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Topic Title: EICR Code for plastic consumer units
Topic Summary: New guidance issued
Created On: 08 June 2015 03:41 PM
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 08 June 2015 03:41 PM
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Bhilly

Posts: 51
Joined: 17 June 2013

Electrical Safety First have updated their Best Practice Guide 4 - EICR's. For inspections carried out after 1st Jan 2016, a C3 is recommended for any consumer unit or similar switchgear with a combustible (plastic) enclosure only when it is located under a wooden staircase or within a sole route of escape. In any other circumstances it is "worthy of note" but does not need to appear on the EICR.
Either the plastic consumer unit represents a fire risk or it doesn't - it shouldn't depend upon where it is installed. The onus will now be upon the inspector to decide. Having fudged the issue in terms of providing a working solution and created confusion everywhere, ESF seemingly now want to pass the buck.
 08 June 2015 04:02 PM
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mapj1

Posts: 9679
Joined: 22 July 2004

wiring matters definition of EICR codes, including C3

The new code C3 should imply to the client that the installation is not necessarily dangerous but it may not comply with the current version of the regulations or for example, may have damaged fittings that do not have exposed live parts.


Hmm. But only under wooden stairs - so would a sheet of hardibacker fire rated A1, so maybe better than plasterboard of unknown origin nailed up under the stairs be an adequate mitigation to give time to get you out of the house I wonder. Will the next chap to inspect in a few years time agree with you that it is still a C3 ?

-------------------------
regards Mike


Edited: 09 June 2015 at 01:38 PM by mapj1
 08 June 2015 06:23 PM
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Zoro

Posts: 300
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And all because the cause of the fires is defective installation of CU's, resulting in a doubling of fires since the start of Part P. (DCLG fire statistics)

Coupled with 3 out of 5 manufacturers taking out the flame retardant materials of their CU's causing them to burst into flames compounding the risk, these include Hager, MK and Electrium, (Wylex, Crabtree, Volex).

It should still be a recall, but has resulted in a compromising of engineering rigour in the installation regulations (BS7671) being used to overrule Product regulation (BS/EN 61439-3).

When you look at the independent evidence the pictures and reports of the testing outcomes of CU's with flame retardant materials in them (CED), not bursting into flames, then Wylex, MK and the Hager bursting into flames it is very clear what action should be taken. A Recall.

But condemning ALL plastic CU's as a safety issue for commercial reasons, then vested interest stating keep fitting them until the stock is used up. Then stating start coding them C3 only if they may start a Serious fire, under stairs and escape routes, just compounds the size of hole this section of the industry is digging for themselves.

As Domestic installers do not work in the commercial sector, plastic CU's can still be fitted in commercial premises such as offices and care homes etc.

What credibility.
 09 June 2015 12:00 PM
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davezawadi

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I have a feeling that someone has taken some legal advice, and they are running far and fast.
Should I code all prohibited items as C3 in future? Not much point left to an EICR then. And we may as well continue with the plastic ones, they are not even potentially dangerous, just improvement recommended, or even not worth a mention at all.

All we need is a fire in a plastic CU which is coded C3 by a poor fall guy, leading to a death. Then the coroner will certainly give the industry some advice which should finish these pieces of direction which are contradictory and grossly misleading, forever.

I feel that this is totally out of control, and issuing coding advice which is clearly ridiculous to anyone competent and contradicts the risk alleged by the LFS photographs used as evidence in the first place, to change the CU material.

Someone has realised that proper coding of prohibited items will lead to a recall, and subsequent business failures. All of these CUs with flammable plastic must be falsely CE marked, surely they do not comply with the product specification standard? I wonder where the EU regulation police are now?

Is this really best practice or another area which could join FIFA, because something is not quite right?

