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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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 24 January 2013 07:38 PM
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spinlondon

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The biggest problem withe the IET guidance, is that it is advocating that you ask your customer to sign a statement that they are not, and do not intend breaking the law.
Regulation 16 of the EAWR requires that no worker conduct a work activity unless they meet the requirements to be deemed either skilled or instructed as defined by BS7671, or adequately supervised.
By asking your client to sign a statement as advised by the IET, you are effectivly telling your client that you believe they are perhaps a criminal, and could they sign this just in case.

As for the OP:
To my mind a guest house or hotel, is just the very sort of commercial installation where 30mA RCD protection for some socket-outlets would be required.
No RCD protection for sockets that are back of house, but RCD protection for sockets in guest rooms.
 25 January 2013 09:45 AM
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AJJewsbury

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The biggest problem withe the IET guidance, is that it is advocating that you ask your customer to sign a statement that they are not, and do not intend breaking the law.
Regulation 16 of the EAWR requires that no worker conduct a work activity unless they meet the requirements to be deemed either skilled or instructed as defined by BS7671, or adequately supervised.
By asking your client to sign a statement as advised by the IET, you are effectivly telling your client that you believe they are perhaps a criminal, and could they sign this just in case.

I read it differently. To me what you're asking the customer is how they're going to comply with the law. Are they going ensure that all their people (and that includes visitors etc that might be affected by their operations, not just employees) are going to be electrically skilled or instructed at all times (in which case you can play the skilled & instructed card and accept the omission of 30mA RCDs) or whether they're following the other option of ensuring that the electrical installation is suitable for ordinary persons.

Just because there's a person who's responsibility it is to ensure electrical safety (i.e. there is a duty holder) to me isn't the same as being able to presume that everyone at the premises are electrically skilled or supervised at all times - especially as the wiring regulations specifically provide options for providing safety for ordinary persons.

- Andy.
 25 January 2013 04:18 PM
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spinlondon

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Andy Regulation 16 of the EAWR has been extant and as far as I'm aware unchanged since 1989.
The HASaWA has been in existance since 1974.
Why now the rush to obtain confirmation from clients that they are (and intend to continue) complying with their statutory obligations?

BS7671 has had requirements for some socket-outlets to be provided with 30mA RCD protection again as far as I'm aware, since 1981.
The critera for determining which socket-outlets should be provided with the 30mA RCD protection has changed slightly.

As far as I can determine, the wording of the new requirements for providing 30mA RCD protection apply primarily to domestic installation, because there are no statutory requirements which apply to the users of such installations.
With just about all other installations, there are statutory requirements which apply to the users.

BS7671 is non-statutory, there is no statutory obligation to comply with it's requirements. Although there are statutory obligations to comply with the HASAWA and EAWR.
Why now due to a change in a non-statutory standard should we be asking for confirmation from our clients that they comply with their statutory obligations?
Why give such advice now, why not give it 20, 30 or 40 years ago?

I wonder what Alan Sugars' response would be if you asked him to sign such a statement?
Whay are the legal ramifications of signing such a statement?
Would such a statement be usable in court proceedings, would it have the same weight as a statutory declaration, would it requre to be notarised etc etc etc.

Edited: 25 January 2013 at 06:27 PM by spinlondon
 25 January 2013 04:51 PM
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AJJewsbury

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sxtabt

I hope you're not making up words that aren't in the regulations

Why now the rush to obtain confirmation from clients that they are (and intend to continue) complying with their statutory obligations?

Like I said, I don't think we are. Legislation doesn't say "you must train your people to be safe when sockets/concealed cables aren't RCD protected" it just says you must have safe systems of work. The duty holder in effect has a choice whether to train people in that respect or to install 30mA RCDs - all we're doing is asking which option they'd like to use.

- Andy.
 25 January 2013 06:43 PM
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spinlondon

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Changed it.

No legslation doesn't actually state such.
However it does state that your people must be trained, have such experience or be adequately supervised to use non-RCD protected sockets or drill/nail into walls where there are non-RCD protected cables safely.
If your people are not so trained, experienced or adequately supervised, you are not complying with your statutory obligations.

If this was for instance, a new installation, or an installation that is not in use, then it would be a different matter.
You would have no knowledge of the type of person who would be using the installation.
As there are no existing non-RCD protected sockets or cables, there wou;d be no reason to expect that workers have experience etc.

However it's not, it's an inspection of an existing installation with existing employees/workers.
As such they must have the experience etc. in order to comply with existing statutory requirements.

