Regulatory application of AS/NZS 4777 - Grid connection of energy systems via inverters
WorkSafe has been asked to advise on the application of AS/NZS 4777.2:2015 Grid connection of energy systems via inverters - Part 2: Inverter requirements as it applies to the supply and installation of inverters in photo-voltaic installations. Specifically, when do the requirements of the latest version of this Standard apply?
The Electricity (Safety) Regulations 2010(external link) directly cite AS 4777.1-2005 Grid connection of energy systems via inverters - Installation requirements in addition to AS/NZS 3000 Electrical installations for the safe installation of low voltage mains parallel generation systems (including photo-voltaic systems) connected to the national grid. AS/NZS 3000 refers to the AS 4777 series for the selection and installation of grid connected inverter systems.
The AS 4777 series has recently been revised. AS/NZS 4777.1:2016 Grid connection of energy systems via inverters - Installation requirements supersedes AS 4777.1-2005. AS/NZS 4777.2:2015 supersedes both AS 4777.2-2005 and AS 4777.3-2005.
When the Government makes Regulations they are issued at a particular time.
What is implemented, including any referenced Standards, is agreed at that time to form the law.
No matter what happens after that, unless the Regulations specifically say otherwise, the law, including references to standards, doesn’t change unless the Regulations are formally amended.
The Government of New Zealand does not delegate the Regulation making process to a Standards committee, or the Standards process.
So simply, at the date the Regulations are agreed the documents are locked. Whatever the documents say about progression means nothing unless the Regulations specifically state what applies. If you look at Schedules 2 and 4 you will find a few examples of this.
For a Standard cited by AS/NZS 3000, which itself is cited by the Regulations, what applies until the Regulations are updated, is what applied at the time the Regulations were made.
So until the Regulations are amended, the latest version is not implemented by the Regulations.
The regulations do allow an alternative that can be applied for non-domestic installations which are designed to Part 1 of 3000. In this case a certified design is needed, and the designer takes responsibility for safety and compliance with Part 1.
There is no restriction therefore to apply the latest version voluntarily through a certified design where Part 1 may be applied. In such cases the latest version is in effect the certified design and the design certifier is included in the allocation of responsibilities and liabilities.
This does not prevent any party specifying compliance with the latest version of AS/NZS 4777.1 or AS/NZS 4777.2, however such a specification would very likely be interpretable as a certified design.