, as the conditions that affect safety can change dramatically once the item is moved.
Stickers and Liability
- No Implied Guarantees:
- Applying a PAT sticker can imply a long-term guarantee of safety, which isn’t realistic for a repair cafe, as we have no control over the conditions the item will be used in after it leaves. In fact, applying a sticker may actually increase our exposure to legal risk, as it could be interpreted as a certification of long-term safety, which we can’t provide. After all, any PAT result is effectively invalid once the item is back at home, where it hasn’t had a visual inspection or risk assessment.
- Internal Records Instead:
- It’s often better to keep internal records of the tests we carry out, including the date, the basic test results, and the name of the volunteer who performed the test, without applying stickers or giving any guarantee, written or verbal, that the item is now certified as safe. This approach demonstrates due diligence without making an unrealistic promise of ongoing safety. And that’s typically taken care of on the item’s booking form.
Training and Competence
- No Formal Certification Required:
- While City & Guilds qualifications do exist, they’re not legally required. Volunteers can be trained internally, or through free online courses, as long as they gain the necessary knowledge and practical skills.
- Documenting Competence:
- It’s a good idea to keep a simple log of volunteer training, including the topics covered and the names of those trained, in case the insurer asks for evidence of competence.
Insurance Considerations
- Competence is Key: Most insurers don’t actually require formal certification, but they do expect volunteers to be competent to perform PAT.
- Record Keeping: Keeping a basic log of tested items helps to demonstrate that we take electrical safety seriously, even if this isn’t formally required by law.
- Stickers and Liability: As discussed, it’s actually better to avoid applying stickers in terms of meeting insurance requirements. We keep our own records for this, but don’t put a guarantee on visitor’s items.
All of which, you might realise, you’re probably doing already at a repair cafe. So chances are, you’re already carrying out PAT on items, even if you don’t have a machine, stickers, certificates and a £350 hole in your accounts where you paid for training.
Final Thoughts
You can obviously tell that we aren’t big believers in the opinion that a PAT machine and a sticker are vital to the operation of a repair cafe.
But that’s not to say we don’t think PAT is an important part of ensuring electrical safety. It’s just that plugging it into a tester isn’t the one-size-fits-all solution that’s often suggested. It should be approached as a practical risk management tool rather than a box ticking exercise.
That’s our approach to PAT, anyway.