Where does BS7671 stop?

[Phoenix]

Now I appricate that Sidewinder is probably the best person to ask on this, and unfortunatly is likely too ill to give his input, but I thought I'd put the question out there....

On paper its simple, BS7671 covers the supply upto the terminals on the isolator of the machinery panel and then other standards take over, but its not normally as straight forward as that...

If someone adds a breaker in the panel and runs something else from it, is that covered by BS7671? maybe not if its just a socket on the side of the panel for the machine operator to plug related equipment in, but what if its a run of sockets along the wall on that side of the factory? How about if the pump panel gets its 32A TPN supply upgraded to 100A TPN, with a new 100A isolator fitted on the side, and alongside breakers for the motor and control circuit has now gained breakers for a couple of portacabins, site lighting columns and a few other things, its more a cobbled together DB than a machinery panel (although it is also still that)

 

[Sidewinder]

BS7671 clause 110.2,xi

 

[Phoenix]

I was more getting at, how do we define electrical equipment of machines, the classic view is anything after the panel isolator, so obviously anything machine up the machines and the controls for the same, is clealry under this category, now a sockt on the side of the panel, you could justify either way, possibly justify either way (possibly even behind why its there, if its for something to be used in conjuction with the machine then its part of the electrical equipment of the machine, but if its for the operators radio, then its just a convience socket thats been supplied off the machine, rather than part of it, which I'd say is defintaly the case where someone adds a breaker to a machine panel and supplies a canteen cabin, the cabin is beyond the isolator of the panel, but cannot be classified as part of the electrical equipment of the machine!

I guess what I'm trying to do is challenge the automatic view that 7671 stops at the isolator, in that after 'dipping out' of BS7671, you can 'dip back in' if a efed goes out to something completely unrelated to the machine, but socket outlets installed in close proximetriry to the machine, it might be not clear if they should be considered part of it or not. Would you be in agreement with this?

 

[Sidewinder]

No once 7671 stops the Machinery Directive takes over and all works must comply with the harmonised standards e.g. 69204-1.  Trust me it’s not a cop out.  The requirements are quite stringent.  The trouble is that most don’t understand what they are and they just ignore them.

 

[Phoenix]

What would your view be on finding the above situation on an EICR then (motor panel driving a sump pump has had breakers added and is now supplying a couple of site cabins, some lighting columns around the site and god knows what else)

1) The cabins, et all must now comply with 69204-1, but thats outside the scope of BS7671 so are excluded from the test

2) The cabins are in the scope of BS7671, but the submain to them isn't, in the same way the DNO supply into a house isn't

*) They simply should not have been supplied this way, and this causes problems under both standards and it requires sorting out

 

[poni]

1) The cabins, et all must now comply with 69204-1, but thats outside the scope of BS7671 so are excluded from the test

2) The cabins are in the scope of BS7671, but the submain to them isn't, in the same way the DNO supply into a house isn't

why would any of this be out the scope of BS7671?

its all connected to the same supply(DNO) Whether it's feed from a DB or an MCC Panel, you still need the  Zs , IR and volt drop to comply with BS 7671

 

[Sidewinder]

A motor control centre is outside the scope of BS 7671, it either falls into the product standards as in the 61439 series.

Or, it falls outside BS 7671 by clause 110.2,xi and thus falls into the scope of EN 60204-1.

The issue is that if the MCC is really an MCC and built to the 61439 series, then it cannot be used for powering machinery unless the whole installation is then undertaken to 60204-1 and CE marked.

The 61439 series are not harmonised to the machinery directive.

If the presumption of conformity route by the use of standards has been chosen, then this needs to be done.

If the modification is done without the use of standards then the technical file must reflect this and demonstrate that the equipment meets the EHSR’s of the directive.

If it is ever involved in an investigation, the. point of reference for ensuring safety of the assembly will be the harmonised standards, and proving that the equipment provides the same or greater level of safety then if they had been used.

It’s a complete cluster crock and should be sorted.

If the MCC (Is it, REALLY an MCC) is being used in this way then it is being used as a product and thus falls into the remt of 61439 and thus requires the appropriate testing, documentation and a technical file must be created.

If the equipment was not originally like this and it has been. modified, then the person who has undertaken such modifications is now the OEM, and they must sort out the documents, testing etc. for the product to be legally placed on the market/into use.  So if the equipment use has been changed from a machine panel to a distribution panel etc.etc. then that must legally be assessed and measures put in place to meet the legal requirements.

BS 7671 does NOT apply to all electrical equipment, hence section 110.2,, exclusions from scope.

