Arctic or HO7RN-F extension lead?

[ericmark]

I have not re-read Part P, but seem to remember when it first came out it was said an extension lead only needed notifying if fixed. But that was some time ago.

As if not fixed it still needs notifying it would mean every time you mow the lawn there would be another fee.

 

[JohnW2]

I have not re-read Part P, but seem to remember when it first came out it was said an extension lead only needed notifying if fixed. But that was some time ago.

Part P (the one sentence of), which has not changed (in either England or Wales) since its inception in 2004/5 says nothing about such things.

However, as I quotes in post#56, the version of Approved document P (not, in itself, 'law') relevant to Wales says that the installation of any item of 'fixed equipment' is within the scope of Part P (hence, presumably, notifiable if it is in a kitchen in Wales) even if it is connected via a 13A plug/socket.

It therefore comes down to the definition of "fixed equipment". I know you have your own ideas about this (based on 'portability', weight, wheels etc., as well as literally 'fixed'), although I don't know where that comes from, and the nearest that the Building Regulations (of which "Part P" is 'part") get to a definition is:

"fixed building services” means any part of, or any controls associated with—
(a) fixed internal or external lighting systems, but does not include emergency escape lighting or specialist process lighting; or
(b) fixed systems for heating, hot water, air conditioning or mechanical ventilation;

... but that's a definition of "fixed building services", not "fixed equipment". So who knows?!

As if not fixed it still needs notifying it would mean every time you mow the lawn there would be another fee.

If the law (together with Approved Doc P) is taken literally, as written, it can certainly be read in a fashion which makes it pretty crazy in (a kitchen in) Wales. Taken literally, it would seem that, even without an extension lead, it can be argued that 'installing' an item of "fixed equipment" by plugging its lead directly into a 13A socket in a Welsh kitchen might be notifiable - which is plain daft. I have electrical items in my kitchen which are literally 'fixed' (screwed to the wall) and plugged into 13A sockets, and for that 'plugging in' to be notifiable would be absolutely crazy.

Maybe I'm glad that I live in England

Kind Regards, John

 

[EFLImpudence]

As we (nearly) all know Part P has nothing to do with notification.

It states:

That's it.

Definitions:
"Electrical installation (abbr: Installation). An assembly of associated electrical equipment having co-ordinated
characteristics to fulfil specific purposes."

and Approved Document P is guidance so virtually irrelevant.


Notification in Wales is still subject to Schedule 4 which only states what is NOT notifiable:
https://www.legislation.gov.uk/uksi/2010/2214/schedule/4/made

"1. Work consisting of—
(a)replacing any fixed electrical equipment which does not include the provision of—
(i)any new fixed cabling, or...

(b)replacing a damaged cable for a single circuit only;"

 

[JohnW2]

As we (nearly) all know Part P has nothing to do with notification.

Quite so, but as I have been trying to explain to eric, although he persists in talking about 'Part P', it is, in fact, 'part' of the Building Regulations - which (as you go on to explain, do have a lot to say about notification (in general and, specifically, in relation to electrical work).

Definitions: "Electrical installation (abbr: Installation). An assembly of associated electrical equipment having co-ordinated characteristics to fulfil specific purposes."

That's the BS7671 definition and so is not really relevant to 'Part P', or to any other 'part' of the Building Regulations. The definition in the Building Regs is:

“electrical installation” means fixed electrical cables or fixed electrical equipment located on the consumer’s side of the electricity supply meter;

- but that begs the question about the definition of "fixed electrical equipment" and, as I wrote to eric, the nearest the Building Regs get to a definition is one of "fixed building services", which is not really the same.

... and Approved Document P is guidance so virtually irrelevant.

One might call it 'virtually irrelevant' but the problem is that we have to choose between pure guesswork and that 'guidance' (which one assumes was produced by, or in consultation with, the legislators). The Building Regs themselves are silent on the question of whether or not equipment connected via a 13A plug/socket is within the scope of the regulations (hence within the scope of 'Part P' and of the notification requirements) - so we either have to guess about that or rely on the 'guidance' in the Approved Doc.

