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Posted By Topic: Changing plugs on imported lamps

Mar 04 2018 14:47

Just thought of another quick question i'd like to get others views on...

Recently asked to change the plug on a imported lamp (by a reputable retailer.
Replacing european plug to NZ standrad plug.

Simple job. Changed plug. The lamp had an isolating switch built into the cord which is not uncommon - although upon testing i noticed the the isolating switch had been wired incorrectly from the factory - so was switching the neutral instead of the phase.

I assume its probably quite a common occurence.

Where does our responsibilty lie??

All i've actually done is replace the plug which just requires an ESC for just the work i've done. is that so?

Most of these isolating switches from the factory are unable to be opened to fix the problem so to fix it i had to chop out the isolating switch completely & put a new one on (which didnt look half as good as the one from the factory (bit bulky).

& the looks department Kind of matters when its an expensive fitting!

Anyway is it our reponsiblity to remedy this or can we leave as is seeing as all we are really doing originally is changing the plug?

i'm assuming seeing as its the factories fault the responsibilty lies therein?
Or the importers?


Mar 04 2018 16:20

Are you sure it was wired incorrectly? What was the colours? I have found white and black cores. White is N and black is A. Also did you check the specs on the lead? Is the lead ok for NZ. Some are rated for 110V. Although being European should be ok.

Mar 04 2018 16:46

I'd be checking the SDoc

Mar 04 2018 20:03

A portable luminaire is a declared high risk article. It needs the whole gambit before it can be offered for sale in NZ. It would be tested against AS/NZS 60598 which requires single pole switches to operate in the live conductor and not the neutral.

Swapping out a non NZ plug seems simple enough but thar be dragons! You may consider yourself lucky to have discovered the neutral switching. But who knows what other non compliance issues remain after the plug and switch?

Check ESR74A and you'll see that an ESC doesn't apply to an appliance. By changing the plug and switch it's arguable whether you were repairing the appliance. If you were repairing then you'd would test and tag it to AS/NZS 5762.

But that assumes that the appliance was electrically safe before it failed and required repair. Given the non compliant plug it fails ESR23 and was never electrically safe to begin with.

What you've actually done is altered the appliance from the manufacturer's spec. Any standard that it once complied with may no longer be met. It's a new declared high risk article and needs to go through the appropriate tests before it can be sold.

Mar 04 2018 20:37

Thanks but just because the lamp came into the country doesn’t with a European plug doesn’t make it electrically unsafe.

I merely changed the 2 pin plug (forgetting for arguments sake that I changed the isolating switch on the cord also) & I wasn’t required to test & tag the lamp.

So if I just changed the 2 pin euro plug to NZ & say for the sake of this discussion I hadn’t discovered the problem at the isolating switch - then who is at fault?

Shouldn’t it lie with the factory - I merely discovered the problem.


Mar 04 2018 20:39

Ppaw - it wasn’t American. European - colours brown,blue & green

Mar 04 2018 20:44

& lets just say I hadn’t discovered the problem - so all I did was change the plug - am I then required to test that all the other functions of the lamp work properly?
Or just my part? I would say just my part!


Mar 04 2018 21:05

No. The problem lies with the importer. You just wasted your time and their money. Worst case you helped make something appear compliant when it is not.

How far through your training are you newbie? This could offer good practice for the Regs exam.

Regards the EU plug. ESR23(1)(e) makes the appliance unsafe if it is fitted with a plug that doesn't comply with the corresponding standard oon Schedule 4.

Schedule 4, 11(2) under portable general purpose luminaries cites AS/NZS 60598-1 in conjunction with 60598-2.4 and as modified by annex ZZ for Australia and New Zealand conditions.

60598-1 Annex ZZ 5.2.18 states that a portable luminaire with a supply cord shall be fitted with a plug complying with AS/NZS 3112 which is a NZ single phase plug.

So the appliance doesn't comply with the applicable standard and therefore meets the definition of "electrically unsafe" by ESR23.

