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RCD required?

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I've got a dist board to replace in a factory.

It's a SP&N board which serves the canteen and some store rooms below.

The switch drops are concealed within the fabric of the walls with no metallic protection.

Would you RCD protect the lighting circuits?
 
Would you RCD protect the lighting circuits?
If you mean regs-wise, then I don't see why you should need to - I don't think that there is any requirement to bring all of an installation 'up to currents standards' when replacing a DB, is there? If you believed that was required, where would you stop? Would you, for example, seek out and replace all the inaccessible JBs?

One presumably deals with any 'unsafe' aspects of an installation before/at the same time as replacing a DB, but I would have thought that a reasonable rule of thumb might be to only 'feel obliged' to rectify things that would have got a C1 or C2 on an EICR. However, I'm sure that "opinions will vary"!!

Kind Regards, John
 
If you don't, you need to attach the risk assessment go the certificate, which is listed on page 1.
 
Some times one really knows something will never happen, but you still write it down, in your example RCD on lighting circuit delayed fitting until emergency lighting modified in order to reduce the risk of occupants being left in dark.

It is always a problem when looking at RCD and lighting, we all know any industrial premises should have emergency lighting and we also know often it either does not exist or only lasts a fraction of the time it should before it fails. In one place I worked there was a real vandal problem we were for ever replacing outside emergency lights designed to light the emergency exits and main problem is it could be weeks between checking and finding they were damaged. Ended up with rechargeable torches just inside the emergency exits which really were not good enough as only really helped the first group of people to exit.

In real life you have to use some common sense and bend the rules. The Awaiting for XYZ before ABC is done may not be a legal option or comply with regulations. However it shifts the blame if something goes wrong. Even awaiting emergency lighting access report before fitting RCD shifts the blame onto some one else should it not work out.

We were forever arguing about outside lighting. In the event of a real power cut clearly all street lamps fail. But we could only emulate a local power cut to our premises only, so the safety officer could not say if we had enough EM lighting or no it was just a guess. He would say I think we need more lighting here. And my boss would say when you have found out let me know. And repeat a rhyme about "Thought" and sweating.
 
With 17th amd3 CD rules for concealed cable are now the same for commercial as domestic

"It is now required to protect cables concealed in a wall or partition (at a depth of less than 50 mm) by a 30 mA RCD for ***all installations*** if other methods of protection, including the use of cables with an earthed metallic covering or mechanical" from iet amd 3 changes doc (*** mine)

John - When you replace/upgrade CU in domestic you bring the circuit protection 'up to current standards', if you replace a plug with unsleeved pins or wooden-backed switches, you upgrade to current standards... but you don't search out hidden jb's on a CU upgrade job just as a joiner wouldn't search for woodworm when there to fit a kitchen.

The reference to risk assessments that i've seen regards omitting rcd protection of sockets, I didn't think it was applicable to concealed cables, maybe someone with the latest regs book can clarify?
 
John - When you replace/upgrade CU in domestic you bring the circuit protection 'up to current standards' ....
Is that actually an explicit requirement of BS7671 (in relation to the sort of issue we are discussing)?
... but you don't search out hidden jb's on a CU upgrade job ...
So where do you draw the line in terms of "bringing the installation up to current standards" when you replace a CU?

If providing RCD protection for buried cables is a requirement, then one presumably could not invoke 120.3 in an attempt to get around omission of that as a "departure", since it would be impossible to argue that the installation was "no less safe" without the RCD protection than it would have been with it. .

I would imagine that, other than for installations wired in steel conduit, the vast majority of all circuits in all domestic installations will have at least some cable which is buried in walls. You are therefore presumably implying that, usually, all circuits will have to be RCD protected when one replaces a CU?

Kind Regards, John
 
I would say usually the primary reason for replacing a CU is so that RCD protection will be added.

You can obviously leave a circuit without if you consider it necessary for some reason.

Other than earthing and bonding, it is not required to "bring the installation up to current standards".
Something considered dangerous would be rectified or not be connected.
 