Notification in Wales is still subject to Schedule 4 which only states what is NOT notifiable:
.... "1. Work consisting of—
(a)replacing any fixed electrical equipment which does not include the provision of—
(i)any new fixed cabling, or...
(b)replacing a damaged cable for a single circuit only;"

Indeed, and that's where (depending upon one's understanding of the meaning of "fixed electrical equipment") the situation in Wales could become silly (crazy?). In my kitchen, I have a number of electrical items which would seem to be very 'fixed' (firmly screwed to walls) and which are powered by being plugging into 13A sockets (A TV and a Dustbuster charging cradle come immediately to mind). There is no doubt that they are "electrical equipment" and, at least in terms of everyday language, are 'fixed' - so, if, rather than guessing, we took note of the guidance in approved Doc P, we could easily end up concluding that, were I in Wales, the 'installation' of those items (including 'plugging them in') would be notifiable- which would surely be crazy!

It's tempting to suggest that the legislation was not 'properly thought through', but I'm not sure what else they could have done (if they wanted to 'single out' kitchens). Had the Building Regs explicitly excluded things plugged into 13A sockets, that would have opened potential 'loopholes' (banks of 13A sockets just outside of a kitchen, feeding everything within the kitchen ). The underlying silliness is, I suppose, in singling out kitchens for special treatment.

Kind Regards, John .

 

[EFLImpudence]

That's the BS7671 definition and so is not really relevant to 'Part P', or to any other 'part' of the Building Regulations. The definition in the Building Regs is:

Ah, fair enough.

One might call it 'virtually irrelevant' but the problem is that we have to choose between pure guesswork and that 'guidance'

W - e - l - l

Guidance is just that - guidance - and presumably not definitive, so one must follow the actual law and make up one's own mind.

(which one assumes was produced by, or in consultation with, the legislators).

Never assume.

Why would the legislators, in such a consultation, not have decided to make the law clear thus negating the need for guidance.

 

[JohnW2]

W - e - l - l .... Guidance is just that - guidance - and presumably not definitive, so one must follow the actual law and make up one's own mind.

As I said, when 'the actual law' is silent on a matter, one either ha to guess or else take note of some external source of guidance - and, although you (rightly) say that it is just an assumption, it seems fairly reasonable to 'assume' (again!) that those who wrote Approved Doc P had more reason to know what was probably the 'intended' interpretation of the legislation then have you or I.

Why would the legislators, in such a consultation, not have decided to make the law clear thus negating the need for guidance.

You'd have to ask them, but one has to accept that it's virtually impossible for any legislation to be 'comprehensive', and nor is it really practical to revise legislation every time someone thinks of something it does not adequately explicitly address.

Anyway, if you want to ignore the guidance in the Approved Doc, and if you were in Wales (since it doesn't really make any difference in England), then what would you guess about the interpretation of the legislation 'as it is'? Would you guess that anything 'fixed' (e.g. screwed to the wall or floor) was within the scope of the legislation, even if it was powered via a 13A plug/socket, OR would you guess that anything supplied via a 13A plug/socket was not within the scope of the legislation?

Kind Regards, John

 

[ericmark]

Indeed, and that's where (depending upon one's understanding of the meaning of "fixed electrical equipment") the situation in Wales could become silly (crazy?). In my kitchen, I have a number of electrical items which would seem to be very 'fixed' (firmly screwed to walls) and which are powered by being plugging into 13A sockets (A TV and a Dustbuster charging cradle come immediately to mind). There is no doubt that they are "electrical equipment" and, at least in terms of everyday language, are 'fixed' - so, if, rather than guessing, we took note of the guidance in approved Doc P, we could easily end up concluding that, were I in Wales, the 'installation' of those items (including 'plugging them in') would be notifiable- which would surely be crazy!

Yes agree crazy, I am not sure about Part P in Wales, it was written by the English, before devolution, and I have not looked to see if there is a Welsh version, BS 7671 is not technically valid in Wales as no Welsh version. Yes I know it is daft, and likely any court would say it does not matter, it is down to being safe.

