Interpretation and application to attain compliance with wiring regs.

[SPECIAL LOCATION]

In Manators thread "is it possible to rewire with no RCD's" the topic of interpreting wiring regulations and signing certificates to declare compliance with regs was raised..

But what happens when the regs aren't clear, or are contradictory...

How do we as individuals decide what is appropriate in order to achieve compliance..

Various schools of thought have been mentioned;

• Apply sound electrical theory and science to ensure the fundamental safety principals are met.
  
• Apply a reg word-for-word without looking at is context in relation to other regs within a chapter or section.
  
• Ignore it and just listen to what another electrician has told me.
  
• Write comments in departures as a get out clause.
  
• Keep a level head, balance common sense with electrical knowledge and a reasonable interpretation of the intent of the regulation not necessarily the exact content of the wording.
  

e.g. If these points were in a game of Top-Trumps which items "trump" others?

Can common sense "Trump" the exact wording of regs?

Obviously RCD's are one of the big issues that frequently comes up

(questions like I have to fit XYZ do I need to add and RCD or are the 3036's OK without RCD)

There are others;

• To bond or not to bond.
  
• Export the earth or TT the outbuilding
  
• Does my Cooker / integrated appliance / extractor fan need a local isolator
  

etc..

So... I would like to develop this thought about what is the overriding element when assessing if compliance is achieved and what takes precedence when conflicts of thought arise..

This is not to be an argument about the "real meaning of a reg" but more to see how and why people interpret and apply things one way or another, sort of to try and see how and why people think the way they do...

I perceive (maybe wrongly), that there are apparent anomalies about how some regs are applied compared to others..

One of the pivotal conversation points in Manators thread was the reg 701.411.3.3, which I would like to come back to later, but can we leave that to one side for the moment and consider another reg in a hypothetical similar scenario...

Consider the regs 522.6.6 & 522.6.7 Page 100 "about cables buried in walls <50mm"

Lets say we have a kitchen with some 12v SELV lights under some open shelves.

Due to the nature of the kitchen there was nowhere to hide the 12v transformers,

so they are concealed in the roof void and 12v SELV cable are run down the kitchen walls buried less than 50mm deep,

All of the 230v supply to the transformers is surface run back to the fuse box.

So as all 230v is surface there is no need to RCD the supply to the primary of the SELV transformers.

BUT heres the question...

Q1/ As the SELV cables are buried in the walls do we have to apply one of the requirements of 522.6.6 and/or 522.6.7

Because 522.6.6 says in black and white "A cable concealed in a wall or partitioin..etc.. etc.." Irrespective of what sort of cable it is..

Q2/ Do we need to note a departure if we don't follow 522.6.6 / 522.6.7?

Gentlemen (and ladies) Discuss?

:Salute

 

[steptoe]

excellent post,

as my book is in the van I will have ample time for lots of others to make suggestions before I post tomorrow and weigh up my options very carefully.

I like your thinking BTW, as I did manators too.

 

[tom1]

i would think put a note in the departure box, as the same level of safety. i was talking to nic tec about this and he said it may be in the ammendments

 

[steptoe]

i would think put a note in the departure box, as the same level of safety. i was talking to nic tec about this and he said it may be in the ammendments

wonder how many tech helplines got hammered with the RCD thread.?

bet they just love this place now. :slap

 

[kme]

OK.

I`ve got the book beside the laptop (though I`m not going to use it, at this time.), after the late night fun & games the other day - AND I`m the very first to post an answer in the poll. :x

I`ve voted "Other (explain)": so I will

Circumstances can alter from job to job, or even from room to room; therefore our assessment and experience/knowledge ought to be brought to the fore, to deal with anomalous happenstances. Blindly adhering to a specific reg is nearly as bad as blindly adhering to nothing! - in both cases you`re blind.

Some regs have to be taken in context with others; some don`t allow for up-to-date improvements in technology. They were never designed to be a "catch-all" solution to every problem (though many think they are).

Many sparks (jokingly) refer to the regs book as "their bible", yet is that really so far from the mark? IMO, both publications are a form of "signpost"; one in "how to live your life", the other in "how to do your job well" - they are a path to follow, NOT a precise set of footprints through a minefield.

What I think I`m saying is that, under the variables introduced in "real-world" scenarios, there are going to be those situations where the reg. writers didn`t include a specific caveat, or interlink to another reg or set of circumstances.

This is where we need to have the logical sense & knowledge to examine the circumstance, and decide for ourselves if a particular reg is pertinent to our particular set of circumstances. e.g. Special Location`s SELV circuit above. We can see what the reg says; but we similarly know that the reg can`t have been designed with those particular cables in mind, unless we are going to question the safety of the SELV transformer?

If we ARE going to question the transformer`s ability to provide seperation, then we MUST also disregard any SELV regs we were adhering to, as we have determined that SELV is not as safe as we previously thought.

