RCBO advice

[Murdoch]

That is guidance only, not a reg. It is also manufactures trying to protect their interests.

of course.

The manufacturers have too much influence over the regs, why else are we getting expensive change over expensive change as the updates to the regs roll by

AND there are countless sparks who continue to ignore this and using any old carp in boxes. I came across a recent CU change recently. Up front RCD, metal case was one make, the RCD another, and the 4 MCBs were 3 brands …..

 

[apprentice87]

All very interesting stuff, a lot of it largely crap. In the foreword to the regulations [i cannot remember the wording] it says something about following them can be relied on to demonstrate compliance with the HSE laws..

In other words, never forget, that one day, you may be called upon to give evidence in a coroners court. If someone gets hurt or killed, and it is a result of you having deviated from the regs, then unless you are something like a chartered electrical engineer and can explain why your deviation was justified and safe, then you are going to be in more trouble than you have ever been in in your life.

THEN, try telling the coroner that; "m'lud, the regs are just a load od ******** with no force in law..."

Good luck with that one..

john..

 

[Mike.J]

They are not a Chartered Institution as they do not haver Royal assent as a member of IET you can apply for CEng through them, but that does not give you a chartered membership of the IET. see 3.1 here: https://www.theiet.org/media/8827/g...ieng-and-ceng-registration-september-2021.pdf

I have never said the document is wrong, its the wording on the front that is misleading, as I said at the beginning of this exchange, how do they get away with it?

As I investigated the process of trying to get a Charter for an Institute I was a director of I know something about the process and what you can, and more importantly, what you can't say in your published documentation.

 

[Mike.J]

THEN, try telling the coroner that; "m'lud, the regs are just a load od ******** with no force in law..."

But what you can say is: BS7671 is a British Standard and as all British Standards is a guidance document only, not the Regulations these being "Electricity at Work Regulations (1989)", the deviation in question went beyond the standard required in the BS and provided better protection as a result"

All very interesting as said above, but I think its important to understand the difference between Regulations and Guidance.

 

[Fleeting]

They are not a Chartered Institution as they do not haver Royal assent as a member of IET you can apply for CEng through them, but that does not give you a chartered membership of the IET. see 3.1 here: https://www.theiet.org/media/8827/g...ieng-and-ceng-registration-september-2021.pdf

I have never said the document is wrong, its the wording on the front that is misleading, as I said at the beginning of this exchange, how do they get away with it?

As I investigated the process of trying to get a Charter for an Institute I was a director of I know something about the process and what you can, and more importantly, what you can't say in your published documentation.

Tell the IET they are wrong in calling them regulations and they are a Chartered Institution.

 

[apprentice87]

But what you can say is: BS7671 is a British Standard and as all British Standards is a guidance document only, not the Regulations these being "Electricity at Work Regulations (1989)", the deviation in question went beyond the standard required in the BS and provided better protection as a result"

All very interesting as said above, but I think its important to understand the difference between Regulations and Guidance.

Yes, it is correct what you say, AND, as you say., if you could show that what you did was an improvement [or even just as good], then yes, as you say, you would be fine.. I would not like to put it to the test though!!

john..

 

[Mike.J]

I used to be on the Expert Witness register and this sort of question came up time and again, the presiding judge/coroner would have to make up their own mind and can only take on board the evidence presented to them, it is not for the witness's or the accused to give opinions unless asked.

 

[Sidewinder]

In my reply I will use CE to refer to CE & UKCA marking.
I will also use LVD to refer to the Low Voltage Directive and the Electrical Equipment Safety Regulations.
I will use harmonised to refer to both harmonised to the LVD and designated to the EESR standards.