Yes, you could swap out the plug. But how do you know that the other requirements of 60598 are met? You don't unless the appliance has passed lab testing and an SDOC issued.

Please don't take offence at this explanation. It is intended to educate, that's all.

Mar 04 2018 21:20

If all you did was change the plug with the intent of repairing the appliance to take it from electrically unsafe to electrically safe then; by your posts you failed to test and tag to AS/NZS 5762 as required by ESR90.

If convicted would be liable to a level 2 penalty, ie. a fine not exceeding $10,000.

The devil is in the details. As a newbie you should stick to what you know.

Mar 04 2018 21:50

I'm a newly qualified sparky - obviously i don't know everything & doubt there are many (if any) that do.

Like you say stick to what you know i guess, but this is why this forum is so great.

I find it crazy that because i'm making something more electrically safe i'm actually liable to get penalised instead of leaving as is!

Anyway so from what i can gather from what your telling me - is that it is fine to simply replace the 2-pin plug.

The onus is still on the importer to supply a SDOC to the whoever they decide to sell the lamp too & by changing out the plug (& only the plug) i am merely helping an appliance seem slightly more compliant than it actually might be.


Mar 04 2018 21:53

& no offence taken, i appreciate you taking the time to try & point me in the right direction :)

Mar 04 2018 22:08

By adding an NZ plug you might make it more unsafe if there are other issues. With an EU plug it is more difficult to connect to a supply.

Read ESR90. If you work on appliances or otherwise affect their electrical safety you must test to 5762 then tag according to the results of those tests.

Mar 04 2018 22:43

Ok. so it seems the tests detailed in 5762 after having a quick look on the online version on ewrb look like they are just fairy common sense visual tests.

So i can change the plug & perform 3760 tests as a minmimum from what i see.

then as long as i record results i dont have to tag the lamp.

So the SDOC means nothing once i've touched anything at all on appliance.

its all very Confusing - who would've thought changing a plug could be such a minefield.

So if lamp fails these tests then what? tell importer tough titties & he's going to need to get a new SDOC issued by a NZ authority.


Mar 04 2018 22:55

Yes, you do the tests in 3760 but don't forget to check the specifics in table A1 of 5762.

Affixing a tag is mandatory by para 2.5.2. I print my own self adhesive tags using a laser printer. I copied AlecK and made one tag with check boxes for both 5761 and 5762.

Mar 05 2018 07:23

Excellent response Rob, you've explained the bear traps/ mine field scenario that our craft can entail really well, Bravo Zulu.

Here's a similar can of worms, Dust Collector with an outlet to run a tool off. Originally rated by the German Manufacturer at 3400W and (I suspect) fitted with a plug rated at 15Amp, item has a 15Amp 3112 compliant outlet.

These were then "changed" by someone, and had a 10Amp plug fitted, and in some instances, the Rating Plate altered with a sticker to state the the item is now rated at 2200 Watt, have pointed all this out to ES and now waiting to see what their response is.

Mar 05 2018 09:04

mowgli's covered it pretty well; just a couple of related points.

First, yes ESR 90 requires testing to "5762" after ANY work on an appliance that could affect electrical safety. That includes both PEW & non-PEW. "non-PEW" work includes safety guards etc; but also covers swapping the plug - which under Schedule 2 is not PEW.

Yes the tests are straight-forward, specific visual checks then off to "3760" for basic electrical tests. Which wouldn't find a switch operating in N alone.

However it is not necessarily "unsafe" to have switches operating in neutrals, (or even in neutrals alone). Same for conductor colour codes. We can't apply rules for the wiring of installations to appliances; they have their own Standards that they comply to (or not). I very much doubt switching N alone would be acceptable in any Schedule 4 Standard; but the point is when you get into appliances you are under a whole different set of rules, and you have to leave "3000" out of it.

Note also the in-line cord-switch is NOT an "isolating" switch.

