v3.0
Authorisation of Independent Connection Providers (ICPs) Craftsperson’s by UK Power Networks
OwnerName / Jason Carmichael
Title / Head of Technical Training
Signature
Date / 18th October 2017
Authoriser
Name / Simon Tapp
Title / Lead Operational Assessor
Signature
Date / 18th October 2017
This document forms part of the UK Power Networks Integrated Management System and compliance with its requirements is mandatory. Departure from these requirements may only be taken with the written approval of the above authoriser.
Revision RecordVersion number / 3.0 / What has changed?
No change to document but Owner and Authoriser changed.
Why has it changed?
Document Reviewed.
Date published / 26/10/2017
Next review date / 31/10/2019
Prepared by / Simon Tapp
Version number / 2.0 / What has changed?
ICP Authorisation options.
Why has it changed?
UKPN would prefer to use Option 1 for connections activity and Option 2 for operational activity, but will make all authorisation option available to all ICP’s to suit the ICP’s preferences.
Date published / 10/10/2016
Next review date / 01/08/2017
Prepared by / Terry Siemers
Version number / 1.0 / What has changed?
The issue of a Competition in Connections Code of Practice
Why has it changed?
New Code of Practice
Date published / 25/08/2015
Next review date / 17/08/2016
Prepared by / Terry Siemers
Who needs to know?
☒ All UK Power Networks Staff
☒ Asset Management
☒ Capital Programme
☒ Connections
☒ Contractors
☐ Customer Services
☒ Finance
☐ Legal
☒ G81 External website
☐ HR & Communications
☒ SHE&TT
☒ In Business HSS
☒ Safety Reps
☒ ICPs (Independent Connection Providers)
☒ IDNOs (Independent Distribution
Network Operators)
☐ Information Systems
☐ Meter Operators / ☒ Network Operations
☒ EPN
☒ LPN
☒ SPN
☒ Distribution Capital Delivery
☐ Logistics
☒ Network Control
☒ Network Operations Connections
☐ Transport Services
☒ Strategy and Regulation
☐ UK Power Networks Services
☐ Airports
☐ Rail
☐ Strategic projects
☐ HS1, DLR & Commercial buildings
☐ MUJV / Allenby
☐ Business Development
☐ Others (specify)
Contents
1.0 Introduction 3
2.0 Scope 3
3.0 Objective 3
4.0 References 3
5.0 Definitions 4
6.0 Responsibilities 4
6.1 CiC Operational Liaison Engineer 4
6.2 Accreditation Development Manager 4
7.0 Records 5
8.0 Process Detail 5
8.1 Review Of Our Process Before The Introduction Of The CiC CoP 5
8.2 The Process in brief before the introduction of the CiC CoP: 5
8.3 Short-falls within our process before the introduction of the CiC CoP 6
8.4 Risks 6
8.5 Benefits 6
9.0 Our Process Following The Introduction Of The CiC CoP 7
9.1 Lloyds Accreditation 7
9.2 National Electricity Registration Scheme (NERS) 8
9.3 Request for familiarisation assessment 8
9.4 Inspection and Monitoring 8
9.5 Non-Conformity Management 8
10.0 Appendix A 10
1.0 Introduction
On 21st January 2015 The Office of Gas and Electricity Markets (OFGEM) published
a document (‘The Findings of our review of the electricity connections market’) following
a review of the market for new connections to the electricity distribution network which described what they found and intended to do to improve competition.
One of the review findings was to introduce a new condition into the electricity distribution licence which will require all Distribution Network Operators (DNOs) to comply with a Code of Practice (CoP).
OFGEM approved the Competition in Connections (CiC) CoP in July 2015.
With the issue of the CoP which sets out the processes and practices that DNOs will follow to facilitate competition it has been necessary for UK Power Networks (UKPN) to undertake a review of the CoP content and put into place any necessary process changes required.
This document looks at two elements within the CoP, the Accreditation and Authorisation
of Craftsperson’s working on behalf of an ICP on the UKPN distribution networks.
The goal of this document is to codify the established and developing arrangements between DNOs and ICPs for facilitating the effective operation of competition in the market for the provision of Connections. In doing so it addresses the issues OFGEM has identified
in its review of the Connections market in relation to Accreditation and Authorisation of craftsperson’s working on the behalf of an ICP on the UKPN distribution networks It also seeks to foster the same high standards of performance by all relevant parties in the harmonisation of processes across DNOs to help foster competition.