-------------------------
David
BSc CEng MIET
david@ZawadiSoundAndLighting.co.uk
 09 June 2015 01:37 PM
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mapj1

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Someone has realised that proper coding of prohibited items will lead to a recall, and subsequent business failures. All of these CUs with flammable plastic must be falsely CE marked, surely they do not comply with the product specification standard? I wonder where the EU regulation police are now?


Well, in a parallel universe run by Germans you might have got such a recall. The fact it is a UK only rule, yet plastic boxes with DIN rail in are in use Europe wide is also telling- suggests that it is kit made specially for the UK market that has been "value engineered" a bit too much (like Volex again, and those solid core enamel insulated links between main switch and RCD, among others -no names but clearly identified from the photos.)

Given that trading standards can't even stem the tide of plug in stuff that is obvious tat with meaningless CE marking, masquerading as battery chargers, table lamps and similar, I hold out no hope at all for them having the resource to do battle with a multinational with a good legal team, even though they may well have failed to meet the glow wire test required of the standard (and personally I'd like it to meet a flame test like UL 94 as well, but that's another story)

Actually a 'name and shame' of the poor CU models on a TV programme like watchdog would probably have had slightly more public beneficial effect than a regs change and a "C3" (= no action required )recommendation.

-------------------------
regards Mike
 09 June 2015 02:01 PM
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John Peckham

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It would be very helpful if the ESC/ESF published on their web site a list of manufactures and models of consumer units that do not comply with the AMD3 requirement for non-combustible.

-------------------------
John Peckham

http://www.astutetechnicalservices.co.uk/
 09 June 2015 02:54 PM
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sparkingchip

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I'll let you have my suggestion later that I posted on the NAPIT forum and went down like a lead balloon.

Andy
 09 June 2015 09:47 PM
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sparkingchip

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I suggested that we request the consumer unit manufacturers get the new consumer units approved as LABC registered products so we can buy approved products carrying the LABC logo confirming that they have been checked against all the relevant standards and regulations, saving us from having to fret about compliance.

Andy
 09 June 2015 10:24 PM
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mapj1

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Actually if they CE mark they are obliged to show their test results ("technical construction files" or 3rd party test house certificates) to enforcement authorites and those with a good cause to see them - I'd have thought that in the circumstances the likes of the IET had good cause to ask.

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regards Mike
 10 June 2015 09:27 AM
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lyledunn

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Sparkingchip
After all the comments, opinions, bluster and dross, you have arrived at the best solution to this mess by far!

-------------------------
Regards,

Lyle Dunn
 10 June 2015 09:52 AM
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Bhilly

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And if you want to know what an escape route is in order to now carry out inspections in your dual role as electrical inspector / fire engineer, you too can take part in the ECA's webinar Webinar and pay £5 for the privilege
 10 June 2015 11:35 AM
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Zoro

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Originally posted by: sparkingchip

I suggested that we request the consumer unit manufacturers get the new consumer units approved as LABC registered products so we can buy approved products carrying the LABC logo confirming that they have been checked against all the relevant standards and regulations, saving us from having to fret about compliance.

Andy


The whole of Europe uses the CE mark as a method of conformance, with regulation Why would adding another layer of bureaucracy help the situation. There are already too many people with vested interest torturing BS7671 for their own commercial interests.

Lets see the 3rd party CE conformance certificates for the CU's tested and the hot wire test certificates, many manufacturers are happy to provide these, others are very evasive, why?

Lets see the video of the MK board (Chinese populated type) going up in flames under formal test at Bureau Veritas that exists, and the Hager.

Lets see the CED CU (Toolstation), with a flame test carried out four times, which is a higher standard than BS/EN 60439-3. It did not combust, including the plastic lid.

Lets see the second tests done at BRE and name the plastic CU's that were used for comparison with steel, which were chosen? the compliant CU's or the non compliant? I believe it was the non compliant, what were the motives for that?

.
 10 June 2015 03:28 PM
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Legh

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The whole of Europe uses the CE mark as a method of conformance, with regulation Why would adding another layer of bureaucracy help the situation. There are already too many people with vested interest torturing BS7671 for their own commercial interests.


