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

[ban-all-sheds]

Quite, and more. As I wrote:

.... do I take it that, for example, switched FCUs, any switch with a neon, dimmers etc. come within that definition?!!

Once again I fall into the trap of either replying to posts, or simply posting, without having seen what others have said. I get the feeling that, much like that graph, there's been a marked increase in the incidents of me doing that. A sudden diminution of my faculties, or a sudden change in the way the forum behaves?

So would I - but I doubt that it would often involve any "low voltage switching device".

http://www.brighthubengineering.com...steps-to-wire-a-door-bell/?PageSpeed=noscript

But hopefully you're right, unless the definition of LV in the standard is different to the one we normally use.

 

[stillp]

This is why I didn't quote the definition. FCUs, light switches etc, are not switchgear, they are wiring accessories.

Sure - that's what you, I and common sense (and even BEAMA) would say, but they would seem to come within the scope of that definition, wouldn't they? Is this yet another case of a badly written/thought-out definition?

Kind Regards, John

Not at all, it is yet another case of you taking a definition out of context.

 

[JohnW2]

Is this yet another case of a badly written/thought-out definition?

Not at all, it is yet another case of you taking a definition out of context.

A definition is surely a definition, and should include a specification of context if it is not 'obvious' (and, strictly speaking, probably even if it is 'obvious')?

Maybe I misunderstood what was posted. I took it that "low-voltage switchgear and controlgear assembly (ASSEMBLY)" was the term being defined, and that the definition of it being given was "combination of one or more low-voltage switching devices together with associated control, measuring, signalling, protective, regulating equipment, with all the internal electrical and mechanical interconnections and structural parts". Is that a misinterpretation? If not, what is the context issue I have overlooked?

Kind Regards, John

 

[ban-all-sheds]

Would you have preferred MPs to introduce legislation? Who knows what they might have written!

MPs would not have written it themselves, and if you are going to tell manufacturers that there's a legal requirement for their products to perform in a certain way you can bet your last euro that their lawyers would have made sure that there was a proper definition of that way.

That might also have been the thin end of a wedge that might have resulted in the banning of DIY electrical work, as in some other countries.

I doubt that very much. We seem to have coped for quite some time with various laws and regulations which require electrical components to comply with specific standards, and they have not lead us down the path of such a ban.

There are two separate issues here.

One - re the LFB and their figures and graphs and conclusions. Is there a genuine problem which needs to be addressed? That is something which should be clarified, but the same could be said of many provisions in BS 7671, such as RCD protection of concealed cables.

Two - the way JPEL/64 went about it. If there really is a problem which requires that CU etc enclosures be less flammable than they are, then 421.1.201 is not the way to solve it. If BS EN 61439-3 does not result in enclosures being safe enough then BS EN 61439-3 needs to be amended. Or if that's inapplicable, a new standard for "non-combustibility" needs to be created and 421.1.201 changed to something like

Within domestic (household) premises, consumer units and similar switchgear assemblies shall comply with BS EN 61439-3 and BS EN 6xxxx

And why only "domestic (household) premises"? Don't the same CUs catch fire in shops, restaurants, pubs, offices etc, for the same reasons? If not, why not? Don't the Fire Service and JPEL/64 care about the property and human losses in those premises?

What about pubs or shops etc with accommodation above? The legislators made sure that Part P would apply to those if the supply was shared, but as it stands there's no requirement for a CU in a pub to be "safe" even though people sleep above it just like they would in a house.


421.1.201 is not fit for purpose, and TBH I'm beginning to wonder if the same might be said of JPEL/64.

 

[JohnW2]

One - re the LFB and their figures and graphs and conclusions.

Just to be clear ... the LFB's figures and conclusions, but my graph

Is there a genuine problem which needs to be addressed? That is something which should be clarified, but the same could be said of many provisions in BS 7671, such as RCD protection of concealed cables.

Indeed so. One is tempted to talk about apparent 'knee jerks' - or, at least, failure to make decisions/changes based properly on proper evidence.

Two - the way JPEL/64 went about it. If there really is a problem which requires that CU etc enclosures be less flammable than they are, then 421.1.201 is not the way to solve it. If BS EN 61439-3 does not result in enclosures being safe enough then BS EN 61439-3 needs to be amended. Or if that's inapplicable, a new standard for "non-combustibility" needs to be created and 421.1.201 changed to something like
Within domestic (household) premises, consumer units and similar switchgear assemblies shall comply with BS EN 61439-3 and BS EN 6xxxx

Agreed.

... And why only "domestic (household) premises"? Don't the same CUs catch fire in shops, restaurants, pubs, offices etc, for the same reasons? If not, why not? Don't the Fire Service and JPEL/64 care about the property and human losses in those premises? .... What about pubs or shops etc with accommodation above? The legislators made sure that Part P would apply to those if the supply was shared, but as it stands there's no requirement for a CU in a pub to be "safe" even though people sleep above it just like they would in a house.

Yet again, agreed.