2.0 Scope
Included in the scope are specific areas of the CiC process that have previously been identified by OFGEM as requiring inclusion in the CoP, the areas covered in this document are Accreditation and Authorisation of craftsperson’s working on the behalf of an ICP on the UKPN distribution networks.
3.0 Objective
To ensure that our current policies, procedures and practices align with the CiC CoP and do not distort, prevent or restrict competition in the market for new electrical distribution connections.
4.0 References
Energy Network Association document / Competition in Connections Code of PracticeLloyds Register Energy / Scope Guidance v3.0 July 2014
Lloyds Register Energy / UK utility schemes
HSS 41 006 / Assessment and Accreditation of Independent Connection Providers
HSS 02 004 / Audit, Inspection and Monitoring of Networks Connections Providers
5.0 Definitions
CiC / Competition in ConnectionsCoP / Code of Practice
ENA / Energy Networks Association
HSE / Health and Safety Executive
ICP / Independent Connections Provider
IDNO / Independent Distribution Network Operator
NERS / National Electricity Registration Scheme
Ofgem / The Office of Gas and Electricity Markets
LoA / Letter of Acceptance
SMS / Safety Management System
LMS / Learning Management System
SORN / System Operations Reference Numbers
UKPN / UK Power Networks, including the three licensed areas Eastern Power Networks (EPN) South Eastern Power Networks (SPN), and London Power Networks (LPN).
6.0 Responsibilities
6.1 CiC Operational Liaison Engineer
To manage the process by which an ICP Craftsperson is enabled to work on the UKPN distribution network.
To ensure that;
· The ICP has effective SMS’s and Safety Rules
· The Craftsperson’s nominated by an ICP have been trained and are competent and NERS accredited.
· The Craftsperson’s nominated by an ICP fulfil the requirements of HSS 41 006
· The quality of work that UKPN adopts is of a suitable standard.
· There is a clear communication of responsibilities
· By management of the System Operations Reference Numbers (SORN) the staff scheduled to carry out work on the UK Power Networks network have been appropriately assessed and appointed
· Forward any network Familiarisation requests to the Accreditation Development Manager.
6.2 Accreditation Development Manager
To ensure that;
· Any network familiarisation requests are facilitated in a timely manner.
7.0 Records
Both the ICP and UKPN will record and store for future reference all the policies, operational processes, certification, local information, procedures and briefing notes exchanged to facilitate safe working on the UKPN distribution system.
UKPN will store its exchanged information, both issued and received within the Learning Management System (LMS)
All auditing, inspection and monitoring information will be held and recorded as stated in HSS 02 004 Audit, Inspection and Monitoring of Networks Connections Providers.
8.0 Process Detail
8.1 Review Of Our Process Before The Introduction Of The CiC CoP
ICPs carry out works on our network that are not for or on behalf of UKPN, but are adopted by UKPN.
Each ICP employee has a letter of acceptance (LoA) from UKPN (rather than a UKPN Certificate) which essentially allows him or her to work on our distribution network.
ICPs are National Electricity Registration Scheme (NERS) accredited and monitored by Lloyds Register so, in practice we should be able to allow the nominated craftsperson’s to work on our network without any problems.
Any ICP nominated craftsperson’s who already holds a current, relevant UKPN Certificate of Competence is automatically issued with a LoA for the type of work his or her company wishes him or her to carry out. When given the LoA the recipients are reminded that there is a distinction between working for UKPN and an ICP.
In the case of someone who has never worked on UKPN distribution network, or who has worked on it but longer than twelve months ago they are invited to attend a Familiarisation session. There are Familiarisation sessions for Live Extension of LV Services, Live Connection to LV Mains, LV Cable ID, HV Jointing and Jointer’s Mate.
The main purpose of these sessions is to familiarise them with safety requirements, types of material and joints etc. used by UKPN. This is done by giving the candidates a combination of joints to carry out appropriate to each category. During this Familiarisation they are also made aware of any cable/system types likely to cause hazard (e.g. Triple Concentric Cable). There is no formal interview.