However, if we are happy to accept the safety of our SELV source, then we can safely accept that the reg in question CANNOT have been designed to apply to our cables; and can, in those circumstances be deviated from (NOT ignored).

KME

 

[PC Electrics]

There's no option for applying 'other relevant published guidance' and/or 'tech help guidance' alongside the regs.

 

[binky]

Having formerly been involved with writing various sorts of instruction manuals, technical documents, and method statements, I know how hard it is to write all encompassing instructions that cover every eventuallity, especially across the entire nation and millions of people. This is why I will rarely argue 'black and white' ' it's in the regs', and will quite happily consider what was really meant / intended by the regs writer with regards to certain scenarios. The aim of the regs is to promote electrical safety through technical compliance and good practice. It has never been intended as a 'must comply' regardless document to be slavishly followed like Pavlovs' dogs.

I will however point out that a sound technical knowledge of electrics and safety aspects therein is essential to make sound judgements about grey areas of the regs. It is not advised that junior (or senior) members go off willy nilly ingnoring inconvienient parts of the regs cos Binky said I could make up my own stuff!!! This has been a public safety announcment.......... :^O

---------- Post Auto-Merged at 08:16 ---------- Previous post was made at 08:14 ----------

There's no option for applying 'other relevant published guidance' and/or 'tech help guidance' alongside the regs.

State your source in of info in writing in the observations box or attach to certs

 

[ADS]

Specs and KME,

You are both absolutely correct in the points that you are making.

The problem is, if you allow what you are saying - i.e. the average spark, out on the job, to make judgements as to whether certain regulations apply to his situation or not, then you are asking for trouble.

Not all sparks are as knowledgeable as you two gentlemen - which is why the regulations are there....to guide.

Some sparks might 'think' a certain regulation doesn't apply - but they might not realise the real reason behind the 'regulation'......they might be missing something.

I have no objection to you making these decisions about regulations, based on your experience and knowledge, and the job that you are working on, but if you decide a certain regulation need not be applied to your situation (as in Specs example), then it is a 'departure' from the 'regs' as they currently stand.

This is what the 'departures' box is for.

The 'Regs' are put together by some very clever and experienced people, but even they will admit that they haven't thought of everything - so they allow you to interpret and use alternative methods than what are outlined within the regulations.

But if you do so, for whatever reason, then you should note it as a 'departure'....because you aren't following the 'Regs' as they are written.

Only my opinion.

 

[Sidewinder]

ADS,

I can see what you are saying, however, if an "average" spark can't make such judgement calls then they must seek further professional advice.

Perhaps even thsy should not be workign alone.

Me I just do what I like and if I feel the need for a departure, or I feel that what I have done is a departure then I will fill it in as such.

HOWEVER, as departures are allowed in the regs then by definition they are not "disallowed", thus they comply! :tongue in cheek

The regs are not statutory, and there are many electrical situations where they have no relevance what so ever.

7671 is NOT a bible of electrical installation and is NOT intended to be it is a BS.

In itself it bows out to many other standards.

Also, it is a legal document, not a safe system of work, or method statement.

The latter 2 documents are better met with the GN's, but then not exhaustively.

I'll argue my corner with my NIC AE & have, and with others, and won.

I have yet to be called as a witness but the time will come.

Just hope I've done the PW trg by then!!!

Discuss more...

 

[kme]

Binky: I think PC was complaining about the lack of that option in SL`s poll, thou I could be sooooooooooooooooooo wrong :coat

ADS: I understand your concern, and agree completely about ignoring a reg because it isn`t "convenient" to adhere to it.

But I believe that those who know their way abound the BRB are the ones who will be showing an interest in this thread - the "wannabes" (no offence intended) who`ve retrained (for want of a better word) in a short space of time - many of them don`t adhere to the regs period (a la Steptoe`s LL post). Many don`t worry about the finer nuances of a reg, because they don`t worry about a reg at all.

I think those who do have the capability to post intelligently on this subject will do so - others will simply ignore it. The thread does allow us to see how some members perceive 7671, and its application.

Choosing to alter the "standard" perception of a reg`s definition shouldn`t be undertaken lightly - you are effectively saying that, in those particular circumstances, YOUR knowledge & experience are better than 7671 is - you`d better be ready to prove that one day!

n.b. I DID say that departures from a reg should be noted, along with the reason if considered necessary.

KME

 

[Zeespark]

I might be niave here, but I use the regs as the minimum standard to conform to. If I look a regulation up, and know that I can safely surpass its standards I will do just that. Awaiting to be shot down here.

Andy

 

[Sidewinder]

Zee,

You are correct.

We are I think here discussing those little difficult areas, such as but not exclusively a SELV supply in a special location, fitting an rcd to the cct is of no help at all.

However, it seems that the regs demand it...