Why indeed!

But it appears that we have created this rod which is now about to be wielded . ie The IET have invented a sub-set of regulations for the UK to satisfy the LFB
Will we still be trading with Europe on an equal footing I wonder?

The best solution so far, and who gains the award for the 'proportionate returning of the buck' goes to sparkingchip

Legh

-------------------------

http://www.leghrichardson.co.uk

de-avatared
 10 June 2015 09:27 PM
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jcm256

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I agree that there should be a CE mark on all new consumer units, (have not seen that mark on the existing ones) Just one example Passenger Lifts, goods lifts or any lifts example may have individual CE markings on safety components as is (MCBs, RCDs, RCBOs in a consumer unit) but if an overhaul CE mark is not placed in the lift car, on or beside the load plate, followed by ID number of the notified body it is a defect. So the natural or legal person who takes responsibility for the design, manufacture, and placing on the market a consumer unit should be the one who affixes the CE marking and draws up the EC declaration of conformity. No CE mark on the casing of a consumer unit should be code C2 ON EICR.

jcm

Edited: 11 June 2015 at 08:51 AM by jcm256
 11 June 2015 09:09 AM
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phantom9

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Given the fiasco of non-enforcement of Part P by the LABC I would keep them well away from the approval process of anything electrical. LABC has its place, it is NOT in the electrical industry. Take the LABC completely out of the equation is what I say and leave them to their Building Regulations. They do not have any interest in, nor expertise in, electrical installations. Part P is proof. They got it completely wrong and pretty much all LABCs made their own rules up, non of which helped us. They failed.

I would revoke the Regulation before it comes in to force on 1 Jan 2016. But oh dear, look at all the AMD3 compliant CUs flooding in to the wholesalers. Money is now behind it. Financial investment in a product that is not really required now supersede any sensible revoking of a Reg. So once again we see money beginning to overtake the situation beyond a point of no return. Too much at stake now!

However, it is still my view that far too much is being expected out of this Regulation. I use the same point every time I see it being debated. The introduction of a Regulation DOES NOT MAKE ANYTHING UNSAFE. I really wish that people would understand this. Regulations are all about safety but they are NOT retrospective in any way shape or form. This aspect has been mismanaged for years. Look at this way. Would any Regulation be made to admit that something is dangerous? Of course not.

I like Zoro's approach tbh. What he says is absolutely true.

Just to reinforce the misunderstanding about the Regulations the arrival of a dateline 1 Jan 2016 does not throw a switch to make all that went before unsafe. The Reg is a response to the London Fire Brigade. They have asked for an IMPROVEMENT. I don't agree with the solution arrived at but even the industry guidance is missing this point completely. Codes are used to identify findings resulting from inspections. If, after 1 Jan 2016, (not now) a Consumer unit deemed non-AMD3 compliant is found then you can only put it down on your report as not complying with the current edition of the Regulations. That is ALL you can do. It is not dangerous in any way shape or form. It is just non-compliant. Simplicity itself.

Another point being largely ignored is that an alternative solution is to install a non-combustible cabinet around it, ignored probably because it is completely unworkable, and that "other similar switchgear assemblies" are required to be non-combustible, too, probably because it is inconvenient to remind us, a fact not even contemplated by the manufacturers it would seem as they are putting current stock of assemblies that don't comply in to the new CUs. Farcical.

Incompetency? It is a wide reaching failing from top to bottom.

Edited: 11 June 2015 at 09:16 AM by phantom9
 11 June 2015 11:55 AM
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whjohnson

Posts: 934
Joined: 24 January 2009

Oh dear!

I have just fitted a plastic CU, and whilst there, the nice Western Power man came to change the meter. I asked him if he would be kind enough to fit an isolator for me whilst he was there, which he duly did - a nice plastic Proteus 100A DP item. Everything is under the stairs..........

Oh dear!

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