OK,
Here we go:
I’m of the opinion that a board that is bottom hinged does not comply with the guidance issued by BEAMA, who are their trade body for compliance with the spirit of Amd3.
The crux of this is the lid opening down and thus the ability of this lid to be left open.
This then does not contain the plastic breakers within the non-combustible, metal enclosure assembly.
See the BEAMA guidance, link here:
http://www.beama.org.uk/asset/7DF1EEE0-F314-452B-81E276BC561F4B89/
This will download the file to your pc, I have attached the pdf anyway.
(Sorry pdf didn't attach)
It was stated by the sales representative during a 25+ minute phone call with myself, that there is nothing in BS7671 that requires a self-closing lid.
This is correct.
BS7671 is an installation standard.
IMHO it has no business dictating product requirements, however, we now have to live with this ill thought out and badly conceived regulation.
The product standard is EN61439-3.
However, BS7671 requires this “additional” situation of a non-combustible enclosure, of which steel is an example of a material that will meet the intent of the regulation.
There is a description of a polymer material test that, should, meet the regulation in EN61439-3, it refers to other product and testing standards.
However, BEAMA (and its members) have gone down the steel route.
As there is no real product standard to go by, one only has BS7671, the associated guidance from the IET and that from the product manufacturers association, BEAMA to judge the requirements by, oh, and when things go all pear shaped, you’ll have to stand in front of the wigs and justify why your board with a downward opening lid caught fire, and killed people.
Remember, because BS7671 is an install standard, you can’t rely on the product standards to back you up.
The board can comply with BS7671, & EN 61439-3 and have a lid that opens both ways, but, if it opens downward and the thing catches fire and burns the house down and kills people, it will be the installer who is to blame, and who will be found guilty because of the inadequacy of the standards and guidance.
So my statement of “non-compliant” could be true or false.
However, this will never be proven until it goes to a court of law, and by then someone will be dead, and that is wrong.
Also an installer, who may well be competent, but, have installed a defective device correctly will be the defendant, and “he” will be hard pressed to prove his innocence.
Now.
BS7671 states:
[SIZE=10.5pt]421.1.201 Within domestic (household) premises, consumer units and similar switchgear assemblies shall comply with BS EN 61439-3 and shall:[/SIZE]
- [SIZE=10.5pt](i) have their enclosure manufactured from non-combustible material, or[/SIZE]
- [SIZE=10.5pt](ii) be enclosed in a cabinet or enclosure constructed of non-combustible material and complying with Regulation 132.12.[/SIZE]
[SIZE=10.5pt]NOTE 1: [/SIZE][SIZE=10.5pt]Ferrous metal, e.g. steel, is deemed to be an example of a non-combustible material.[/SIZE]
[SIZE=10.5pt]NOTE 2: [/SIZE][SIZE=10.5pt]The implementation date for this regulation is the 1st January 2016, but does not preclude compliance with the regulation prior to that date.[/SIZE]
Next we need to look at what BEAMA define as the enclosure.
Please see the pdf, in this link:
and if you look at point 2 on the second page, and the associated diagram, Diagram 1, then this becomes clear.
Noting also that the BEAMA document is dated June 2015.
http://www.beama.org.uk/asset/7DF1EEE0-F314-452B-81E276BC561F4B89/
Now we need to look at what is an enclosure and what an enclosure does.
So if we look up the meaning of enclosure in the Oxford English Dictionary, where else can we go?
It is not up to you or I to define the term enclosure.
The word enclosure suggests that it is something that encloses another thing.
Now a consumer unit consists of 3 main parts which make the enclosure, basically, the back (base), the front (cover) and the access cover for the breaker operating devices (door). This is defined in the BEAMA document, attached and linked, point 2 on page 2.
We cannot go to EN61439-3 for any of this as it is not defined in the product standard, it is a bodge from BS7671, we can only refer to BS7671 & the manufacturers trade body for guidance as this is a .2xx regulation.
Looking to the Oxford English Dictionary (online, accessed 09/09/15).
The word enclosure has several meanings.
Those relevant are below:
enclosure, n,
1. The action of enclosing.
2. That wherewith something is enclosed:
a. An outer covering or case; an envelope.
Now taking the last word of these definitions copied directly from the OED, the last word, envelope.
As in envelope that one would send a letter in, or envelope, as in to cover completely “I was enveloped by my duvet in bed Sunday morning because it was cold outside” kind of thing.
Does this make sense?
If one looks up the etymology and words associated with the word envelope, then these all point towards a total enclosure or total surrounding of something.
The etymology of the word enclose thus enclosure also directs the reader to something, totally, surrounded.
I am not the person to argue with, The, Oxford English Dictionary (oed.com).
I will leave the reader to look up the various derivations and mutations of enclose and envelop.
However, they all point toward the same thing, totally covering or enclosing (I can’t think of a better word) something.
So, it seems from the definition of the words given in the OED, BS7671, is very explicit in its requirements.
That the whole board encloses fully the devices therein.
Ergo, if the cover over the breaker operating devices (door) does not envelop these then it is not an enclosure as it does not enclose the breakers.
Remember, we have only BEAMA guidance and EN61439-3 to look to for what a consumer unit consists of.
I’ve not looked to EN61439-3, however, I can & will if needed.
However, I VERY much doubt that the BEAMA definition will be in contravention of that given in the EN std.
Noting, that the EN standard, is the product standard that these boards must meet, to comply with the Low Voltage Directive, therefore to be legal for sale in the EU, thus the UK.
So, taking this onward, and using the Electrium Crabtree board as a comparison.
The fundamental design of the board is such that it will default to being an enclosure.
The breaker access lid is top hinged so it will be self-closing, thus default to enclosing the devices fully, as per the definitions of the words given in BS7671 by the Oxford English Dictionary.
A bottom hinged lid however will not
Hence my issue.
Now, one can prop the door on the Crabtree open, however, that is a modification to the default design.
The door on a bottom hinged assembly could be knocked open and would then not default to being an enclosure.
Take from this what you will.
In the event of a court case, I suspect that an expert witness would go down this same road as I have here.
IMHO those utilising a bottom hinged lid are wrong, and unless you can argue in court that the words used do not actually mean what the OED says they mean then you are on a hiding to nothing.
If this email were presented in a court of law, I would expect that a Judge/Jury would agree with it?
What do you think, now I’ve put it this way?
We are not in a position to argue with the definitions put in BS7671 when they are confirmed by the OED IMHO.
I have sent this to BEAMA and they have ignored my questions.
So BEAMA, have refused to comment upon my argument.
Remember these are not my definitions of interpretations of the words used they are those of BS7671 & the OED.
Almost all of the major manufacturers have gone with a top hinged lid.
Whilst this is my opinion, I have not “made up” my own definitions, the definitions of the words, phrases, and specifications are those from BS7671, the OED, & BEAMA.
Now, I know one of our members has a relative who is in the legal profession.
I would seriously appreciate this being passed to him, and to get his interpretation.
BTW, you know who I am on about, & you know how to get me, away from here if needed!