I would say usually the primary reason for replacing a CU is so that RCD protection will be added.
Yes, very commonly. However, providing RCD protection for buried cables might be quite low in list of reasons for wanting to add RCD protection. However, I must admit that I wondered why RF asked the question - is there perhaps some reason why he does not want to RCD-protect the lighting circuits (which would obviously be possible with a new DB)?
You can obviously leave a circuit without if you consider it necessary for some reason.
That's what I thought.
Other than earthing and bonding, it is not required to "bring the installation up to current standards".
Again, that's what I thought and wrote - but, as I suspected would be the case, there appear to be some contrary views!
Something considered dangerous would be rectified or not be connected.
Indeed. I still think my 'rule of thumb' would be reasonable - to only feel that something 'must be rectified' (or not connected) if it is something that would get a C1 or C2. If only C3 (or nothing!) I would not personally feel that it was something that one 'must rectify' as part of a CU/DB change.

Kind Regards, John
 
As skenk says, there is no longer a get out for an installation under the control of a skilled or instructed person.

So to fully comply with 7671 RCD protection is required. However whether or not you do on a board change is perhaps a little bit of a grey area.

1) You could say that as the cables are not currently RCD protected that by changing the board, you have not made it any worse than it already is in terms of 7671 compliance. This is an idea which crops up in a few places, such as building reg.s and 5839 for fire alarms.

2) The other school of thought is if you are changing a protective device, then can you say you have complied with 7671 if the devices you install do not provide all the protection the circuit requires under the current edition?

I don't really have a problem with (1) as long as one has considered fitting the RCBOs and had to decide not to do it for various reasons, rather than just saying "Its a board change, we can get away without RCD'ing the lighting"

Perhaps RF should tell us why he is wishing to omit RCD protection to the lighting?
 
Is that actually an explicit requirement of BS7671 (in relation to the sort of issue we are discussing)?
You're installing a CU. You install it to the latest version of the regs. If you connect a circuit which should be RCD protected and you don't RCD protect it, your CU installation is not in compliance with '7671 (note a departure on the EIC, quote/estimate for fault finding/repair/issue warning notice/paperwork if appropriate and move on).

So where do you draw the line in terms of "bringing the installation up to current standards" when you replace a CU?
You don't draw lines, you do the work you are doing to the regs (so, in this case a CU installation), do the bonding & earthing and that's it. You're not there to search for dodgy junction boxes, you're there to replace the CU. By all means, with the clients approval, fix the dodgy socket you find (or whatever) and add some extra to the bill; note & quote to repair defects you find; factor £50 in the CU job for the (inevitable) little repairs ?(or do an eicr beforehand..). It's very simple the work you do, you do to the regs, the rest of the installation you leave alone (if only there to replace CU)

You are therefore presumably implying that, usually, all circuits will have to be RCD protected when one replaces a CU?

That's what usually happens (if all circuit cables are buries less than 50mm), yes.

Of course in diynot-land nobody gets their CU replaced without a full EICR and they would know about any issues beforehand, in reality it doesn't always work like that.
 
So to fully comply with 7671 RCD protection is required.
I don't think that is in dispute, but ....
However whether or not you do on a board change is perhaps a little bit of a grey area.
... which is the question we've been asked, and are discussing. As you go on to say, one can argue both ways.
Perhaps RF should tell us why he is wishing to omit RCD protection to the lighting?
Indeed, and I have already asked that question. If he feels that, for whatever reason, that it would in some way be 'safer' (or, at least, 'no less safe') to omit the RCD than to include it, then he could declare a departure under 120.3.

Kind Regards, John
 
Last edited:
Is that actually an explicit requirement of BS7671 (in relation to the sort of issue we are discussing)?
You're installing a CU. You install it to the latest version of the regs. If you connect a circuit which should be RCD protected and you don't RCD protect it, your CU installation is not in compliance with '7671 ...
I'm not sure that it's necessarily as simple as that. Nothing in the regs says that the RCD protection has to be within the CU, so what you seem to be saying is that when replacing the CU it's necessary for the circuits to which it is connected to be fully compliant - and that would included the JBs etc.
(note a departure on the EIC, quote/estimate for fault finding/repair/issue warning notice/paperwork if appropriate and move on).
I'm not sure you could do that (and still sign the declaration). The standard EIC forms only allow for departures in relation to 120.3 and 133.5 - and I think it would be difficult for you to argue that the installation was 'no less safe' without the RCD protection than with it, wouldn't you? There is, AFAIAA, no provision for declaring a departure which you believe has resulted in the installation being less safe than would be the case with full compliance with the regs.

Kind Regards, John
 
If there are machines in use, plunging a factory into sudden darkness will certainly make it less safe. Insulation fault monitoring would be far better in an industrial situation.
 

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