What do I need to know about Supplier Declarations of Conformity (SDoC)?
Series of FAQs explaining what an SDoC is, why they are important to electrical workers, what information should be contained in them and what electrical products require an SDoC.
Why are SDoC important to me?
When an Electrical Worker (EW) has issued a Certificate of Compliance (CoC) or Electrical Safety Certificate (ESC) for an installation, they are accepting legal responsible and liability for the electrical safety of the fittings and equipment (products) they have installed. Citing SDoC for declared medium risk articles (DMRA) on a CoC shifts the primary liability for any unsafe DMRA fittings or products back to the supplier.
An SDoC can only reasonably be used by an EW, if they are acting in good faith. If an EW is aware something is not right or has reasonable concerns about the compliance or safety of a fitting or appliance they are asked to install, under their registration they are expected to refuse to install, until they can be satisfied that the compliance or safety is satisfactory.
It does not however remove the EW’s responsibility or liability if the installation of the product was the cause of the fault and it was not installed in accordance with manufacturer’s instructions.
What is an SDoC and who can issue them?
An SDoC is a legally recognized document containing mandatory information including a formal declaration in a prescribed format. This can be used to verify the product complies with the required recognised standards and is therefore safe to install and use in NZ.
A recognised SDoC can only be made by a NZ importer or the NZ manufacturer of the article. Declarations from overseas have no status and should be treated with extreme caution. If they prove to be invalid, the EW and the product suppliers, will be held jointly responsible not the overseas declarer.
Do I have to cite SDoC on my Certificate of Compliance (COC)?
It is not mandatory to cite SDoC on CoCs, however you need to be aware that by not doing so you are liable for the electrical safety of the product.
If you have any doubt about the quality, safety, origin or compliance with NZ standards of any electrical fitting or equipment either don’t install it, or request a valid SDoC and manufacturers’ instructions and reference these on the certification.
Are SDoC mandatory for all electrical products?
No, only products that have been assessed as medium level of risk which are referred to as declared medium risk articles (DMRA) require a valid SDoC prior to sale.
How do I know which products require an SDoC?
A legally recognised SDoC is only required in for a DMRA as referenced in Electrical (Safety) Regulations 2010 (ESR) Regulation 83(external link). Currently Gazetted DMRA’s are listed on the WorkSafe website medium risk products(external link). The list of DMRA’s is subject to review and the website should be checked regularly for possible updates.
Why are some medium risk products also classed as high risk?
Because these products have been assessed to pose greater safety risks, in addition to having an SDoC, they also need approval from WorkSafe or a recognised agency.
Some products are classified as declared high risk articles (DHRA) under ESR Regulation 84(external link).These are required to be fully type tested to a cited safety standard by a legally recognised electrical testing laboratory and in addition have a legally recognised approval.
As evidence of recognised approval is not legally required to be available to any enquirer, all DHRA’s are also currently DMRA’s requiring an SDoC.
Legally an SDoC must be supplied by a NZ supplier of a DMRA with 10 days of a request being made by anyone in NZ. As the DHRA is also a DMRA, it is normal practice for the SDoC to cite the approval or certification recognised as an approval, as the supporting documentation for the SDoC being made.
Can SDoC be used for products that don't legally require them?
Although any voluntary SDoC’s made for non-DMRA’s are not deemed to be evidence of electrical safety by ESR Regulation 83(3A)(external link), they can be used as reasonable evidence of due diligence by an EW, if they declare compliance with a cited safety standard. If there is no relevant cited safety, an international safety standard such as an IEC can be used provided the product declared ratings are compatible for the standard NZ supply to which it will be connected.
Can a product which requires an SDoC be sold without one?
No, nor can it be offered for sale.
What information should be on an SDoC
- A description of the declared medium risk article
- Contain a statement that the article complies with the appropriate standard listed in Schedule 4(external link) of the Electricity (Safety) Regulations or AS/NZS3820; or the Conformity Cooperation Agreement and be in the form that is prescribed by WorkSafe, / comply with ISO/IEC17050–1.
SDoC have a reference to test reports, do I need to have copies of these as well?
No, as along as the test reports are referenced on the SDoC. The test certificate with the report confirms its compliance. However on request the full test reports must be made available and produced by the issuer of the SDoC.
Apart from using an SDoC is there any other way of confirming medium risk products are compliant with NZ required regognized standards and where can I find out more about this?
Authoritative information on this is available from this link on the WorkSafe / Energy Safety website(external link).