SAFETY OF SOLAR PANEL INSTALLATIONS IN VICTORIA REPORT

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1 SAFETY OF SOLAR PANEL INSTALLATIONS IN VICTORIA REPORT July 2010

2 Table of Contents Executive Summary... 3 Glossary of Acronyms and Phrases Introduction...5 Background 6 Electricity safety requirements for installation of solar panels in Victoria...7 Audit methodology and results 10 Immediate compliance and enforcement activity in response to audit findings...12 Medium and longer-term measures to improve the safety of solar panel installation.13 Responding to this report.14 Attachment 1 15 Attachment 2 17 References...19 Energy Safe Victoria. This publication is copyright. No part may be reproduced by any process except in accordance with the provisions of the Copyright Act 1968 and the permission of Energy Safe Victoria Page 2

3 EXECUTIVE SUMMARY In Victoria, most electrical equipment can only be installed by qualified persons who are licensed by ESV. The licensing ensures that only competent and qualified workers carry out electrical installation work. The installation of solar panel systems is electrical installation work. Only licensed persons can install most grid-connected solar systems in households in Victoria and Australia. In response to reports of potentially unsafe situations associated with installed solar panels, ESV commissioned audits of solar systems across Victoria. Of a total of 81 audited installations, 9 were found to have incorrect isolating switches installed that did not comply with applicable electrical standards. ESV has taken steps to ensure that the identified non-compliance is rectified by requiring the fitting of correct switches. The use of incorrect switchgear in solar installations is a potential fire risk. While the risk is low, nevertheless the risk to safety is not acceptable and ESV has now implemented a range of measures to improve the technical knowledge and practices of the industry in relation to the installation and inspection of solar panel systems. As I reported in my last column for vicnews, ESV has also formed an industry working group one of its tasks being to examine the regulatory arrangements applying to solar installations and the adequacy of the regulation of the solar installation industry. The working group will provide advice and recommendations to myself and its work will inform the scope and nature of further audits to be carried out by ESV to ensure that corrective actions that have been adopted are effective and that the community is being protected. Comments on this report are invited from stakeholders and interested parties and can be directed to: Neil Fraser Executive Manager, Electricity Installation & Equipment Safety tel: Page 3

4 GLOSSARY OF ACRONYMS AND PHRASES AC DC ELV ESV ETU LEI LV NECA PV REC RET the Act alternating current direct current extra low voltage Energy Safe Victoria Electrical Trades Union licensed electrical inspector low voltage National Electrical and Communications Association photovoltaic registered electrical contractor Renewable Energy Target Electricity Safety Act 1998 (Vic) Page 4

5 INTRODUCTION Solar power is an increasingly important source of renewable energy. Electricity generated by interconnected solar PV cells more commonly known as solar panels is supplied to household appliances and excess power can be fed back into the electricity grid. According to the Clean Energy Council, 7.6% of Australians have solar systems installed in their homes 1. In Victoria electrical equipment can only be installed by qualified persons who are appropriately licensed. ESV oversees the safety of electrical installation work and administers a licensing system to ensure that only competent and qualified workers carry out electrical installation and inspection work. Firms installing solar panels under the Commonwealth government s RET scheme are now required to be licensed electricians. Under Victorian law, the wiring associated with the connection of solar panels to the customers installation and the network grid is electrical installation work and can only be performed by licensed persons. It has come to ESV s attention that a number of solar panel installations recently completed across Victoria has had an incorrect switch fitted. This report outlines the nature of the risk associated with the fitting of incorrect switches and the action that ESV has taken and is taking to address the associated safety issues. Purpose of report The purpose of this report is to: inform all stakeholders of the outcomes of audits that were carried out in response to reports of unsafe situations; explain the immediate action ESV has taken and is taking to address the risks and ensure public safety; invite responses and feedback from stakeholders, industry and the public on this report and ESV s preliminary conclusions and views as to the longer-term actions that need to be taken to ensure that the public, workers and property are kept safe from risks. 1 Clean Energy Council, Clean Energy Australia 2009, page 29. Page 5