As far as I am aware, in mainland Europe, it is rare if not unheard of to have an 80 or 100 A incoming 1ph mains supply; most are circa 30-40 A, 1 or 3ph.
A consumer unit falls under the LVD and must be CE marked as an assembly.
The normal route for this is by following product standards. The legal link between product standards and the LVD is much stronger than BS 7671 & EAWR because of how the product standards and the legislation are constructed.
The legislation states that compliance with a harmonised standard will ensure compliance with the EHSRs of the legislation.
The harmonised standards state that if certain clauses are met, then the EHSRs will be met by those clauses.
Now, whilst standards are voluntary, it is rare for a manufacturer to not follow standards because the level of work required is inordinate in comparison to the standards route.
Ergo, 99% of products are designed and manufactured to the product standards (assuming compliance).
A consumer unit has a product standard, the EN 60439, now EN 61439 series.
In there is a national annexe for the UK, Annexe ZA.
National annexes to harmonised standards are legitimate.
The UK has a national annexe because of the allowed 16 kA fault current at the origin of a normal domestic installation.
Apparently, the 30 - 40 A mainland European supplies do not have such fault current levels IIRC, it's been a while.
As a result, an assembly placed on the market in the UK must withstand this 16 kA of fault current without damage and without collateral damage.
Therefore, the manufacturer (placing the equipment on the market) must ensure that the assembly meets this requirement.
They can only do that by testing. They can only do that by testing their products.
Therefore, if you fit a different product, the type or partial type testing by the manufacturer to prove compliance with the LVD is no longer valid as the assembly is a new product.
You become the manufacturer of this new assembly.
The burden of proving compliance with the LVD falls upon you.
Few sparks have professional indemnity and product liability insurance for product design, manufacture, and supply.
So firstly, you may be working uninsured.
Next, you have created a product and placed it on the market without CE marking it; that is a criminal offence.
The original CE mark is invalid because of your modification.
The hazard is that there is no way to prove that the assembly created meets the requirements of annexe ZA in the standard.
You must follow this route to compliance because that was the route taken for the base product you modified.
Your only route is to follow the requirements of the product standard.
Remove and test the assembly, then refit it, which would be impossible because the test is destructive, so you would not have a DB to refit!
Therefore, there is a reason behind the no mix and match in the UK, and there is a reasoning behind why mainland Europe is different.
The choice is clear; it is up to the individual and their risk aversion.
If you are risk averse, then you don't do it.
If you don't care, then you mix and match, knowing that the job can never comply with BS 7671 and can never comply with, the LVD and is a breach of product legislation; that is, you are committing a criminal offence.
You can say that it is protectionism by the manufacturers, but then again, why should they take the liability for the actions of others?
Would any spark here accept liability for their work which had been modified or changed in some way by a third party, or would you say that as it has been modified, it's no longer my liability?
I know what I would be saying.
It is the same for the CU manufacturers. Why should they take liability for produces (rouge breakers) fitted to their assembly by persons whose competence is unknown to them?

You could argue that the product standard for circuit breakers should be enough for compatibility, but the fact is it is not.
If it were, we would have companies making the cheapest circuit breakers to fit, and it would be a race to the bottom concerning quality and safety for consumer units. It's approaching that now, but that's another topic.
This would reduce safety and detract from product innovation.

Question what I have written, but any personal attacks will be reported for moderation.
These are the facts; if you don't like them, that is not my fault, so don't attack me.
I don't like this situation, but, having gone through the legislation and the standards in detail and done expert witness work on product standards and legislation, it is difficult to get away from how they are structured.

 

[kerching]

@Sidewinder
I was just going to say exactly the same thing

 

[Geoff1946]

Brilliant explanation.

 

[binky]

can't argue with that!

 

[Murdoch]

Brilliant explanation.

Well, only to the people that actually bother to read it ................

 

[Badger]

French twist:

View attachment 13915

Prefer ponytails myself

 

[Sharpend]

well I think that’s cleared that up then.

Many thanks to Sidewinders expertise on subject matter.

 

[Sidewinder]

Well, only to the people that actually bother to read it ................

If you read it, you might learn something.

 

[Murdoch]

If you read it, you might learn something.

I did read it, your terse response is unnecessary

My point is that so few people even attempt to keep up to date.

 

[torbrowser]

Section 4.14 in codebreakers book gives this a C3 as long as no access to live parts or thermal damage.
I come across this a lot and as long as the breaker fits properly i go with the recommended code (on EICR)

Only you will know if the off brand breaker fits properly and is a sound connection, and whether this will cause future problems.

 

[Sidewinder]

Section 4.14 in codebreakers book gives this a C3 as long as no access to live parts or thermal damage.
I come across this a lot and as long as the breaker fits properly i go with the recommended code (on EICR)

Only you will know if the off brand breaker fits properly and is a sound connection, and whether this will cause future problems.

That is one of the codes I disagree with.

 

[Fleeting]

Section 4.14 in codebreakers book gives this a C3 as long as no access to live parts or thermal damage.
I come across this a lot and as long as the breaker fits properly i go with the recommended code (on EICR)

Only you will know if the off brand breaker fits properly and is a sound connection, and whether this will cause future problems.

What engineering judgement do you use to ascertain it 'fits properly' aside from what some Guide suggests. Or Is this a blind judgement based on this Guide.

 

[binky]

Where do we stand with 'badge engineering ' MCBs, wholesalers own brands are just another make with a different logo on, so are surely suitable for mix and match?

Some makes are direct copies of popular brands like MK, so fit perfectly, but I would say are not engineered to the same standards, so are no doubt fail the standards as pointed out by @Sidewinder