Yes "5762" calls for a tag - but ESR 90 doesn't. Note the wording: 90(2)(a) calls for "testing", it does not call for "testing and tagging". Compare ESR 26. The words not used in an ESR may be just as important as those that are used.
So what you have to do after swapping a plug is test, and as a result of that testing you either "confirm it is electrically safe" i.a.w. the appropriate listed standard; OR , if it is electrically unsafe, you "disable and mark it". Clause (3) then explains a method of disabling & marking that is deemed to comply - meaning the "fail" tag should be - but doesn't have to be - the type specified in "4701".
A "pass" tag can be a useful thing, but it can also be hugely ugly; so I use mine with discretion.

So if we agree to undertake this sort of work, we're not automatically taking on responsibility for every aspect of it; on;y for what the combination of "5762" & "3760" can pick up. And we don't have to put our name to it.

The real issue is whether we should do the job in the first place; and for my money the answer is "no", unless there is already an SDoC - which I would want a copy of as bum-cover. The fact that it has a euro plug (or UK, or USA, or anything else "foreign") shows clearly that the importer has NOT issued a valid SDoC, because an SDoC must be based on testing by an accredited lab; and there's no way it could have got through that with the non-standard plug.

Agree changing the plug type would technically invalidate the SDoC - if there was one.

SteveH's case of an altered nameplate is interesting; but could well be perfectly OK.

The original rating was very likely based more on the rating of tool to be plugged into it, ie the item creating the dust rather than the relatively small motor that collects it. In which case, as long as both the plug and the socket are swapped-down to 10 A, the modified tally-plate may be kosher. I'd also expect some form of overload, so that the total of tool + dust collector can't overload the collector's plug; and this would similarly need to be swapped-down to 10A.

Or just change the socket, leaving plug & overload at 15 A.

So it could just be an appropriate response to the fact that very few sites in NZ have 15A-rated sockets. However as above, making that sort of alteration would invalidate the SDoC, so there would need to be an SDoC for the modified form.

On the other hand, I've lost count of the number of times I've found "double insulated" stickers applied by an NZ importer to light fittings that clearly require an earth.

So we can't afford to take sticky-labels at face value.


Mar 05 2018 12:20

"...also covers swapping the plug - which under Schedule 2 is not PEW"

I presume you mean Schedule 1(2), but even then (a) requires the work is done in accordance with ECP51 and without payment or reward. I'd be surprised if this was free work.

Mar 05 2018 14:39

Correct; I got the reference wrong. And I meant to say "is not always PEW".

The point was that doesn't matter whether PEW or not, doesn't matter who does it; ESR 90 still requires the testing, plus a decision about whether it's electrically safe or not.


Mar 06 2018 06:50

If I purchase a small Air Con unit with a Valid SDoC which has a build in lead and plug. Say the lead is to long and I shorten it, the SDoC is no longer valid?

Are we suggesting we can no longer use this unit?

Mar 06 2018 07:27

Yes, the SDOC would be invalidated. However, the SDOC was valid up until the point you shortened the lead. So you can include the original SDOC when assessing whether the changes you made have affected electrical safety. If there was no SDOC to begin with then you could be left guessing.

Mar 06 2018 07:41

Sometimes I wonder if SDoCs are really about safety?

It seams like a system to protect large importers/suppliers from any competition and they make electricians police it for then for free in the name of safety?

Mar 06 2018 08:25

"Sometimes I wonder if SDoCs are really about safety?

It seams like a system to protect large importers/suppliers from any competition and they make electricians police it for then for free in the name of safety? "

Yep, welcome to the free market approach of pass the cost onto someone else.

This is, IMO, compounded by New Zealand's ACC legislation which I believe, encourages the "she'll be right approach" by manufacturers, suppliers and the distribution network of wholesalers & retailers.

With the advent of the Workplace Safety Legislation, there are now some teeth which could be used, but most probably won't (bit like the E(S)Rs.