6 BACKGROUND Overview of ESV s statutory role and functions ESV is established under the Energy Safe Victoria Act 2005 as the technical regulator responsible for ensuring the safe and efficient supply and use of electricity, gas and pipelines in Victoria. ESV seeks to discharge theses responsibilities by: working collaboratively and in consultation with industry and the community to facilitate safety outcomes; developing and communicating safety and efficiency requirements and programs; monitoring, auditing and enforcing compliance with safety requirements; and administering licensing, registration and approval systems that maintain safety standards and skills. ESV s statutory objectives relating to the safety regulation of electricity include: ensuring the electrical safety of electrical generation, transmission and distribution systems, electrical installations and electrical equipment; and maintaining public and industry awareness of electrical safety. ESV s statutory functions relevantly include: determining minimum safety standards associated with electrical equipment, electrical installations and electrical work; inspecting and testing electrical equipment, electrical installations and electrical work for compliance with specified safety standards; investigating events or incidents which have implications for electricity safety; advising the electricity industry and the community in relation to electricity safety; and monitoring and enforcing compliance with the Act and the regulations made under the Act. ESV monitoring and compliance activity ESV monitoring of the safety of electrical installation work in Victoria is facilitated through the certificate of electrical safety system and random audits of electrical work. Audits enable ESV to identify trends in the standard and compliance of electrical work. This data is used to inform ESV and, if necessary, the government of the possible need for specific initiatives or legislative change to address emerging safety issues. Information obtained from the audit program and from incident reporting and response is used to ensure that ESV administers regulations that are targeted, proportionate and evidence-based. Page 6

7 ELECTRICITY SAFETY REQUIREMENTS FOR INSTALLATION OF SOLAR PANELS IN VICTORIA Overview - general requirements The Act sets out a number of duties in relation to how electrical installation work is to be carried out in Victoria. Only licensed persons may legally carry out electrical installation work, and such work must comply with the Act and the new Electricity Safety (Installations) Regulations 2009 and be tested before it is connected to electricity supply or before the work is first used after it is completed. Furthermore, a licensed electrician must complete and sign a certificate of electrical safety in respect of that work and, if the electrician is also the person responsible for carrying out of the work, give the signed certificate to the responsible person. In most situations involving the carrying out of electrical installation work in homes and businesses, the responsible person is the REC engaged by the owner of the premises to carry out the work. If the work is prescribed electrical installation work 2, the work must be inspected by a LEI in accordance with the regulations before the installation is connected to the electricity supply or before the work is first used after it is completed. The responsible person is also responsible for ensuring that a certificate of electrical safety is completed and given to the customer and to ESV within the required time. Under the regulations, a person must not install, alter, repair or maintain an electrical installation unless the installation complies with AS/NZS 3000, which is commonly referred to as the Australian/New Zealand Wiring Rules. Under those rules, electrical equipment forming part of an electrical installation must be selected and installed to operate safely and reliably and so as not to be a hazard in terms of fire, electric shock or other injury The regulations also contain more detailed requirements for the testing and inspection of electrical installation work. Safety requirements applying to the installation of solar panels Under new Commonwealth regulations that commenced on 21 June 2010, firms seeking to install solar PV installers under the RET are now required to be licensed electricians 3 2 In broad terms, prescribed electrical installation work is work on, or upstream of, the installation s switchboard and, in the case of solar installations, the LV portion of the solar installation. 3 with the exception of some remote non-grid connections, as outlined in the Media Release issued by Senator Penny Wong, Minister for Climate Change, Energy Efficiency and Water on 21 June Page 7

8 and accredited by the Clean Energy Council in order to avoid penalties, which include fines and ineligibility to create renewable energy certificates. A solar PV installer who is not licensed under the ESA is not able to lawfully carry out any electrical installation work associated with the connection of solar panels. However, it is permissible under Victorian law for an installer to sub-let the electrical installation portion of the work to an REC. In this case, the installer is the REC s customer and receives the required certificate of electrical safety. All parts of the solar panel installation are required to comply with the Wiring Rules. An electrician who connects the ELV portion of the installation to LV is responsible for ensuring that the ELV section complies, and a certificate of electrical safety must be issued attesting to that fact. ELV is voltages below 50V AC or 120V DC. These voltages are not considered dangerous and installers are not subject to licensing requirements. LV is voltages between 50V and 1000V AC and 120V and 1500V DC. Installation of equipment operating at LV requires a licence. Individual solar panels are ELV DC and when combined in an installation form an LV array of between 280 and 600V DC. The DC array is then connected to the inverter via a DC isolation switch; the inverter converts the DC to AC electricity and controls the output voltage and manages the connection to the electricity grid via an AC isolator and the meter. The inverter also ensures that if grid supply fails, the solar system does not backfeed the grid. Backfeeding refers to a phenomenon where, in the event of a power failure in the street, solar installations in the vicinity maintain supply to each other and the grid, thereby endangering supply company workers who may be rectifying the failure. It is a requirement of the inverter standard that inverters not backfeed the grid. This is referred to as anti-islanding. A typical home-based grid-connected solar panel installation is illustrated below. Page 8