With a new installation one would expect some confirmation of the type of user.
With an unused existing installation, it might be appropriate to comment and mention the requirements of HASAWA and EAWR.

As far as I'm aware, BS7671 does not provide Regulations or guidance for instances where statutory obligations are not or not intended to be complied with.
There are no safe isolation proceedures for stealing supply cables, etc.
I would also consider it a waste of time making requirements in a non-statutory standard for instances where someone can't be asked to comply with statutory requirements.
I can't really see that someone who is breaking or intending to break the law is going to be bothered about complying with a non-statutory standard.

I worked once at a ham and gammon factory as a maintenance engineer.
It used to be, that workers could pick up some product, go to reception and pay a discouted price for the product.
Because of pilfering or more likely suspected pilfering, it was decided that the workers must arrange in advance, that they would like some pf the product, the discounted price would be deducted from their wages, and they could pick up the product from reception at the end of the week.
To my mind the new proceedure only caused inconvenience for the honest workers, anyone pilfering would not care a toss.
Yes if someone was found with product on their person, it could indicate that they were pilfering, but as there was no policy of searching the workers, it was very unlikely that anyone would be found with product on their person.

Edited: 25 January 2013 at 06:56 PM by spinlondon
 25 January 2013 07:00 PM
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OMS

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You could say they made a bit of a pigs ear of it, Spin

regards

OMS

-------------------------
Failure is always an option
 26 January 2013 07:13 AM
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ebee

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Martyn,

"I assume you ask them first John ?

I personally would not code it without client agreement. "

I think it`s up to the inspector whether to code or not code.
Also which code number (C1, C2 or C3) applies when considering all circumstances .
I can`t see that client agreement alters that in any way.

Indeed if client agreement did come into it the following could apply.

Two installations exactly identical in every way including intended use. For one the client agrees to coding, for the other the client disagrees. You end up with one installation coded and one not ! or both coded differently for the same fault.

Unless I`ve misunderstood you.

rougediablo,

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

Same reasoning ref two installations exactly identical but installed when different versions of the regs applied.
Identical coding or non coding as applicable to today's standards.

We might use our reasoning on what is considered safe or unsafe, attracts a code and if so which code by considering earlier regs and when they changed and think if it complied recently it`s probably relatively safe and if it would have not complied for a long time it might not be that safe . But the date it was actually installed would not alter that.

Again , I might have misunderstood you.

Back to the OP,

I`d say RCD required in areas where guests are allowed to use points as they are probably likely to be "Ordinary persons".

I suppose that the remainder is a workplace so far as the employer and his employees are concerned.

Another question, ref EAWR, do they apply in a domestic home?

I live in a house, it`s not a workplace, I ask a joiner to come and fix some skirting boards, it then (temporarily ) becomes his workplace.
Therefore do these regs and acts then apply?

Second point, the regs although entitled "At Work" contain lists of "You must" and "you must not" . What they do not say is "AT WORK you must" or "AT WORK you must not" . So do they apply in all locations and not just at work or does the title on its own prevent that?

-------------------------
Regards,
Ebee (M I S P N)

Knotted cables cause Lumpy Lektrik

Edited: 26 January 2013 at 07:25 AM by ebee
 28 January 2013 11:20 AM
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rougediablo

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Originally posted by: ebee

rougediablo,

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

Same reasoning ref two installations exactly identical but installed when different versions of the regs applied.

Identical coding or non coding as applicable to today's standards.

We might use our reasoning on what is considered safe or unsafe, attracts a code and if so which code by considering earlier regs and when they changed and think if it complied recently it`s probably relatively safe and if it would have not complied for a long time it might not be that safe . But the date it was actually installed would not alter that.

Again , I might have misunderstood you.


The reg's are not retrospective is what I said & therefore the absence of RCDs doesn't automatically mean the installation is unsafe.

If you look at GN3 p110 it says:

"Older installations designed prior to BS 7671:2008 may not have been provided with RCDs for additional protection. The absence of such protection should as a minimum be given a code C3 classification"

ie Improvement recomended unless there is something else which makes the installation unsafe & therefore be coded as C1 or C2.

I would agree that in the case of a guest house it would be prudent that RCD protection is fitted but that is something for the duty holder to decide following receipt of the EICR.

I have had this discussion with contractors carrying out Periodic Inspections at our facility several times & I usually use it as leverage to get upgrades to existing parts through approval.
IET » Wiring and the regulations » rcd protection ( commercial)

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