And this is the point of course, if some one does unsafe work, then Part P or not they are going to be prosecuted if some one is injured, and if the work is safe, it is unlikely any court case will follow. The Part P makes it easy for some one who does unsafe work to be taken to court.

It is like the FCU, and does fitting one result in a new circuit, if the circuit it is fed from is the final circuit then can't really form another circuit. Like many English phase and word "Very end", "worser" etc.

 

[JohnW2]

Yes agree crazy, I am not sure about Part P in Wales, it was written by the English, before devolution, and I have not looked to see if there is a Welsh version, BS 7671 is not technically valid in Wales as no Welsh version. Yes I know it is daft, and likely any court would say it does not matter, it is down to being safe.

At best this is a technicality which, as you say, Courts would undoubtedly over-ride by common sense - but I'm also uncertain about this belief that legislation and regulations are only 'valid' in Wales if they exist in the Welsh language. There is surely a vast amount of UK law (and probably many 'regulations' as well) which is still applicable in Wales, but which has never existed in the Welsh language.

In any event, in relation to BS7671 (since you mention it!), as you often tell us, the infamous Approved Doc P says that compliance with part P can be demonstrated by compliance with BS7671 OR "an equivalent standard approved by a member of the EEA" - which I presume would not even be in English, let alone Welsh!

And this is the point of course, if some one does unsafe work, then Part P or not they are going to be prosecuted if some one is injured ...

I don't really understand why we have to remind you so often that "Part P" relates to all electric work, and requires all electrical work to be done safely, even in it is not notifiable in either England or Wales

It is like the FCU, and does fitting one result in a new circuit ...

I think that we 'know' that it was an oversight on the part of those who wrote the notification rules (for England) not to explicitly state that adding to an existing circuit via an FCU did not count as 'creating a new circuit' - not the least because we definitely know that, even in Wales (where very little is not notifiable) extending an existing circuit via an FCU is explicitly not notifiable.

Kind Regards, John

 

[EFLImpudence]

As I said, when 'the actual law' is silent on a matter, one either ha to guess or else take note of some external source of guidance

Surely if the law is silent on a matter then it does not apply to that matter.

- and, although you (rightly) say that it is just an assumption, it seems fairly reasonable to 'assume' (again!) that those who wrote Approved Doc P had more reason to know what was probably the 'intended' interpretation of the legislation then have you or I.

Not necessarily. It might be no different than NICEIC publishing their interpretation of the law.

You'd have to ask them, but one has to accept that it's virtually impossible for any legislation to be 'comprehensive', and nor is it really practical to revise legislation every time someone thinks of something it does not adequately explicitly address.

Anyway, if you want to ignore the guidance in the Approved Doc, and if you were in Wales (since it doesn't really make any difference in England), then what would you guess about the interpretation of the legislation 'as it is'? Would you guess that anything 'fixed' (e.g. screwed to the wall or floor) was within the scope of the legislation, even if it was powered via a 13A plug/socket, OR would you guess that anything supplied via a 13A plug/socket was not within the scope of the legislation?

I would say the wording does actually state that.

However, screwing one's television set to the wall or one's kettle base to the worktop or a shelf would obviously not mean you had to notify the L.A.

Using BS7671 definitons:

"Electrical equipment (abbr: Equipment). Any item for such purposes as generation, conversion, transmission,
distribution or utilization of electrical energy, such as machines, transformers, apparatus, measuring instruments,
protective devices, wiring systems, accessories, appliances and luminaires."

"Fixed equipment. Equipment designed to be fastened to a support or otherwise secured in a specific location."

"Mobile equipment (portable equipment (deprecated)). Electrical equipment which is moved while in operation or which can easily be moved from one place to another while connected to the supply."

 

[flameport]

All electrotechnical definitions are available here: https://www.electropedia.org/
and if they are not there, you are on your own.

 

[ericmark]

"Electrical equipment (abbr: Equipment). Any item for such purposes as generation, conversion, transmission,
distribution or utilization of electrical energy, such as machines, transformers, apparatus, measuring instruments,
protective devices, wiring systems, accessories, appliances and luminaires."