9 The LV part of the installation must be inspected by a LEI before the panels can be connected to supply. Any section of the electrical installation operating at ELV is not prescribed electrical installation work and accordingly is not required to be inspected. However, it is the responsibility of the electrician to ensure the ELV portion complies with the relevant installation standards and that the certificate of electrical safety that is required to be issued covers this work. Prior to operation, a grid-connected solar system must be inspected by a licensed electrical inspector. The new Electricity Safety (Installations) Regulations 2009 also require a person who carries out electrical installation work on a consumer electricity generation system which includes most domestic or household solar PV installations - to clearly and permanently mark the main switchboard, associated switchboards and fire panels in the premises with a warning 4 and to clearly identify the location of isolation switches installed for the generation system. What has driven the need for ESV action in relation to solar PV installations? There is an increasing trend toward the use of renewable energy technology driven by concerns over climate change and a range of government incentives designed to encourage adoption of new technology. Solar energy is one form of renewable energy. The total number of Australian households using solar energy increased by 60% between 2002 and In July 2009, more than 41,000 homes across Australia had solar PV installed. 6 Earlier this year, ESV was approached by the ETU and NECA in relation to the safety of solar installations. ETU and NECA raised concerns that solar PV systems were being installed incorrectly, posing risks to the customer. There have also been media reports of concerns regarding adherence to relevant minimum safety standards 7 and of constituent complaints to members of parliament. ESV has received one report of a fire arising from an isolator situated at a solar cell and requested further information from the Metropolitan Fire Brigade. As this notification was not received soon after the event, no formal investigation was conducted by ESV. ESV has a key role in ensuring electrical safety and minimising risk to human life and property. In response to the concerns and reports regarding the safety of solar PV installations, ESV implemented an audit program with a view to identifying and rectifying potentially unsafe solar installations. 4 The wording of the warning is as follows: Warning this premises contains an electricity generation system. 5 Clean Energy Council, Clean Energy Australia 2009, page Clean Energy Council Fact Sheet, All About Solar Photovoltaic. 7 For examples, see Hawthorne, M. & Murphy, M.; Arup, T. Page 9

10 AUDIT METHODOLOGY AND RESULTS The purpose of the audits was to test the standard of electrical work and the adequacy and veracity of the regulatory checks and balances in place with respect to solar PV installations. Audit methodology ESV commissioned three electrical inspection companies to audit 100 solar installations in 4 designated audit zones across Victoria. To allow for the likelihood of lack of access to premises, about 40 certificates of electrical safety relating to installed solar systems in each zone were allocated to the inspection companies. Eighty-one audits were actually carried out. All audits were carried out by LEIs. The key items related to compliance with applicable standards and legislation, including: warning labels (point of supply, meter panel, DC wiring); panel/inverter specifications; isolation devices; and functional tests. The record of inspection and testing used by the LEIs is Attachment 1. Audit results Nine audited solar installations were found to have incorrect AC switches or circuit breakers (switchgear) installed where DC switchgear should have been used. This switch is installed on the roof adjacent to the solar panel array to isolate the DC voltage generated by the panel from the inverter in an emergency or to enable safe maintenance of the solar installation. Of the 9 non-compliant installations, 8 were LV and were required to be inspected as prescribed electrical installation work. The remaining installation operated on ELV and was not required to be inspected upon installation. In 2 of the 9 audited installations, the AC current rating was found to be approximately 3 times the DC current and accordingly would be unlikely to fail in an unsafe manner 8. The use of an incorrect switch is potentially unsafe because of the potential to ignite and cause fire if switched while under load. However, switches are designed to fail safely. To become a fire hazard, ignition would have to occur while being switched off under load and the enclosure housing the switch mounting, which should contain any outbreak of fire, would have to fail. Other ignitable material would also need to be in the vicinity. Also, operating instructions and procedures require the method of shutdown to ensure that the switch is only operated under no load and is therefore not unsafe. Even so, with 8 Information is not available in relation to the other 7 audited installations. Page 10

