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Topic Title: rcd protection ( commercial)
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Created On: 23 January 2013 07:49 PM
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 23 January 2013 07:49 PM
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DALEC

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discussing a recent eicr with a fellow electrician about a guest house i have been asked to test , no rcd protection just main switch and 60898 breakers smallish guest house 3 x 8 way boards , i said non compliant due to no rcd he said its a pass due to commercial use .....surely guests cannot be classed as suitably qualified or experienced.... whats the general feeling ! .....2 or 3 ?

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 23 January 2013 07:57 PM
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aligarjon

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is it potentially dangerous or do you recommend they improve it. ?

i would suggest a 3 personally . are there sockets that are likely to be used outside ?

Gary

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Specialised Subject. The Bleedin Obvious. John Cleese
 23 January 2013 08:01 PM
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daveparry1

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I say code 3

Dave.
 23 January 2013 09:11 PM
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Martynduerden

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Perfectly acceptable, guests are not your concern, they are the concern of the duty holder.

Send them the EICR with the two extracts from the relevant regs...

You are there to report on the condition of the installation not the unfulfilled duties of the holder.

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 23 January 2013 09:30 PM
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AJJewsbury

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he said its a pass due to commercial use .....surely guests cannot be classed as suitably qualified or experienced.... whats the general feeling

Guidance has varied - I believe the current version from the IET recommends (for designers of new installations) that the designer obtain written assurance from the customer that their H&S@W procedures make 30mA RCD additional protection unnecessary before omitting them (e.g. ordinary employees aren't permitted to bring in their own untested appliances, use any appliance outdoors or bang nails into walls etc). A similar approach for a Periodic would seem logical - i.e. unless written evidence shows that they're unnecessary, the inspector should presume that the normal BS 7671 requirements for ordinary persons apply in full.

- Andy.
 23 January 2013 09:36 PM
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perspicacious

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It would be interesting to see how the insurer/LABC who "forced" the EICR would respond to being asked prior to carrying out the PIR, how they view this position........

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BOD
 23 January 2013 09:54 PM
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Martynduerden

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Originally posted by: AJJewsbury

he said its a pass due to commercial use .....surely guests cannot be classed as suitably qualified or experienced.... whats the general feeling


Guidance has varied - I believe the current version from the IET recommends (for designers of new installations) that the designer obtain written assurance from the customer that their H&S@W procedures make 30mA RCD additional protection unnecessary before omitting them (e.g. ordinary employees aren't permitted to bring in their own untested appliances, use any appliance outdoors or bang nails into walls etc). A similar approach for a Periodic would seem logical - i.e. unless written evidence shows that they're unnecessary, the inspector should presume that the normal BS 7671 requirements for ordinary persons apply in full.

- Andy.


That is a very risky approach Andy, I would suggest we cannot "presume" without first making our presumptions known at least in the Extent & limitations/Pre contract negotiations.

I guess in a commercial premises I would be "asking why am I here?" "Who requested it"? "should I follow the requirements for commercial premises"?

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 23 January 2013 11:01 PM
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AJJewsbury

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"should I follow the requirements for commercial premises"

That's my point though - BS 7671 doesn't have requirements specific to commercial premises as such (although there are a few for household and similar - e.g. DP main switch). The requirements for additional protection by RCDs are based on 'supervision by skilled or instructed persons' - which is a feature of the people, not the premises.

Presume maybe wasn't the right word. As I see it, it's not up to the electrical inspector to take on the risk of controlling how employees (or others) at the premises are going to behave. Especially when there's industry guidance for comparable situations saying clearly not to. That's the duty-holder's responsibility. Unless the duty-holder is going absolve you of that risk (in a form you can wave at a court if necessary), then play-safe, is my advice. Discuss with and explain to the customer by all means, but don't put your name to it unless you're sure it's right.

- Andy.
 23 January 2013 11:06 PM
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AJJewsbury

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Here's the IET guidance I had in mind: http://electrical.theiet.org/w.../41/rcds.cfm?type=pdf
- Andy.
 23 January 2013 11:36 PM
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John Peckham

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I put a C3 on EICRs if I find sockets that are not RCD protected and are for general use by ordinary persons. I am therefor only recommending improvement, it is up to the owner if they accept my advice and take action. If I don't recommend it and their is an accident the owner no doubt would say they employed me to give them professional advice and they would have acted on it, a get out of jail free card. If I recommend it and there is an accident the owner having not acted on my advice is in deeper s**t.

The regulations do not mention "duty holder" in respect of RCD protection on sockets (411.3.3) they specify supervision by a skilled or instructed person. Those definitions are set out in Part 2. I wonder if the guest house owner fits the definition of skilled or instructed as per Part 2 although he or she may be the Duty Holder? Are the guests using the sockets behind the bedroom doors under the supervision of the guest house owner?