Over the past few years we have undertaken Familiarisation sessions on Craftsperson’s with differing levels of skills, so in the interests of the candidates, those who were unable to demonstrate good abilities were denied a LoA until they had gained further experience, safety information and were then able to demonstrate at another Familiarisation session a better ability and attitude to safety.
Similarly, there has been a variation in the responsibility, attention to detail and safety systems exhibited by the ICP companies.
8.2 The Process in brief before the introduction of the CiC CoP:
Applications for work to be carried out including names of proposed craft operatives are passed to CIC and as part of the process they filter out those who hold Competence Certificates from those without and request LoA for the Certificate holders and Familiarisation sessions for the others.
One or two days per month have been held in reserve for Familiarisations to be carried out by our Craft Assessor.
Candidates are invited to attend one of those sessions.
Once assessments are satisfactorily completed appropriate LoA are issued to the ICP for each individual.
Scheduled work can then be carried out.
8.3 Short-falls within our process before the introduction of the CiC CoP
An inconsistent approach compared against other DNOs
ICP may experience delays in being invited to a Familiarisation session.
Extra inconvenience incurred by the ICP waiting for LoA
Resentment by ICPs because they thought the process an unnecessary step.
8.4 Risks
OFGEM sought to promote competition in the provision of connections as part of the Distribution Price Control Review for the period 2010-15 (DPCR5) and undertook a review of these measures in January 2015 concluding that there were inconsistencies between DNOs in how they manage the connections process.
In setting out its proposed remedy OFGEM summarised…we think there is sufficient evidence to show that there are behavioural changes that can be made by the DNOs that could resolve the issues identified without the need for structural reform.
We have made the necessary changes set out in this document to ensure we fully meet the requirements of the CoP for CiC; however, the possible alternatives do not come without their own risks. For example, there is the risk of injury or worse to members of the public, those that work for UKPN and the ICP staffs themselves if there is not a sufficient degree of control to ensure the competence of that craftsperson’s accepted to work on the network.
The as-is process that UKPN currently uses to accept the competence of ICP Craftsperson’s to work on the distribution network is very similar to how it determines the competence of its own staff and contractors. However, the new to-be process option 1 of the CiC CoP requires the ICP to ensure that those they are nominating to work on the network have the necessary competence and experience.
The to-be process will use NERS to check competence and to mitigate against any risks UKPN will implement a to-be process that balances a sufficient degree of control to ensure competence that at the same time is harmonised with the CoP.
8.5 Benefits
Potential for harmonisation with other DNOs,
Compliance with the CiC CoP,
Improved co-operation between ICPs and UKPN,
Reduced start up times for the ICPs,
Reduced clerical time and costs for UKPN.
9.0 Our Process Following The Introduction Of The CiC CoP
UK Power Networks prefers to authorise an ICP’s Craftsperson using option1 of the CiC CoP under part C 5.2.1 ICP Authorisation of ICP Employees and Contractors
ICPs shall operate under their own Safety Management System (SMS), including the ICP’s own Safety Rules, which shall be of an equivalent relevant standard to the DNO’s (in all cases the SMS should align to OHSAS18001 or equivalent).
ICPs are responsible for determining the relevant competence requirements for the work to be undertaken and for the issue of an appropriate authorisation to their employees or contractors. The relevant competence requirements shall include any network specific issues identified by the ICP following consultation and communication with the DNO on whose Distribution System the work is to be carried out.
ICPs shall provide if requested details of their SMS to the DNO before first accessing the DNO’s Distribution System.
ICPs shall thereafter provide, when required, reasonable information regarding their ongoing SMSs to a requesting DNO.
The DNO will be entitled to carry out reasonable checks on the application of the relevant SMS to demonstrate so far as reasonably practicable to the HSE (or other interested parties) that safety assurance is in place for any ICP working on its Distribution System.
Either party shall make available to the other relevant policies, operational processes, local information and procedures as required to facilitate safe working on a DNO’s Distribution System. This may be in writing or by personal briefing as may be appropriate, but in all cases the information exchanged shall be recorded and such records must be held for future reference by each party.
(See flow chart Appendix A page 10)
Whilst UK Power Networks would prefer to use Option 1 for “connections activity’ we will
work together with any ICP to develop and agree effective arrangements for any alternative