Query regarding Amendment 3, 2015 to the Wiring Regulations (England)

[bernardgreen]

What next, non flamable insulation on twin and earth cable ?

The PVC triple and earth that has just been flame tested did burn when in the presence of warm to hot combustion products from another heat source.

Probably no more inflamable ( ie not self sustaining ) than most good quality plastic consumer unit cases.

 

[stillp]

If stillp finds that there is a relevant standard which defines "non-combustible" then the absence of any "clarity" (aka requirements to the contrary) guarantees that it would be compliant with BS 7671.

That's surely the point - or, at least, the point I was trying to make. If (as he seemed to be suggesting is possible) stillp finds a Standard relating to, say, structural building materials which defines 'non-combustible' (in that context), who is to say that that Standard (and definition) is relevant to BS7671?

Kind Regards, John

Who is to say that it isn't? We're talking about a standard here, not "The Janet and John guide to rewiring your house". There are many instances where the user of the standard has to use reasonable skill and judgement to decide how to meet the requirements of the standard. Reference to another existing standard would be one way of doing that. Since the term 'non-combustible' is not used in electrical equipment standards, it is certainly permissible to use a standard for building materials, particularly when, as in this instance, the intent is to mitigate the possibility of a building fire.

 

[ban-all-sheds]

All true, but that still does not mean that a definition of 'non-combustible' in the context of, say, ventilation ducts is necessarily relevant to electrical equipment. There are Standards which relate to the combustibility of furnishings etc. within a home but, again, I don't think they are necessarily relevant to electrical equipment.

I can't work out why you aren't getting it. I hope it isn't because of a deliberate refusal.

Doors, windows, ducts, decorative mouldings, wall and ceiling cladding, wall and ceiling panels, flooring, fixed electrical accessories - none of these are structural, none of them are furnishings, any or all of them could have flammability standards, and some jolly well ought to.

In the absence of anything specific in BS 7671 with which it is possible to comply, I would defy anybody to make even a flaky case to say that an electrician who referred to a relevant standard for materials used in buildings, backed up by the manufacturer of the CU, had not exercised reasonable skill and care and had no grounds for believing to the best of his knowledge that he had complied with 421.1.201.

 

[JohnW2]

Since the term 'non-combustible' is not used in electrical equipment standards, it is certainly permissible to use a standard for building materials, particularly when, as in this instance, the intent is to mitigate the possibility of a building fire.

That is certainly one view.

[Edit: When I wrote this, I thought I was reply to BAS, not stillp. this paragraph therefore relates to BAS, not stillp!. Apologies to all concerned]You seem to have changed your opinion. I thought it was your view that we should completely ignore 421.1.201, since it was requiring something that was a physical impossibility (a "non combustible" material), and therefore was 'invalid'. You now seem to be saying that if some other Standard contains a definition of that "physically impossible" concept, it is acceptable to apply that to BS7671. Is that a correct statement of your new position?

Kind Regards, John

 

[JohnW2]

In the absence of anything specific in BS 7671 with which it is possible to comply, I would defy anybody to make even a flaky case to say that an electrician who referred to a relevant standard for materials used in buildings, backed up by the manufacturer of the CU, had not exercised reasonable skill and care and had no grounds for believing to the best of his knowledge that he had complied with 421.1.201.

Very true - but you're now talking about "to the best of the knowledge" of the individual concerned - i.e. a personal viewpoint.

Kind Regards, John

 

[JohnW2]

What next, non flamable insulation on twin and earth cable ?

Quite so.

Kind Regards, John

 

[ban-all-sheds]

Very true - but you're now talking about "to the best of the knowledge" of the individual concerned - i.e. a personal viewpoint.

The declaration on a certificate is always a personal viewpoint.

Care to put forward a convincing explanation of why someone who did what I said could be shown to have not exercised reasonable skill and care and to not be justified in believing to the best of his knowledge that he had complied with 421.1.201?

 

[JohnW2]

Very true - but you're now talking about "to the best of the knowledge" of the individual concerned - i.e. a personal viewpoint.

The declaration on a certificate is always a personal viewpoint.

