Landlords test certificate.

433.1.204 does not say "Accessories to BS 1363 and anything else which the designer thinks are equivalent may be supplied through....". It really does not.
It doesn't. However, 120.3 says that the work will be compliant with BS7671 if the designer can demonstrate that whatever is being supplied by the circuit makes the circuit no less safe than it would have been if the words of 433.1.204 had been followed literally and rigorously.

Kind Regards, John
 
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What if I were to assert that the intention of JPEL/64 is that 120.3 shall be used to cater for new inventions, not to allow an explicit regulation to be contravened because someone who doesn't like the regulation would rather do something different?
I, for one, would ask you to point out exactly where it says that it's only for new inventions (however they might be defined) and can't be applied to existing types of apparatus. Does it actually say any such thing? (Perhaps somebody would quote the precise wording of 120.3 at present.)

It would be an irrelevant argument, as the issue of whether a CU supplied through a ring final is safe or not is irrelevant.

433.1.204 does not say "Accessories to BS 1363 and anything else which the designer thinks are equivalent may be supplied through....". It really does not.
It may not, but does that matter if there's something which overrides that?

Regulation A says that you must do X. Regulation B says that you may disregard regulation A so long as you do Y. So if you don't do X but have done Y, have you not complied with the regulations as a whole?
 
I, for one, would ask you to point out exactly where it says that it's only for new inventions (however they might be defined) and can't be applied to existing types of apparatus. Does it actually say any such thing? (Perhaps somebody would quote the precise wording of 120.3 at present.)
It very much doesn't. It merely talks about 'deviations', with no qualification at all. As I wrote last night, there IS a corresponding (and very similar) regulation which is specifically about "new materials and inventions" (133.5) - which, to me, underlines the fact that BAS's suggestion/interpretation regarding 120.3 makes little sense.

Kind Regards, John
 
If we go back to the 16th, 120-02, which was the one about new materials and inventions, was in the same chapter as 120-01.

So is it unreasonable to interpret the intention behind departures as being to do with new materials, rather then "don't like it, want to do something different"?
 
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But when it comes to the specific ring regulation, weren't you just saying that it's not for us to interpret what we think they might have meant to say, but only to go by what the wording of the regulation actually says?
 
If we go back to the 16th, 120-02, which was the one about new materials and inventions, was in the same chapter as 120-01.
Maybe it was, but so what? What concerns us is what the regulations in Amd3 of the 17th edition actually say.
So it it unreasonable to interpret the intention behind departures as being to do with new materials, rather then "don't like it, want to do something different"?
You are the one who is usually criticising people for guessing that the intent behind a regulation was what they would like the regulation to say.

What 120.3 "actually says" is very clear. There is no qualification regarding the reason for the departures, merely that they must not result in a lower level of safety than would have been achieved by full compliance with the specific regulations in BS7671. You might "want" it to say something else, but it doesn't.

Kind Regards, John
 
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But when it comes to the specific ring regulation, weren't you just saying that it's not for us to interpret what we think they might have meant to say, but only to go by what the wording of the regulation actually says?
Oh dear - is that the sound of a penny dropping for you?
 
Maybe it was, but so what? What concerns us is what the regulations in Amd3 of the 17th edition actually say.
Why does the change matter?



You are the one who is usually criticising people for guessing that the intent behind a regulation was what they would like the regulation to say.
I asked you if it was unreasonable.

Is it?


What 120.3 "actually says" is very clear. There is no qualification regarding the reason for the departures, merely that they must not result in a lower level of safety than would have been achieved by full compliance with the specific regulations in BS7671. You might "want" it to say something else, but it doesn't.
Isn't that what I have been trying to get you to understand?
 
Oh dear - is that the sound of a penny dropping for you?
How so? I was pointing out that you seem to be applying a double standard, saying that one regulation should be taken to mean exactly what it says without room for interpretation as to what you or I might think it was intended to mean, while at the same time claiming that it's acceptable to "interpret" another rather than just taking it exactly as written.
 
Why does the change matter?
Because, presumably, if there had been no intent to change the meaning, or at least to clarify what meaning was intended, then it wouldn't have been changed?

