Test and tag records: what the law requires and what to keep

Test and tag records requirements are simpler than most people expect. In every state and territory that uses the model Work Health and Safety (WHS) laws, a record of each test must show four things: who did the test, the date, the outcome and when the next test is due. It must be kept until the item is next tested, permanently removed from the workplace or disposed of. A tag on the equipment can be that record.

That's the legal minimum. It's not what a good test and tag business keeps. This guide separates what the law requires from what's recommended and what's common practice, then covers how long to keep each kind of record.

General information only, not legal advice. Requirements differ by state, territory and industry. Check the current WHS or electrical safety regulation where you work, AS/NZS 3760 and any client or contract requirements.

What the law requires in a test record

The rule sits in regulation 150 of the model WHS Regulations, which every state and territory except Victoria has adopted in some form (Safe Work Australia). SafeWork SA's summary of it is a clear example. A record of testing must specify (SafeWork SA):

• the name of the person who carried out the testing
• the date of the testing
• the outcome of the testing
• the date the next test is due

The record can be a tag attached to the equipment, but logbooks, a register or a computerised database can also be used. SafeWork SA lists an expiation fee of $144 for an individual and $720 for a body corporate for breaching the record rule.

The model Code of Practice, Managing electrical risks in the workplace, goes further than the regulation. It says a logbook or register gives a permanent record if tags are damaged or removed, makes internal audits easier and lets you record more detail. That's a recommendation, not a legal duty, but it's the reason most operators keep a register as well as tags.

RCD records

Residual current devices (safety switches) have their own rule. Under the model regulations, the person with management or control of the workplace must make sure RCDs are tested regularly by a competent person. A record of that testing, other than the daily push-button test, must be kept until the RCD is next tested or disposed of.

Where the rules are different

• Queensland. Test and tag rules for most workplaces come from the Electrical Safety Regulation 2013, not regulation 150. For most workplaces the tag is the record, and there are separate rules for hire equipment and amusement devices. Our Queensland test and tag requirements guide covers them section by section.
• Victoria. Victoria hasn't adopted the model WHS laws. WorkSafe Victoria says employers need to keep records of electrical safety maintenance programs, including any testing and tagging, and make them available for review and inspection (WorkSafe Victoria). Its guidance doesn't set a list of fields or a retention period.
• Construction and demolition sites. These follow AS/NZS 3012 and carry heavier record keeping. SafeWork SA's guidance, for example, says results must be kept on site or made available for audit, including a register of all equipment, a record of formal inspections and tests, a repair register and a record of all faulty equipment. RCD test results must be kept for at least five years, excluding daily push-button tests (SafeWork SA).

How long to keep test and tag records

Read the first row carefully. "Until the next test" means that, legally, last year's record can go once this year's test is done. Nothing in the regulation stops you keeping it longer, and there are good reasons to.

Why keep more than the legal minimum

This part is our recommendation, not a legal requirement. We'd keep each item's full test history for as long as the item is on the client's register, and keep it after that for at least as long as you keep your business records.

• Incidents. If someone is hurt by a piece of equipment, the first question is when it was last tested and what the result was. A history shows the item was tested on schedule, not only that it has a current tag.
• Tags don't last. They get painted over, peeled off or cut off when a lead is shortened. Without a register, a missing tag means a missing record.
• Trends. A history shows which items fail repeatedly, which sites are hard on equipment and where a shorter retest interval makes sense (our test and tag frequency guide covers how intervals are set).
• Disputes and audits. Insurers, head contractors and auditors often ask for more than a current tag. A register lets the client answer in minutes.
• Changing providers. When a client changes test and tag providers, a complete history means nothing is lost.

What a good test and tag register holds

The four legal details are the floor. In practice, a register worth keeping holds the following for each item:

• client, site and location (building, floor or room)
• an asset ID that matches the number on the tag
• description, make, model and serial number
• equipment class (Class I, Class II, cord set, RCD and so on)
• the retest interval and why it was chosen

And for each test:

• date, tester's name and outcome (pass or fail)
• the readings, such as earth continuity, insulation resistance or leakage current
• the next due date
• for a failure, the fault and what happened next: repaired, replaced or disposed of, and by whom

Many operators also record the tester (instrument) used and its calibration date, so they can show which results came from which instrument. That's common practice rather than a legal rule. If you're starting from a spreadsheet, our guide to moving a test and tag register off spreadsheets shows how to bring this history across without retyping it.

Who is responsible for the records?

The duty sits with the business that has the equipment: the person conducting a business or undertaking (PCBU) under the WHS laws. As the test and tag provider, you create the records, but your client is the one who has to keep them and produce them for an inspector.

So agree in your quote or service agreement what you hand over after each visit (a certificate, a full register or both) and in what format. Then keep your own copy. If a client loses theirs, or a question comes up two years later, you'll want to answer it from your own records.

Paper, spreadsheet or software?

Any format that holds the required details is acceptable. The differences are practical:

• Paper logbooks are easy to start with, but hard to search, easy to lose and impossible to share across sites.
• Spreadsheets are searchable, but they're easy to overwrite, often exist in several versions and don't remind anyone when items are due.
• Test and tag software keeps one register per client and site, builds each item's history as you test and works out due dates. Check that you can export your data to a standard format such as CSV. The ATO says the same about tax records you store digitally: it must be able to extract them into a standard format.

Whatever you use, back it up and make sure records can't be quietly changed after the fact.

Common record-keeping mistakes

• Relying on tags alone. It meets the legal minimum, but a lost tag is a lost record.
• Overwriting the last result. A spreadsheet row that only holds the latest test throws away the history.
• Leaving out failed items. An item that failed and was disposed of still needs its record and what happened to it.
• Asset IDs that don't match the tag. If the tag says 0412 and the register says "kettle, kitchen", nobody can prove which kettle was tested.
• No copy for the client. The client carries the legal duty, so make sure they have the records, not only you.

Keeping records with Koalaris

Koalaris keeps an equipment register for every client and site, and every test you record in the field app, even offline, adds to that item's history. Tags and certificates come from the same results, so nothing is typed twice. Your clients can see their own register, history and certificates in a free client portal, and you can export your register to CSV at any time. See the full list on the Koalaris features page. The Solo plan is $29 a month, and every new business gets a 14-day trial with no card needed.

Frequently asked questions

Is a test tag enough of a record?

Under the model WHS Regulations, yes, if the tag shows who did the test, the date, the outcome and the next due date. If the tag can't fit all four, the rest must be recorded elsewhere. A register is recommended because tags get damaged or removed.

How long do you have to keep test and tag records?

In states and territories using the model WHS Regulations, until the item is next tested, permanently removed from the workplace or disposed of. Some situations need longer. Construction site RCD results are an example: SafeWork SA's guidance says to keep them for at least five years. Many businesses keep full history for longer as good practice.

Who has to keep the test and tag records, the client or the tester?

The legal duty is on the business that owns or controls the equipment. The test and tag provider creates the records and should give the client a copy, and most providers keep their own copy too.

Can test and tag records be kept electronically?

Yes. The regulations allow a logbook, register or computerised database as well as a tag. Make sure it holds the required details, is backed up and can be exported.

Do I need to keep records of failed items?

The test record covers every test, pass or fail. On construction sites, guidance also calls for a repair register and a record of faulty equipment. Elsewhere, recording what happened to a failed item is good practice and protects you and your client.

Does Victoria require test and tag records?

WorkSafe Victoria says employers need to keep records of electrical safety maintenance programs, including testing and tagging, and make them available for review and inspection. Victoria hasn't adopted the model WHS Regulations, so regulation 150's list of details doesn't apply there directly.