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

[stillp]

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

Yes, that's one reason. Another is that governments don't like mandating specific solutions unless there really is no alternative; there could be many ways in which one could deviate from the prescriptive requirements in BS7671 while still achieving a 'safe' installation, so legislation that required compliance with 7671 would be unduly restrictive.

 

[ban-all-sheds]

I would not consider requiring the use of materials and equipment etc which comply with applicable (inter)national standards for safety, quality etc to be unduly restrictive.

I would consider it to be a BGI, and an efficient way to build on a hierarchy of safety.

 

[stillp]

It just struck me while posting in another thread - the Restriction of Hazardous Substances regulations, which are derived from a 2011 EC Directive, place restrictions on the use of certain flame retardents. Manufacturers were aware of the Directive and were making changes to their products in 2011 and in some cases a little earlier. It seems possible that new CUs installed around 2011 were more flammable that older ones.

 

[PBC_1966]

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?

But could that not be avoided by legislating that something must comply with whatever standard as at a specific date or edition? That would ensure that while the government might not have any direct control over which direction the standard might take in the future, it certainly does have control over legal requirements, since it can choose whether or not to adopt a later revision into law.

That is effectively what happens here with the National Electrical Code. The NEC itself is an external standard maintained by the National Fire Protection Association and which has a revised edition published roughly every 3 years. Individual states then adopt the NEC into state law for new electrical work, but it's not on an "open" basis of the new edition becoming the law the moment it's published. A state has to formally adopt the new edition, and can make whatever amendments it sees fit when adopting it into its own state electrical code. Some states are quick to adopt new editions and impose few if any changes, while others sometimes lag a couple of code editions behind, e.g. the latest NEC edition is 2014, while the California code is still basically the 2011 NEC with state amendments. A few states are still on the 2008 edition, and there are a couple of states which don't formally adopt the NEC at all (at statewide level; individual counties and/or cities may do so).

In fact, on a very small issue of adopting one specific definition contained within BS7671, isn't this what the government did with the original version of Part P, in writing the regulation in such a way that it said, very specifically, that "special location" was to be as defined in BS7671:2001 rather than stating the current edition of BS7671?

 

[stillp]

But could that not be avoided by legislating that something must comply with whatever standard as at a specific date or edition? That would ensure that while the government might not have any direct control over which direction the standard might take in the future, it certainly does have control over legal requirements, since it can choose whether or not to adopt a later revision into law.

That's another problem. If the standard that is referred to in law needs to be changed, then either the law needs to change at the same time, or the standard and the law will deviate from each other.

 

[JohnW2]

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.

Look at the fourth post in the first 'sticky' ("ELECTRICS SAFETY") at the top of the front page of this forum.

Kind Regards, John

 

[JohnW2]

But could that not be avoided by legislating that something must comply with whatever standard as at a specific date or edition?

Theoretically it could, but that would require legislation to be revised simultaneously with the appearance of every amendment or new edition of the Standard (or whatever), which might come along - otherwise everything could end up in a mess.

Kind Regards, John

 

[PBC_1966]

or the standard and the law will deviate from each other.

But that's the whole point - If the powers-that-be don't like the changes in a new edition of an external standard they don't have to adopt it into law.

 

[JohnW2]

or the standard and the law will deviate from each other.

But that's the whole point - If the powers-that-be don't like the changes in a new edition of an external standard they don't have to adopt it into law.

Yes, it addresses that issue, but it would be very confusing/messy if (as would not be impossible) compliance with the current BS7671 resulted in non-compliance with the law ... for example, the law (by requiring compliance with an earlier version of the regs) might require supplementary bonding and various warning labels that would not be required for compliance with the current version of BS7671.

In any event, I don't think that stillp was necessarily talking about a situation in which the law deliberately decided not to recognise a new version of a Standard. Rather, I think he was probably thinking about the messy/confusing 'transition/overlap' period, should there be a time delay between the appearance of a new version of the Standard and it being adopted into the law.

Kind Regards, John

 

[stillp]

The IEC/EN/BS EN processes work on entirely different timescales to those of Government, and changes are triggered by entirely different reasons.

 

[ban-all-sheds]

That's another problem. If the standard that is referred to in law needs to be changed, then either the law needs to change at the same time, or the standard and the law will deviate from each other.

And this is also a bit of a deviation from the real issue, which is a standard requiring compliance with other standards. Legislation requiring compliance with them is not, IMO, a bad thing per se, but as observed there are concerns of the scheduling and interlocking of changes to be dealt with.

But as far as standards go, there should be a presumption that as far as possible a hierarchy should be built. So if BS 7671 wants to say that all whatevers have to perform whichway, then it should require the use of whatevers that comply with the other standard(s) that specify the whichway, not reinvent its own.

If there simply is no standard for the whichway performance of whatevers, then that's a different matter, but it would behove the writers of BS 7671 to specify the whichway performance, and methods of testing and demonstrating compliance, with just as much rigour as if they were writing a standalone EN standard for it.

If there is a standard, but it is felt inadequate, then by all that is logical and consistent, the only way to sort it is by fixing that, not by tacking other unique requirements onto it. JPEL/64 may not write IEC 61439-3, but I would hope that they (and indeed the LFB) would be listened to seriously if they had serious, evidence-based, concerns about the inadequacy of it.

What we have right now is JPEL/64 saying that many CUs currently on sale are not safe enough for use in houses to be permitted from next year. IF this be so then they are not safe for use in pubs etc, so should not be allowed there either, and they are not safe for use in houses in France, Germany, and so on, and should be withdrawn from sale across the whole of Europe.

If this be not so, then WTF do JPEL/64 think they are doing?

 

[ban-all-sheds]

Theoretically it could, but that would require legislation to be revised simultaneously with the appearance of every amendment or new edition of the Standard (or whatever), which might come along

Not if the law was worded to require compliance with the the standard in force at the time.

Just what mess, for example, would result if Part P of the Building Regulations were to require that work on fixed electrical cables or fixed electrical equipment located on the consumer’s side of the electricity supply meter which operate at low or extra-low voltage and are in or attached to a dwelling etc comply with the version of BS 7671 in force at the time the work is done?

 

[stillp]

Yes, you're right about the hierarchy. Is there a general reg in 7671 requiring components of the installation to meet IEC/EN/BS EN standards where applicable?
Yes, I'm sure the MT4 members would listen to the concerns of JPEL/64, and also to the LFB's concerns. Whether they would reach a consensus on any changes is another matter. Actually since the verification of resistance to abnormal heat & fire is in 61439-1, it's the responsibility of MT2. I know a member and will ask his opinion. Don't hold your breath though!

 

[JohnW2]

Theoretically it could, but that would require legislation to be revised simultaneously with the appearance of every amendment or new edition of the Standard (or whatever), which might come along

Not if the law was worded to require compliance with the the standard in force at the time.

You mean "the current Standards"? If so, as discussed, that's the very thing that government might well want to avoid - demanding compliance with something not-yet-written (at the time of drafting the legislation) which could, at least in theory, prove to be totally unacceptable to them.

Kind Regards, John

 

[PBC_1966]

Rather, I think he was probably thinking about the messy/confusing 'transition/overlap' period, should there be a time delay between the appearance of a new version of the Standard and it being adopted into the law.

Or one could look upon it as giving time to "get used to the idea" of changes to come!