11 the increasing number of solar systems, this represents an unacceptable outcome across the population of solar installations in Victoria. A further 17 installations were found to be technically non-compliant due to incorrect labelling or the lack of a label in breach of clause 3.5 of Australian Standard 5033:2005 (Installation of Photovoltaic Arrays). 9 No defects were identified in the remaining 55 audited installations. 10 In addition, all systems were tested to ensure that the anti-islanding function worked correctly. All operated correctly. 9 Clause 3.5 of AS5033:2005 states that where PV array cabling could be confused with other wiring systems, appropriate identification shall be provided at regular intervals. 10 Six of these audits were limited due to inability to safely access the roof area. Page 11

12 IMMEDIATE COMPLIANCE AND ENFORCEMENT ACTIVITY IN RESPONSE TO THE AUDIT FINDINGS By way of follow-up to the audits, ESV officers carried out assessments of the 9 solar installations that had been identified as non-compliant to confirm the defects. The RECs who were responsible for those installations have now been directed to replace the AC switch with an appropriate DC switch. A sample of the letter that was sent to each REC concerned is attached as Attachment 2. The relevant RECs were directed to comply and to send a copy of the requisite certificate of electrical safety to ESV by 5 July As at the date of writing, ESV had received certificates documenting rectification of 7 of the 9 defective installations. 11 The LEIs involved in certification of the non-compliant installations will be required to undertake additional training in solar inspection requirements before they are able to inspect solar systems. The significant safety issue arising out of the audits is the possibility that about 10% of installed switches are AC and, accordingly, a potential fire risk. While the risk is very low, ESV has implemented the following measures to raise industry awareness and to improve the compliance of installation and inspection practices: 1. ESV held 3 seminars in April and May 2010 to give LEIs an opportunity to upgrade their technical knowledge of standards, including requirements applying to solar panel installations. About 160 LEIs attended the seminars. 2. Technical guidance and advice explaining correct procedures with respect to solar installations has been published in recent editions of energysafe magazine, which is sent to all electricians, RECs and LEIs in Victoria. 3. ESV is encouraging LEIs to participate in a course offered by RMIT in inspection of solar installations. 11 with the remaining 2 certificates being followed up. Page 12

13 MEDIUM AND LONGER-TERM MEASURES TO IMPROVE THE SAFETY OF SOLAR PANEL INSTALLATIONS As previously mentioned, the new Electricity Safety (Installations) Regulations 2009 require additional labelling in premises containing consumer generation systems, alerting emergency services and tradespeople to the location of isolation switches. ESV has set up a specialised working group to provide guidance and advice on training and the regulatory arrangements that will ensure the safe installation and operation of new and emerging technologies. The work of the group will include review of the standards and requirements associated with installation of solar panels (including review of the scope of prescribed electrical installation work as defined in the regulations). The title of the working group is the Sustainable and Emerging Technology Consultative Committee which comprises representatives from unions, electrical contractors and inspectors, solar installers and trainers, the electricity distribution businesses, fire authorities and ESV. Additional targeted audits are to be carried out later this year to assess the effectiveness of corrective actions and to inform the further work of the working group and the community. ESV is also offering more support to, and education of, solar installers and LEIs through the publication of appropriate guidelines and provision of technical advice with respect to solar PV installations. Page 13

14 RESPONDING TO THIS REPORT This report has highlighted the potential risks associated with incorrect installations of switchgear in solar PV installations. ESV has attempted to address the problem by requiring rectification of identified non-compliance. At a systemic level, ESV is attempting to address the situation implementing a range of measures designed to enhance industry awareness of applicable standards, improve work practices in relation to solar panel installations and to inform future audit activity. Comments are invited on any matters which stakeholders and interested parties consider require attention either now or in the context of the review of the safety regulation of the solar installation industry by the Sustainable and Emerging Technology Consultative Committee. Comments can be sent to: Neil Fraser Executive Manager, Electricity Installation & Equipment Safety tel: Page 14