Kind Regards, John

 

[ban-all-sheds]

Indeed so. One is tempted to talk about apparent 'knee jerks' - or, at least, failure to make decisions/changes based properly on proper evidence.

Something else for you to agree on:

That is so unacceptable in an official standard that I don't think that Mr Roget can provide enough words to describe it.

 

[JohnW2]

Indeed so. One is tempted to talk about apparent 'knee jerks' - or, at least, failure to make decisions/changes based properly on proper evidence.

Something else for you to agree on: That is so unacceptable in an official standard that I don't think that Mr Roget can provide enough words to describe it.

422.1.201 is clearly (at least, in both our eyes) an abomination. The one possibility we have not considered is that ('consciously' or otherwise) JPEL/64 may conceivably have deliberately written it so badly that they knew they would come under considerable pressure to get rid of it at the earliest possible opportunity (particularly if they were 'bullied' into introducing it in the first place)!

Kind Regards, John

 

[ban-all-sheds]

The one possibility we have not considered is that ('consciously' or otherwise) JPEL/64 may conceivably have deliberately written it so badly that they knew they would come under considerable pressure to get rid of it at the earliest possible opportunity (particularly if they were 'bullied' into introducing it in the first place)!

If that be true then they are so unfit for purpose that they should all be dismissed forthwith, and any engineering organisations who have given them membership status should give serious consideration to bringing charges of bringing the organisation into disrepute.

 

[stillp]

what is the context issue I have overlooked?

The rest of the corpus of standards, and the International Electrotechnical Vocabulary

 

[JohnW2]

what is the context issue I have overlooked?

The rest of the corpus of standards, and the International Electrotechnical Vocabulary

If I am to stand any chance of understanding that, I think I would need a fair bit more explanation!

As I see it, BS7671 cites (and requires compliance with) a Standard which defines term X (essentially the same as the term used in BS7671) as having meaning Y. I'm struggling to see how other Standards and/or International vocabularies can alter any of that.

Kind Regards, John

 

[stillp]

Would you have preferred MPs to introduce legislation? Who knows what they might have written!

MPs would not have written it themselves, and if you are going to tell manufacturers that there's a legal requirement for their products to perform in a certain way you can bet your last euro that their lawyers would have made sure that there was a proper definition of that way.

That might also have been the thin end of a wedge that might have resulted in the banning of DIY electrical work, as in some other countries.

I doubt that very much. We seem to have coped for quite some time with various laws and regulations which require electrical components to comply with specific standards, and they have not lead us down the path of such a ban.

Manufacturers' lawyers have in my experience had little if any influence on legislators. Luckily there are very few examples of electrical equipment being required by law to comply with specific standards.

JPEL/64, as a body, does not have influence on the content of IEC 61439-3, although some of its members are UK members of the body that does, IEC/SC121B/MT4. There does not seem to be a target date for the revision of IEC 61439-3.

 

[ban-all-sheds]

Manufacturers' lawyers have in my experience had little if any influence on legislators.

Maybe not to change their minds, but not to make them state their mind in a way which is guaranteed to be understood?

Manufacturers will really stand by and let this sort of thing happen:

L: It will be illegal for you to sell your products unless we consider that they are safe.
M: OK. Please tell us how you would like our products to perform so that you consider them safe.
L: No.

?

Luckily there are very few examples of electrical equipment being required by law to comply with specific standards.

That will be wrt "luck" as in "bad luck", will it?

 

[JohnW2]

Luckily there are very few examples of electrical equipment being required by law to comply with specific standards.

I wonder to what that is related to my often-mentioned observation that government seem (perhaps understandably) very reluctant to enact any legislation which requires compliance with some 'external' Standard (or whatever) over which they have no control and which could theoretically change dramatically overnight. I suspect that such (and maybe the views of IET/BSI) is at least one of the reasons why there is no legislated requirement for compliance with BS7671. Do you think there is 'anything to' my suspicions?

Kind Regards, John

 

[PBC_1966]

You and BAS talk about "Chinese tat/junk" but, of course, the one issue we do know about is the fire hazard which resulted in recall of Electrium MCBs manufactured mainly in 2009. That might possibly have some bearing on the figures we are looking at, particularly the more modest and gradual increase that was seen during 2007 - 2011.

I wasn't aware of that recall. As you say, something such as the rapid deployment of devices which are then shown to be defective could certainly account for a jump in the statistics when they start causing problems very soon after installation.

However.....

Having said all that, my opinion remains that by far the most likely explanation for the figures relates to possible changes in the way in which they were collected - particularly changes in the extent to which they 'went looking for' possible CU origination of fires.

I very much agree that this seems to be a much more likely explanation.

 

[ban-all-sheds]

I wonder to what that is related to my often-mentioned observation that government seem (perhaps understandably) very reluctant to enact any legislation which requires compliance with some 'external' Standard (or whatever) over which they have no control and which could theoretically change dramatically overnight.

Tell that to vehicle manufacturers.