Indeed it is, but I haven't really been talking about the declaration, or the sincere personal opinions of those who sign the declaration - but, rather, have been seeking to 'clarify' what the regulation may actually be trying to require.

Care to put forward a convincing explanation of why someone who did what I said could be shown to have not exercised reasonable skill and care and to not be justified in believing to the best of his knowledge that he had complied with 421.1.201?

As I said, I do not doubt that anyone who did what you have said would have 'done their best to comply' - but, as above, that is different from the question of what they are actually meant to be complying with.

As I recently wrote (*), this seems very different from your original attitude - which, AIUI, was that one should not even attempt to comply with 421.1.201, since it was 'asking for the impossible', and hence 'invalid'.

Kind Regards, John
Edit: I accidentally wrote this is my response to stillp, but it was intended to relate to BAS (to whom I thought I was responding). Apologies for the confusion. What I wrote (which was intended for BAS) was ...
"You seem to have changed your opinion. I thought it was your view that we should completely ignore 421.1.201, since it was requiring something that was a physical impossibility (a "non combustible" material), and therefore was 'invalid'. You now seem to be saying that if some other Standard contains a definition of that "physically impossible" concept, it is acceptable to apply that to BS7671. Is that a correct statement of your new position?"

 

[stillp]

Since the term 'non-combustible' is not used in electrical equipment standards, it is certainly permissible to use a standard for building materials, particularly when, as in this instance, the intent is to mitigate the possibility of a building fire.

That is certainly one view.

You seem to have changed your opinion. I thought it was your view that we should completely ignore 421.1.201, since it was requiring something that was a physical impossibility (a "non combustible" material), and therefore was 'invalid'. You now seem to be saying that if some other Standard contains a definition of that "physically impossible" concept, it is acceptable to apply that to BS7671. Is that a correct statement of your new position?

Kind Regards, John

I can't imagine what gave you that idea.

 

[JohnW2]

I can't imagine what gave you that idea.

In the absence of any emoticons, I'm not sure whether that is a serious or sarcastic statement! However, in case it is the former, although I haven't got time to search properly, for starters how about ...

I submit that it cannot be a regulation. It does not mandate ferrous metal, but it does not define non-combustible. If it does not require compliance with a European standard which does, then it has no meaning.

and ....

Until it is "clarified", which will mean re-writing with references to actual standards against which people can evaluate their products, and which will mean qualifying "non-combustible" so that there do become substances known to man which can be thus described, the regulation is meaningless, and impossible to comply with.
Let me put this plainly - nobody can "deem" something which burns to be "non-combustible" - that is a physical impossibility, so anybody who actually believes that 421.1.201 is a regulation which can be complied with will not be complying with it if they install a metal CU.

Kind Regards, John

 

[stillp]

Oh I see, you'd meant to quote BAS.

 

[JohnW2]

Oh I see, you'd meant to quote BAS.

Oh dear - I made a right mess of that . Since there had been a to-and-fro between BAS and myself, I thought that your earlier message was from him. I therefore replied accordingly, and my comments about a 'change of view' related to him, not you. My apologies - and I'll see if I can do something to reduce the potential confusion by editing my previous posts!

Kind Regards, John

 

[Risteard]

I don't agree. It would not be permissible to connect into a combustible domestic DB from next year.

Why not?

Because such work carried out after 1/1/16 would not comply with BS 7671.

 

[PBC_1966]

Because such work carried out after 1/1/16 would not comply with BS 7671.

Does this new amendment actually say that you may not connect a new circuit into an existing "combustible" unit, or that you may not add to an existing circuit fed from such? Or does it just say that new consumer units must be of the "non combustible" type, however that is defined?

 

[JohnW2]

I don't agree. It would not be permissible to connect into a combustible domestic DB from next year.

Why not?

Because such work carried out after 1/1/16 would not comply with BS 7671.

The "work" itself could be fully compliant with BS7671, and I'm not sure that connecting it to something which was not compliant would alter that, would it?

As has been said, if your interpretation correctly reflected the intent of Amd3, the consequences would be horrendous.

Kind Regards, John