 

[Zeespark]

BS7161:2008 went RCD mad, they are prosterior covering.

Andy

 

[Sidewinder]

Yes it did and they are one of the most unreliable devices known!!!

 

[Manator]

Could I pose a little question within a question so to speak ?

What would you reply if asked by your assessor " Do the regulations allow you to depart from those regulations?" .

I know my answer.

 

[Sidewinder]

I know mine too, probably the same as yours Manator!... PM

 

[SPECIAL LOCATION]

:Applaud :Salute

There's no option for applying 'other relevant published guidance' and/or 'tech help guidance' alongside the regs.

Quite right PC..

That will have to be "other"

 

[Zeespark]

I look at it this way with regards to the SELV debate, would you have had to RCD it during the reign of the 16th Edition? No, but because of wall thickness rules now, you would have to RCD it. There is mention of a change to the 17th to allow some discretion to the designer/electrician on this subject area if I am not mistaken.

Andy.

 

[SPECIAL LOCATION]

Specs and KME,You are both absolutely correct in the points that you are making.

The problem is, if you allow what you are saying - i.e. the average spark, out on the job, to make judgments as to whether certain regulations apply to his situation or not, then you are asking for trouble.

Not all sparks are as knowledgeable as you two gentlemen - which is why the regulations are there....to guide.

Some sparks might 'think' a certain regulation doesn't apply - but they might not realise the real reason behind the 'regulation'......they might be missing something.

I have no objection to you making these decisions about regulations, based on your experience and knowledge, and the job that you are working on, but if you decide a certain regulation need not be applied to your situation (as in Specs example), then it is a 'departure' from the 'regs' as they currently stand.

This is what the 'departures' box is for.

The 'Regs' are put together by some very clever and experienced people, but even they will admit that they haven't thought of everything - so they allow you to interpret and use alternative methods than what are outlined within the regulations.

But if you do so, for whatever reason, then you should note it as a 'departure'....because you aren't following the 'Regs' as they are written.

Only my opinion.

1/ I appreciate what you are saying ADS and I ALWAYS have respect for anyone who can debate and stand their ground on any opinion. (Better to have opinions than be a no-brain sheep IMHO ) Guinness

2/ Just because two persons have opposing strong views does not mean one is wrong and the other is right.. (It can be a little overlap from both parties)

3/ However.. I don't agree with some of your statements..

And I would like us to discuss them further without getting too hung up any one specific regulation at this stage..

We have touched on the bath/shower rooms situation..

Coming back to the Kitchen with SELV coming down the wall

and the "ALL CABLES" phrase from the regs..

Does it mean ALL CABLES...

What about communications, data, security alarm cables?

or just cables that could induce a fatal electric shock if pierced or damaged in some way.

You suggest note SELV with no RCD as a departure from 522.6.6 (reasonable suggestion and I can see the logic)

BUT... IMHO just following 522.6.6 without interpreting if it is applicable to a particular situation is also a DEPARTURE from BS7671!

Because BS7671 requires that all persons who carry out electrical work be competent with sufficient skill & knowledge to interpret the regs correctly.

i.e.

Erection & initial verification of electrical installations:- (pg 19)

134.1.1Good workmanship by competent persons or persons under their supervision and proper materials shall be used in the erection of the electrical installation. Electrical equipment shall be installed in accordance with the instructions provided by the manufacture of the equipment.

So a competent person must be doing or supervising the work..

and a competent person is:- (pg 22)

A person who possesses sufficient technical knowledge, relevant practical skills and experience for the nature of the electrical work undertaken and is able at all times to prevent danger and where appropriate, injury to him/herself and others.

So merging the Competent description into reg 134.1.1 we find that work encompass;

 

[ADS]

Another good post, Specs.

The only problem I have with it is that I think you're overestimating the competence/understanding of about 60% of the sparks out in the field, but, as you say, then their work should be being supervised by someone who is competent.

If the 2391, (aimed at experienced electricians, remember), is anything to go by, then the failure rate of 50 to 60 % is a sad reflection and shows that, although most can do their jobs well, they're lacking on the theory, and require the guidance of the 'Regs'.

There's also a lot of sparks out there who think they know electrics and the 'Regs' like the back of their hand, but couldn't be further from the truth.

This I noticed on my 2391 course, where some of the ideas and interpretations put forward were, literally, unbelievable - and this from 20/30 year sparks.

That said, if someone feels they're competent to make those kind of decisions, and can back it up with their knowledge if questioned, then why not.

As you rightly point out, sometimes knowledge and experience of a situation can count for more than a 'general' regulation.

Personally, I would still lean towards noting anything I 'depart' from, as it might not just be one 'SELV' related regulation, there could be a number of 'Regs' not followed to the letter and I'd like to leave a record of what I've done and why - even if it's just for the spark who follows me