The issue here is that you have imbeciles running a BS 7671 supply to equipment which is out of the scope of BS 7671, then modifying that equipment to take supplies away to “equipment” that does fall within the scope of BS 7671.

My take would be the best that can be achieved is an FI.

I would inspect & test the supply to the MCC panel against BS 7671.

I would I&T the supplies leaving the MCC and the relevant attached equipment against BS 7671.

I would do a check on the panel against EN 60204-1 & the relevant part of EN 61439, and I would report any discrepancies.

I would obtain the OEM data for the MCC and then FI the EICR with an instruction to the client that until the safety of the modifications to the MCC to supply the additional loads is checked and verified by the MCC OEM, or other competent “person” who can provide the relevant test data on the assembly that the way the installation is configured is not only. in breach of BS 7671, EN 60204-1, the relevant parts of EN 61439, but also likely not to be compliant under EAWR and quote the EAWR clauses that are likely breached.

If there are safety functions built into the MCC, e.g. e-stops, or other safety dependent interlocks or functions of some sort, then you are immediately outside the scope of the LVD, and into the MD, and thus EN 6020401, and the machinery panel is no longer CE marked without a full assessment and documentation of that assessment  by a competent person, proving that the panel still meets the EHSR’s of the MD and the requirements of the safety functions have not been compromised in any way.

This scenario is also a breach of PUWER Reg 10.

Just because the equipment is not covered by BS 7671 does not mean that IR, ADS and the other protective measures that are described in BS 7671 are not relevant and required.

EN 60204-1 also requires safety measures similar to BS 7671, some are actually more onerous.

It is however, not correct to apply BS 7671 to equipment and systems out of scope.

 

[poni]

Well that's me told off

 

[Sidewinder]

Well that's me told off

Not at all mate, I’m sorry of it came across that way.

It’s taken me about 3 hours to put that together, so I was worried that it was disjointed..

I’m a bit straight to the point at the moment because the pain I have is a little of a nuisance.

I am guessing that the general forum populous is unaware that I am currently unaware that I am hospitalised.

I have recently been diagnosed with highly advanced prostate cancer, which has spread to my skeleton and primarily my spine.

This has resulted in paralysis from the waist down, unimaginable pain, which we have now under control with controlled drugs and I have had some radio therapy which has helped.

I am also undergoing hormone treatment which should hopefully get the cancer under control.

Prognosis is as yet unknown as it depends on how my body reacts to the treatment.

Whether I can ever walk again, well again that depends, but at the moment, no, I am likely to be confined to a wheel chair for the rest of my life, however long that is.

Anyway, Poni, I apologise if my message came across in any way aggressive, offensive or in any way upset you, I assure you it was not meant to.

I just wanted to get the facts down for Phoenix to move forward.

I hope that there are no bad feelings, because that was never my intention, I promise.

 

[poni]

Sorry to hear that you are so unwell 

I have taken no offence at all, 

Infact its me that shiuld apologise as my coment was ment "tongue in cheek" 

It's was very well put together and I have learnt something 

Every day a school day

 

[Phoenix]

Thank you for your comprehensive reply Paul. I'm hoping the medical situation improves for you soon I'm guessing the whole virus situation has hindered the speed of the original diagnoses?

I'm guessing you'd feel a C2 justified for the mis-use of a panel / MCC as a DB?

You make comments to, is it really a MCC, what defines a MCC?, Im assuming that a simple panel with a contactor, O/L and float switch with 240v control might not be classed as one, but other panels on this site would be classed as such with rows of VFDs for various motors throughout the plant.

The porblem is that this site is a a bit of a state, both in terms of BS7671 and machinery (which is out of my area of expertise) but you see things that are 'obviously' not right. I'm looking at the installation under BS7671 and ensuring that anytghing that falls under other standards is excluded with a comment that they should be accessed by a specialist in this area.

You mention technical files and CE marking, HAH,  most of the panels on this site are assembled on site with not even a drawing, even the ones that came from a manufactor are full of undocumented modifications and its not unusual to find relays hanging loose and conductors run everywhere, but not my monkeys and not my circus, the recommendation to bring a suitable specialist in to access to the machinery side tends to fall on deaf ears, I dread to think what such an inspection would throw up! The mantenance staff cannot get the BS7671 stuff right

What consitutes a DB is very blured here,. you often find some MCBS clipped ona bit of a DIN rail and fixed into a GRP enclosure as a poor mans DB, well I say 'poor mans' but its always schneider they use, so I have a feeling its not financial related, its more to do with what can be found in the stroes at any given moment!

 

[Sidewinder]

@Phoenix

In house built equipment is subject to the same laws and requirements as those bought in.