“equipment” includes plant, meters, lines, supports, appliances and associated items used or intended to be used for carrying electricity for the purposes of generating, transmitting or distributing energy, or for using or measuring energy;

“consumer’s installation” means the electric lines situated upon the consumer’s side of the supply terminals together with any equipment permanently connected or intended to be permanently connected thereto on that side;

We tend to split equipment into two groups, the current using equipment normally tested with the inspection and testing of in service electrical equipment, which for some reason does not include the lights? and the electrical installation condition report.

Either way all items should be tested and inspected, be it a maintenance contract, EICR, PAT test or other. Any item deemed as not safe should be put into quarantine or locked off, the whole idea of saying some thing is not safe but not locking off seems fundamentally wrong.

It seems a little pointless arguing about the English, and the EICR was altered some years back, and code 4 was removed as being unhelpful, the owner does not need to know if it complies with current regulations, all he wants to know is it safe.

If we were to follow the regulations then there is little point in this forum, as few DIY people have the knowledge or equipment to install electrical equipment to the letter of the regulations.

This is a DIY forum and we and I include myself have gone OTT with this discussion.

 

[EFLImpudence]

What has that to do with whether something is notifiable or not?

 

[JohnW2]

Surely if the law is silent on a matter then it does not apply to that matter.

It's not as simple as that. If 'the matter' is important (e.g. in current context, in determining the scope of legislation), then one has to make some decision, even if the legislation is silent on the matter - be that decision based on guesswork, 'guidance' or whatever.

Not necessarily. It might be no different than NICEIC publishing their interpretation of the law.

As I've said, given that one has to have some basis for one's decision/interpretation, I think it is reasonable to say that a document published by the government, with the explicitly expressed purpose of providing guidance on how to omply with the government's own legislation is more relevant than is the opinion/interpretation of any 'third party' individual or organisation, isn't it?

I would say the wording does actually state that.

The wording of what? Nothing in 'the law' (Part P, or any other 'part' of the Building Regs - only App Doc P, which you ignore) says anything about whether or not things connected via plugs/sockets are within its scope - and, as I've said, there are definitions (in the Building Regs) which give any useful clarification.

However, screwing one's television set to the wall or one's kettle base to the worktop or a shelf would obviously not mean you had to notify the L.A.

It may be 'obvious' in terms of common sense, but what 'actual wording' (in the Building Regs) says that (in relation to Welsh kitchens)?

A 'blanket' interpretation (such as you appear to have) that anything connected via a 13A plug/socket is not within the scope of the legislation (and therefore cannot be notifiable) would not seem to be within the spirit of the notification requirements (in Wales) ...

The electrics for my boiler, together with a fairly complex CH 'control system', are all supplied through a single 13A plug (to facilitate changeover to a genny supply) - see pic below. It's not in my kitchen, but could be, and if I were, and I were in Wales, then that 'blanket' interpretation would mean that it was not notifiable. Whilst it may be 'obvious' that the TV and kettle base (screwed to wall or work surface) were not notifiable, is it equally obvious to you that none of my CH control system would be notifiable?

Using BS7671 definitons: ....

As per your subsequent response to eric, I'm not sure what BS7671 definitions have got to do with whether or not work is notifiable - which is entirely down to the Building Regulations.

Kind Regards, John

 

[JohnW2]

All electrotechnical definitions are available here: https://www.electropedia.org/ ... and if they are not there, you are on your own.

Well, legislation is 'on its own'' if it doesn't refer to the IEC definitions - and if it (the legislation) is otherwise silent about relevant definitions, then everyone is, indeed, 'on their own'.

Kind Regards, John

 

[JohnW2]

... This is a DIY forum and we and I include myself have gone OTT with this discussion.

As so often, we're all guilty, but it was you who started the recent part of this discussion by suggesting that one could avoid (evade?) the need for notification of work in a Welsh kitchen by connecting things with an extension lead

Kind Regards, John