15 ATTACHMENT 1 PV System Record of Inspection and Testing Certificate of Electrical Safety Number: Installation address: Occupiers name: Occupiers contact Tel: Mob: Inspectors Name Inspectors Licence Number Inspectors Signature Date of inspection Details of Inspection Initial inspection. Yes No Comments Is the installation a stand alone installation? Is the installation a grid connected installation? Risk Yes No Comments Has a risk assessment been completed? Have risk treatments been defined and put in place? Switchboard Yes No Comments Is there a main switch to isolate the (normal) incoming supply? Does the main switch incoming supply have a permanent label Normal Supply MAIN SWITCH? Is there a circuit breaker to act as a main switch to isolate the solar supply? Does the main switch solar have a permanent label Solar Supply MAIN SWITCH? If solar system is connected to a distribution board is the following sign on the main switchboard and all intermediate switchboards WARNING DUAL SUPPLY ISOLATE SOLAR SUPPLY AT DISTRIBUTION BOARD----? Page 15

16 Switchboard (cont) Yes No Comments Is the following sign permanently fixed to the switchboard WARNING Dual Supply Isolate both Normal and Solar Supplies before working on this installation? Is the following sign on the switchboard WARNING DUAL SUPPLY ISOLATE SOLAR SUPPLYAY AT DISTRIBUTION BOARD----? Is the following sign on the switchboard SOLAR ARRAY ON ROOF Open circuit voltage --- Short Circuit Current ----? Inverter Yes No Comments Is there a dc double pole isolator or circuit breaker at the inverter input? Is there an ac isolator at the inverter output? If the inverter is not adjacent to the switchboard, is location information provided. Passed test for anti islanding PV Array Yes No Comments Is there a dc isolator adjacent to the array Is this dc isolator accessible for ease of operation (not under unit). Manufactures details. Open circuit voltage. Short circuit current Cabling Yes No Comments Are LV dc cables clearly identified?. Other Yes No Comments Warning label attached to meter panel Warning label attached to conductors in pit Warning label attached to pillar Warning label attached at point of supply Page 16

17 ATTACHMENT 2 SAMPLE OF LETTER SENT TO REGISTERED ELECTRICAL CONTRACTORS Ref: [date] [recipient] Dear Solar Installation [address of premises] A recent audit conducted on behalf of Energy Safe Victoria (ESV) at [address] revealed that you installed an ac. isolator to the dc supply from a solar array. I am of the opinion that the electrical work carried out by you on or about [date] does not comply with Clause of AS/NZS 3000:2007, guidance to this can be found in Clause 4.3 of AS/NZS 5033:2005. Therefore I direct you under Section 45AB of the Electricity Safety Act 1998 to replace the ac isolator adjacent to the solar array with a suitably rated dc isolator. This must be done at no cost to the customer who will also be given a copy of this letter. If you fail to comply with this direction by the 30 June 2010 it is likely that you be prosecuted in the Magistrates Court RECTIFICATION NOTICE: TAKE NOTICE I direct [recipient] to carry out the following electrical repair work, 1/ To remove the ac switch adjacent to the solar array and replace it with a suitably rated dc switch. The switch at [address] must be repaired in accordance with this notice no later than the 30 June 2010 and a copy of the Certificate of Electrical Safety for that work must be provided to me no later than 5 July If you require any further information on this matter, please contact me on telephone [number]. Yours sincerely [name of ESV officer] ENFORCEMENT OFFICER ENERGY SAFE VICTORIA Page 17

18 SECTION 69 ELECTRICITY SAFETY ACT 1998 Rights of Review A person to whom a rectification notice is given under section 45AB of the Electricity Safety Act 1998, may apply to the Victorian Civil and Administrative Tribunal for review of that rectification notice. The application for review of this rectification notice must be made within 7 days after the latter of; a. the day on which this rectification notice was received by you, or, b. if under section 45 of the Victorian Civil and Administrative Tribunal Act 1998, the person requests a statement of reasons for the decision, the day on which the statement of reasons is given to the person, or the person is informed, under section 46(5) of that Act that a statement of reasons will not be given. Page 18

19 REFERENCES Arup, T. Concern rises on solar panel safety, The Age, 19 February Clean Energy Council, Clean Energy Australia Available at: olumnparagraphs/00/text_files/file13/clean%20energy%20australia% pdf. Clean Energy Council Fact Sheet, All About Solar Photovoltaic. Available at: ncolumnparagraphs/0/text_files/file24/solar%20photovoltaic%20fact% 20Sheet.pdf Hawthorne, M. & Murphy, M. Turning Off Solar, The Age, 27 February Page 19

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