BS7671:2018 DPC - Local Earth Electrode with TN systems

[JohnW2]

Probably about as often as a government changes its mind following a consultation process.

It might not be quite the same situation, because the BSI/IET committees don't generally have to worry about being 're-elected' (or not) by those commenting during a consultation process!

Kind Regards, John

 

[JohnW2]

IME, quite common.

Thanks. That's interesting. I suppose a lor depends upon how you interpret my phrase "significant changes".

Closer to the present discussion, have you ever come across a situation in which a fairly major change proposed in a draft (of any Standard) has been abandoned as the result of comments received during consultation?

Kind Regards, John

 

[stillp]

Yes, frequently.

 

[JohnW2]

Yes, frequently.

Thanks. That's interesting - and, I confess, not the answer I was expecting! I don't suppose you could give any examples, could you? (I imagine that the relevant DPC, comments and final version will usually all be in the public domain).

In fields I have worked in where consultations take place in relation to regulations etc., it is often pretty difficult to detect the (usually very few and very minor!) differences between the draft and the final version, leading some people to wonder about the value/point of consultation process!

Kind Regards, John

 

[stillp]

I've worked in a significant number of standards committees (not including JPEL/64), and in every one, all comments, whatever their source, have been considered and discussed. The discussions, and the results of discussion, are not generally in the public domain, but I would feel confident that if a comment is rejected there is a sound reason for that rejection. It is usual to record the reason for rejection in a revised Compilation of Comments, but that document is not made public. Of course since I'm not a member of JPEL/64 I have no idea if they follow the rules!

 

[JohnW2]

I've worked in a significant number of standards committees (not including JPEL/64), and in every one, all comments, whatever their source, have been considered and discussed.

That is, of course what one would hope and expect, and what I assumed was probably the case with Standards committees. However, as you will realised, I was more interested in knowing about the 'usual' outcome of those "considerations and discussions"!

The discussions, and the results of discussion, are not generally in the public domain, but I would feel confident that if a comment is rejected there is a sound reason for that rejection. It is usual to record the reason for rejection in a revised Compilation of Comments, but that document is not made public.

That differs a bit from most of the situations I have experienced, in other fields. Whilst the discussions themselves are not usually made public, there is often a requirement that each any every comment (or grouped comments, when several are very similar) should receive a written response, in a public document. However, as I rather implied, those responses are often useless - often merely saying something along the lines of "following discussions, the Committee decided that, on balance, no change to the wording of the draft is required"! Sometimes, however, the responses are much more detailed, hence useful.

Kind Regards, John

 

[stillp]

It is sometimes difficult to write a succinct but meaningful response to comments - I have on occasion written "Not accepted - no added value perceived". Technical comments tend to attract a more technical response.

 

[JohnW2]

It is sometimes difficult to write a succinct but meaningful response to comments - I have on occasion written "Not accepted - no added value perceived". Technical comments tend to attract a more technical response.

Yes, I can understand that. It is probably particularly difficult in the case of comments like the ones BAS has been talking about - essentially questioning whether the proposal for a new wide-ranging requirement is adequately evidence-based. I suppose they could simply say that they are satisfied that the evidence they have justifies the proposal - but I rather doubt that would satisfy him! However (and I suppose this is where I started), given the amount of discussion/consideration there must have been prior to drafting the proposal, I really can't see them responding with "Yes, you're right, on reflection there's not enough evidence - we'll drop it"

Kind Regards, John

 

[ban-all-sheds]

It is sometimes difficult to write a succinct but meaningful response to comments - I have on occasion written "Not accepted - no added value perceived". Technical comments tend to attract a more technical response.

"Thank you for your interest in xxxxxxxxxx. Your comments were appreciated."

 

[JohnW2]

"Thank you for your interest in xxxxxxxxxx. Your comments were appreciated."

That's a very standard sort-of 'cop-out'/'no comment' response (and a formula I've often used when critical comments have been thrown at me in the name of 'asking a question' after a presentation!) - it may be succinct, but it certainly does not qualify in my book as 'a meaningful response'!

Kind Regards, John

 

[ban-all-sheds]

Yes, I can understand that. It is probably particularly difficult in the case of comments like the ones BAS has been talking about - essentially questioning whether the proposal for a new wide-ranging requirement is adequately evidence-based.

The point is that it must be.

It absolutely must be. It is utterly essential. Inadequate, or no, evidence is totally unacceptable.

I suppose they could simply say that they are satisfied that the evidence they have justifies the proposal - but I rather doubt that would satisfy him!

It would, if their satisfaction were reasonable, and if the evidence were to be public.

Concealing the evidence, and/or drawing unwarranted conclusions from it, are also totally unacceptable.

However (and I suppose this is where I started), given the amount of discussion/consideration there must have been prior to drafting the proposal, I really can't see them responding with "Yes, you're right, on reflection there's not enough evidence - we'll drop it"

If there is enough evidence then there is no problem.

If there isn't then the people responsible for pushing ahead with non evidence-based conclusions should be dismissed, and those who lie in response to comments asking them if there is enough evidence should be imprisoned.

As you well know, John, in your field of expertise, all kinds of messes result from politicians refusing to do what the evidence says they should, and you know that decent and honest people get sacked or feel obliged to resign when they continue to espouse evidence-based policy or see that their employer has no interest in such policies.

Policies made in prejudice and bigotry, and which fly in the face of what the evidence says should be done, are a cancer in our society. So yes - I am quite serious about dismissals and imprisonments, because just like with biological cancers, sometimes the only thing to do is to cut it out and destroy it.

 

[securespark]

Yeah, I believe there were some alterations to the final 17th compared to the DPC.

If not, what is the point of having the DPC?

 

[ban-all-sheds]

For show?

 

[JohnW2]

Yeah, I believe there were some alterations to the final 17th compared to the DPC.

I don't know about the original 17th., but in terms of Amd3 there were, indeed a few differences between the DPC and the final version. However, I have to say that what few differences I was able to identify (I'm sure I will have missed a good few!) were all very trivial and of little consequence.

If not, what is the point of having the DPC?

Well, we know what the point is meant to be. However, with a fairly large number of 'experts' having been involved in the drafting (involving, I'm sure, a lot of discussion), I suppose it is not surprising that they usually feel that what they have already decided (on the basis of discussion amongst experts') is 'correct', no matter what comments they receive from 'outsiders'.

I suppose that a more cynical view would be that they have to be seen to have gone through this process - quite possibly because they are 'required' so to do (by their own 'constitution' or whatever).

Kind Regards, John

 

[securespark]

For show?

Never had you down as a conspiracy theorist.