I carried out an inspection and test of a church and church hall a couple of years ago. The premises are looked after for maintenance purposes by a NAPIT QS in his free time. The hall is used in the day time by a nursery. I asked him if the sockets not (RCDed) were used under the supervision of a skilled or instructed person. He said, "only when I am here" which was not normally in the day time.

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 23 January 2013 11:57 PM
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Martynduerden

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I assume you ask them first John ?

I personally would not code it without client agreement.

Business premises is skilled or instructed by virtue of EAWR Duty holder, I will point it out in a covering letter as part of the report but fail/code never, unless instructed to do so in writing.

What would your insurers say at you exposing yourself / them to risk of being sued for mis-information?

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 24 January 2013 12:20 AM
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John Peckham

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Have a look at the article in Wiring Matters from the link listed above. I try not to provide my clients with mis-information. My EICRs contain observations and recommendations I cannot compel my clients to do anything.

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John Peckham

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 24 January 2013 12:28 AM
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Martynduerden

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Originally posted by: John Peckham

Have a look at the article in Wiring Matters from the link listed above. I try not to provide my clients with mis-information. My EICRs contain observations and recommendations I cannot compel my clients to do anything.


Quite, but the power of "unsatisfactory" is amazing, it teddy to make owners angry, and an angry owner may be looking to sue one for incorrectly coding one thing or another, it is only the inspectors opinion but it is informed by the requirements.

By virtue of EAWR business premises don't NEED to have RCD's

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 24 January 2013 12:32 AM
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John Peckham

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"Quite, but the power of "unsatisfactory" is amazing, it teddy to make owners angry, and an angry owner may be looking to sue one for incorrectly coding one thing or another, it is only the inspectors opinion but it is informed by the requirements. "

That may be the case but a C3 for lack of RCD protection would not make the EICR "unsatisfactory".

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John Peckham

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 24 January 2013 12:38 AM
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Martynduerden

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Originally posted by: John Peckham

"Quite, but the power of "unsatisfactory" is amazing, it teddy to make owners angry, and an angry owner may be looking to sue one for incorrectly coding one thing or another, it is only the inspectors opinion but it is informed by the requirements. "

That may be the case but a C3 for lack of RCD protection would not make the EICR "unsatisfactory".


Very true -for you but they do exist.

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Martyn.

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 24 January 2013 09:07 AM
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rougediablo

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I would have thought it depends on when the installation was done & which edition of BS7671 applied at the time.

If it was installed to the 16th then for dwellings or installations that are for use by ordinary persons and not under the supervision of skilled or instructed persons the requirement for RCD protection only applied to socket outlets where it was likely that they could be used for equipment outdoors.

The Wiring Regulations are not retrospective so existing installations that have been installed in accordance with earlier editions of the Regulations may not comply with the 17th edition in every respect. This does not necessarily mean they are unsafe for continued use or require upgrading unless your inspection finds otherwise due to deterioration, modification etc.

As you are inspecting to the 17th edition then a code 3 - Improvement Recomended seems the most appropriate. The duty holder then has to risk assess whether to act upon your observation.
 24 January 2013 11:19 AM
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AJJewsbury

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I would have thought it depends on when the installation was done & which edition of BS7671 applied at the time.

Period inspections are meant to measure against the level of safety provided by current standards. Otherwise where would you stop? - nothing earthed - that's OK because it was done to the 1888 version? Is an installation done today to 15th Ed standards any more dangerous than an identical installation that happened to be done in 1980?

Knowledge of earlier standards can be used to inform the coding process though - e.g. if it was OK according to standards 5 years ago, it's probably not that dangerous - so probably a C3 rather than C1.

By virtue of EAWR business premises don't NEED to have RCD's

Have a read of the article. As I understand it, while the duty-holder might need to have a certain level of competence, that's not the same as ensuring that all persons at the site will also be electrically competent. For example, if the duty-holder realised there was problem with lack of RCDs they could take the stance that they'd order the workforce not to use untested appliances, not knock nails into walls etc. On the other hand they could equally take the stance that they'd let employees do what they want and just check that the electrical installation was up to standard. If you then come along and give them a piece of paper saying it is, then they're off the hook ... but you might not be.
- Andy.
 24 January 2013 11:31 AM
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daveparry1

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I had a similar situation to this with an office a year or so ago and just recently with the same client at a new office he has aquired. There was no rcd in either of them and I got him to post notices around the premises instructing staff not to bring personal electrical items into the building and that no portable electrical equipment is to be used outside, gave both offices a C3 of course, in a covering letter I also told the client that all equipment should be regularly PA tested (which he assures me they are anyway, not by me though)

Dave.
 24 January 2013 11:50 AM
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rougediablo

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Period inspections are meant to measure against the level of safety provided by current standards.


Which is what I said.

Doesn't mean that, provided the inspection doesn't find otherwise, the installation is unsafe. Hence the C3
 24 January 2013 12:49 PM
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Parsley

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You wouldn't note a C3 if it was unsafe would you?

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IET » Wiring and the regulations » rcd protection ( commercial)

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