In fact, in house built equipment is specifically mentioned as included in the legislation.

I would go with FI or C2, in this case I would also be adding the EAWR & PUWER law breaches with regulation numbers.

Remembering that whilst we call 7671 regulations it is not in the eyes of the law, the individual regulations in BS 7671 are actually just clauses of the standard.

Where as for example EAWR has Reg 29, which is a real regulation and is your defence regulation to keep you out of jail.

Puwer Regulation 10 is real law so is a real regulation.

Now when it comes to an MCC, that is a specific kind of panel that only contains motor start gear,  if you have VSD’s etc. then these are NOT MCC’s.

If you are back on site, take some pictures and I’ll give you some guidance.

@poni

Thank you for the understanding. I really didn’t mean any offence.

You don’t need to apologise I promise.

All’s good yeah? 

As you know this is my “bag” and I don’t mind putting the facts out there for people to learn.

I know I am unwell and I have good and bad days, I am facing the first Christmas in my life away from my family which is a blow.

Psychologically I am not always good, facing cancer does that to people.

I have been very lucky and grateful to the IET Foothold charity that has provided us with some financial support, and one of my fellow IET members has started a just giving for me, otherwise, well, we still might, be facing extreme financial hardship.

Though the foothold and just giving will help.

Being able to answer questions like this keeps my brain going and helps to keep me sane.

It’s not always easy and quick because my levels. of pain vary during the day and day to day.

Plus my mental state has a massive impact on my ability to concentrate.

However, doing this helps me a lot, when I am able.

 

[phil d]

Sidewinder, a couple of points, we've not always got on, you are like me, you can be a bit prickly at times, or as our mate Tony would have said, ' a pain in the arse' lol, but you know your stuff on machinery and the like. The whole thing of taking power from X to power Y is a minefield and quite often it is got wrong by people who really out to know better, recently I have taken to reading the stuff on the HSE website and some of it makes scary reading, it's even worse when you see it done in the 'real world'.

In my foray into the rail industry I saw a great many things that disturbed me, and breached safety rules, one particular railway company issues it's engineers with Fluke voltage indicators (test lamps) to prove a section of electrified track (3rd rail ) is dead, this is despite the fact that the Fluke does not have the large collars to prevent your hand slipping onto the live rail (Fluke are about one fifth of the price of the proper tester) cost is the governing factor here.

I really do think that there are far too many people in the electrical industry who see a machine, particularly a large one, as just another source of supply, without any real idea of the potential risks of 'strapping off' said machine to feed something else.

Anyway enough of that for now, I'm sorry to here just how ill you are, it doesn't sound good, but it's one of those isn't it, I hope they can do something for you, but if it turns out they cannot then I hope you can enjoy whatever time you have left with your family, being ill or losing friends is a great one for concentrating the mind, you suddenly realise what REALLY is important. Anyway take care my friend, drop me a line if you want to moan to anyone, I'm good at listening, lol. All the best to you and yours at what must be a tough time for you all, Phil.

 

[Sidewinder]

@phil d, thank you for the message.

Funnily enough, Tony & I were often at loggerheads over things.

That was until we spent a couple of hours on the phone together talking about work, machines and just stuff.

 I had always had the greatest respect for Tony, but I always rubbed him up the wrong way.

After we spoke he understood my psyche and why I am the way I am.

 I also understood where he was coming from.

After this we got on very well.

One big regret that I will take to my grave is that I never managed to make time to meet him in person.

I agree that there are too many people that meddle with things that they don’t understand what the ramifications of their actions are.

 

[phil d]

@phil d, thank you for the message.

Funnily enough, Tony & I were often at loggerheads over things.

That was until we spent a couple of hours on the phone together talking about work, machines and just stuff.

I had always had the greatest respect for Tony, but I always rubbed him up the wrong way.

After we spoke he understood my psyche and why I am the way I am.

I also understood where he was coming from.

After this we got on very well.

One big regret that I will take to my grave is that I never managed to make time to meet him in person.

I agree that there are too many people that meddle with things that they don’t understand what the ramifications of their actions are.

He didn't suffer fools gladly and the other thing with him was he'd met so many idiots he found it hard to believe there was intelligent life out there, lol. I remember him telling me about your little chat, ' that Paul isn't bad when you get to know him' he told me, high praise indeed from Tony, I remember our little chat too, I thought me and you got on rather well, incidentally when I was at his flat today his family let me into a little joke about the song they played at his funeral, it had a video that went with it, naturally they didn't show that at the service, but it typified Tony, growing old disgracefully, lol




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