You are the one who is usually criticising people for guessing that the intent behind a regulation was what they would like the regulation to say.
I asked you if it was unreasonable.
To think that it was intended to allow for new types of apparatus? No, that's not unreasonable. Neither is it unreasonable to take it that it is referring to the use of existing types of apparatus which provide a similar level of safety.
 
How so? I was pointing out that you seem to be applying a double standard, saying that one regulation should be taken to mean exactly what it says without room for interpretation as to what you or I might think it was intended to mean, while at the same time claiming that it's acceptable to "interpret" another rather than just taking it exactly as written.
But you think that interpretating is acceptable. Are you saying that, in general, it is OK for people to "interpret" regulations in a way which supports your position, but not when it undermines it?

Because, presumably, if there had been no intent to change the meaning, or at least to clarify what meaning was intended, then it wouldn't have been changed?
Oh, I see.

You take the change to mean that they wanted to change the meaning, or to clarify what they intended it to say.

But when it comes to a regulation which they have not materially changed for at least 15 years you refuse to accept that that means they are happy with the meaning as written, and consider that it quite clearly expresses their intentions.


What's going on here, with you and JohnW2, is very similar to what happened regarding high integrity earthing.

It's not a case of a regulation being impossible to comply with because it requires something undefined, like "power circuit". It's not one that can't be complied with because it's physically impossible, like "non-combustible".

There is no reason whatsoever why you cannot comply with only having BS 1363 accessories supplied through a ring final, but you just don't want to.

Again, you have seen a regulation which you do not like, and therefore you seek to find ways to rationalise your refusal to comply with it, and to justify your contravention of it, by wittering on about "what they really intended", about "common sense" (funny how in your eyes that always equates to "let's find a way to not do what they say", rather than "let's try and comply").

It matters not that you think that JPEL/64 intended something other than what they wrote - they wrote what they did and a CU supplied by a ring final, either on the ring or on a spur, does not comply. It really does not.

It matters not that you think it is safe, a CU supplied by a ring final, either on the ring or on a spur, does not comply. It really does not.

It matters not if you are correct in your assumption that JPEL/64 intended something other than what they wrote - they wrote what they did and a CU supplied by a ring final, either on the ring or on a spur, does not comply. It really does not.

It matters not if you are correct about the safety, a CU supplied by a ring final, either on the ring or on a spur, does not comply. It really does not.



Your refusal to comply with the regulation because you simply don't want to is unacceptable. It really is.
 
I don't see why not, if the point of connection to the rfc is near enough to the centre that the requirements for protection of parallel conductors are satisfied. Whether a CU spurred off a ring is a good design though, is another matter.
 
I don't see why not, if the point of connection to the rfc is near enough to the centre that the requirements for protection of parallel conductors are satisfied.
Indeed so, but it is apparent that BAS's main point is nothing to do with the degree of cable protection per se. The point he is labouring is that, because of what 433.1.204 "actually says" (and doesn't "actually say"), a ring final loses its dispensation to be wired in cable with CCC ≥20A protected by a 32A OPD if anything other than "an accessory to BS1363" is connected to the ring. In other words, he would presumably say that the whole ring became 'non-compliant' if it (amongst other things) supplied a load via, say, a 1A or 3A MCB.

Kind Regards, John
 
Bas has now stated:
a CU supplied by a ring final, either on the ring or on a spur, does not comply.
Where has this come from?

The spur does not have to be wired in the same way stated by 433.1.204 for a ring and as such obviously does not have to comply with it. So how can it be said that the ring becomes non-compliant when the spur is different.

E.g. the spur does not have to have a minimum csa of 2.5mm²,
does not have to have a minimum Iz of 20A, (apart from, possibly, the agreed ridiculous Table 52.3),
is not itself a ring,
does not have allowances built in for unbalanced loading and
is not restricted to supplying BS1363 accessories.
 
Bas has now stated:
a CU supplied by a ring final, either on the ring or on a spur, does not comply.
Where has this come from?
I presume it comes from his belief that (from the words of 433.1.204) if a ring final ("with or without spurs") 'supplies' something which is not a BS1363 accessory (i.e. if the first thing the electrons hit {either in the ring itself or in a spur} is a non-BS1363-accessory) that it invalidates the OPD/CCC dispensation for ring finals.

Kind Regards, John
 

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