Portable appliance testing on site: what's actually required

PAT isn't a legal must, and a green sticker isn't maintenance. What the law asks for portable kit on a factory floor, and where the real risk sits.

SiteSOS team · · 5 min read

The PAT contractor has been in. Every kettle in the canteen has a green sticker. So do the monitors in the office, the fans in the despatch cabin and the radio in the goods-in hut.

Down in the workshop, the 9-inch grinder has a sticker too. It's eight months old. Since then the lead has been run over by a pallet truck and taped up where the sheath split. Nobody thinks of it as a PAT problem, because it passed.

Most sites test the wrong kit too often and the right kit too rarely. The sticker becomes the goal. The real goal is kit that's safe the next time someone picks it up.

No. HSE is direct about it. The Electricity at Work Regulations require kit that could cause injury to be kept safe. They "do not specify what needs to be done, by whom or how frequently" (HSE PAT FAQs). Testing isn't a legal must, and nor is testing once a year.

The duty is maintenance. Regulation 4(2) says systems must be maintained "as may be necessary to prevent danger" (regulation 4). How you do that is up to you, as long as it works. We cover the wider duties in the Electricity at Work Regulations for maintenance managers.

Three kinds of check

HSE's guide for industrial sites is HSG107. It builds maintenance from three layers (HSG107, paragraph 36):

  1. checks by the user, every time they pick it up
  2. formal visual inspections by a competent person
  3. where needed, a combined inspection and test, which is the PAT

Most dangerous faults show up in the first two. HSG107 lists what users should look for: cut or frayed cable, cracked plugs, taped joints, coloured cores showing at the plug, burn marks, and kit that's wet or caked in muck (HSG107, paragraph 38). The grinder would have failed a user check on the first day.

Some faults you can't see. A broken earth wire inside a flex, or insulation breaking down, can "only be reliably detected by a combined visual inspection and test" (HSG107, paragraph 47). That's where the test earns its money. HSG107 says it's justified when you suspect a fault you can't confirm by eye, after any repair or modification, and at periods to suit the kit and how it's used.

How often on an industrial site

HSG107 has a table of suggested starting intervals (HSG107, Table 1). For heavy industrial sites, or anywhere kit gets knocked about, it suggests:

  • user checks daily*
  • formal visual inspection weekly*
  • combined inspection and test every 6 to 12 months*

For light industrial, it's a formal visual before first use then 6-monthly*, with a test every 6 to 12 months*. Battery tools under 40 V* need none of the three. Office computers that rarely move get a visual every 2 to 4 years*.

These aren't legal limits. HSG107 says the intervals are "not legal requirements" (HSG107, paragraph 57). Start with them, then adjust. If you find few faults, you can stretch the gap. If faults are common, shorten it. When you group kit for testing, use the shortest interval in the group.

So spend the money where the damage is. On most sites that's the workshop, the yard and the extension leads. The canteen is rarely the worry.

Stickers and records

There's no legal need to label kit or keep records. HSE still calls a record and labels "a useful management tool" for checking your system works (HSE PAT FAQs).

One detail most sites get wrong. HSG107 says that if you use a label, it shouldn't show a next test date. The person testing shouldn't decide when the next test is due. That's the dutyholder's call, based on risk (HSG107, paragraph 54).

Who can do it

You don't need an electrician for visual checks. HSG107 says a member of staff with enough knowledge can do the formal visual inspection, and trained people "should know when the limit of their knowledge and experience has been reached" (HSG107, paragraph 40).

Testing needs more. HSG107 describes two levels. Level 1 is someone not skilled in electrical work using a simple pass/fail tester. Level 2 is someone with electrical skills using an instrument whose readings need interpreting (HSG107, paragraph 50). For 110 V site kit and anything heavy, we'd want level 2.

New kit, hired kit and contractors' tools

New kit should arrive safe and doesn't need a formal test. A quick visual check that it isn't damaged is enough (HSE PAT FAQs).

For hired tools, HSE strongly recommends the hire firm inspects and tests before each hire. While it's on your site, keeping it safe falls to you.

Contract engineers bring their own kit. It's still being used on your site. Make a look at their leads and tools part of the induction, as covered in inducting a contract engineer. A good contractor won't mind, and will often keep their own records, as we set out in your tool kit as a contractor.

When it fails

Take it out of use straight away. HSG107 suggests labelling it faulty and, if it has a rewireable plug, taking the plug off. It stays out until someone competent repairs it (HSG107, paragraph 39).

Here's our view. The tape on the grinder lead is the real failure, more than any missed test. It means someone saw the damage and decided to keep going. Usually that's because there was no spare, and the job had to be done. A spare lead in the stores costs less than one hour of a stopped line. See the true cost of downtime.

What to do on Monday

  1. Walk the workshop and the yard. Pull anything with taped, cut or crushed leads.
  2. Sort your kit into risk groups and set an interval for each, using HSG107 Table 1 as a start.
  3. Brief users on the pre-use check and where faulty kit goes.
  4. Stop putting next-test dates on labels.

* Suggested inspection and test intervals and the 40 V battery figure, from HSG107 Table 1, correct as of 15 October 2026. Check HSG107 on HSE's website and HSE's PAT FAQs for the latest. HSG107 references are to the third edition (2013).

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