Electric under floor heating, and BS 7671

735.411.3.2 was not in BS7671:2008 (At least I can't find it.) only in BS7671:2008 Amendment 1 so that document they have sent you is out of date.
Eric, if you are literally looking for 735.411.3.2, that does not exist, and never has existed; indeed there is no Section 735.

What you should be looking for is 753.411.3.2, which was present in the original BS7671:2008 in exactly the same form as in the 2011 Amendment.

Kind Regards, John
Sorry copied and pasted from your post. I assumed it must have been in amendment 1 which I never bought.

I also had problems with underfloor heating fitted by a builder where he had caught the cable and repaired with insulation tape. I had to rip up all tiles and replace the whole lot. It took phone calls also to find out if suitable for under a wet room and after all that useless anyway.
 
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Common sense ( my version ) and some experience would suggest that in the absence of any grounded mesh above the heating system any penetration of moisture that reaches the live element would not trip any safety device until the moisture on the surface has an electrical path to ground. That path could be via a person's foot, leg, heart, arm hand, water tap.
I doubt that anyone would argue with that. It is, however, worth noting that the instructions do say:
ECOFILMSET must only be installed in dry locations.
That means that for the hazard you describe to arise would require a fault in the primary insulation AND appreciably wetness of the the overlying flooring (despite being in a 'dry location) AND someone with bare feet (not in a bathroom etc.) AND for them to touch something earthed to all occur simultaneously.

However, this is probably really all pretty irrelevant in terms of this discussion about the regs, since I personally see no way of interpreting the regs as written other than indicating that one must install an earthed grid over the product.

Kind Regards, John
 
Sorry copied and pasted from your post. I assumed it must have been in amendment 1 which I never bought.
Yes, you're right - it was a typo of mine that confused you. My apologies - I'll give my typing fingers a reprimand :)
I also had problems with underfloor heating fitted by a builder where he had caught the cable and repaired with insulation tape. I had to rip up all tiles ...
Several people (but not RF, the OP) have talked about tiles, but the manufacturer's instructions for RF's ufh say:
ECOFILMSET underfloor heating systems are designed to be used under suitable laminate, engineered board and solid wood flooring with a maximum thickness of 15mm ...
.. no mention of tiles ... and, as I've just written in another post, the instructions also say that it must only be installed in 'dry locations'.

Kind Regards, John
 
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Several people (but not RF, the OP) have talked about tiles,
I was presented with an underfloor heating system which was installed by the tiler.
An understandable assumption even if not correct.
Indeed, and I now see that I didn't make the point which was in my mind very clearly! I was wondering whether, in addition to the earthing issues, the installation was perhaps non-compliant because it had been installed under tiles, seemingly in contravention of the MIs. Indeed, if tiles/tilers indicate that it was not a 'dry location', then the installation is probably at least doubly (probably trebly!) non-compliant!

A bit more clarification from RF would probably help.

Kind Regards, John
 
Sorry, been busy at work!

Some interesting discussions here, which kind of re-enforce what I was thinking.

The floor covering was actually a wooden floor, not tiles as I inferred earlier.

The floor is in a kitchen, so while not really a wet area, but a leak from the sink / washer etc, a spillage or even mopping up could cause the floor to become wet.
 
Sorry, been busy at work! Some interesting discussions here, which kind of re-enforce what I was thinking. The floor covering was actually a wooden floor, not tiles as I inferred earlier.
OK - so that's one non-compliance (with the MIs) you don't have.
The floor is in a kitchen, so while not really a wet area, but a leak from the sink / washer etc, a spillage or even mopping up could cause the floor to become wet.
That's an interesting one! - is a kitchen a 'dry location' (per MIs) or not? I would personally be inclined to say 'no', for the reason you give. However, if you were to think the same, you would never be able to 'certify' that product on a kitchen floor (regardless of the earthing issues etc.) - so you might no want to go down that road!

Kind Regards, John
 
From 700 - General

The particular requirements for each section (special installation or location) in Part 7 supplement or modify the
general requirements contained in other parts of the Regulations.
The absence of reference to the exclusion of a part, a chapter, a section or a regulation means that the corresponding
general regulations are applicable.
My view from reading that is as follows. Therefore the rest of the section 400 still applies - i.e. you can use any suitable protective measure including either automatic disconnection of supply, or double or re-inforced insulation, and apply the suitable supplementary regulations depending on that protective measure, i.e. either the supplementary 753.411... regulations or the supplementary 753.412... regulations (although you can, of course, apply 2+ protective measures if required/desired). They're only in their own chapter in Part 7 to make them easily accessible and convenient for both persons working in special locations, and those who aren't.

It also means that 412.1.3 applies, which is of some contention, but I think in this case there's no real risk of user modification:

Where this protective measure is to be used as the sole protective measure (i.e. where a whole
installation or circuit is intended to consist entirely of equipment with double insulation or reinforced insulation), it
shall be verified that the installation or circuit concerned will be under effective supervision in normal use so that no
change is made that would impair the effectiveness of the protective measure...
 
My view from reading that is as follows. Therefore the rest of the section 400 still applies - i.e. you can use any suitable protective measure including either automatic disconnection of supply, or double or re-inforced insulation, and apply the suitable supplementary regulations depending on if you are reading the supplementary 753.411... regulations or the supplementary 753.412... regulations. They're only in their own chapter in Part 7 to make them easily accessible and convenient for both persons working in special locations, and those who aren't.
I'm not sure that I fully understand what you're suggesting. In particular, when do you think that 753.411.3.2 would apply? It appears to be giving very specific instructions about what has to be done if the product is supplied 'without exposed-conductive-parts', one might think 'regardless of everythong else'.

Kind Regards, John
 
I was presented with an underfloor heating system which was installed by the tiler.

This installation can't be certified by tiler.

Then the tiler shouldn't have been installing it, and if the tiler installed it you can't certify it.

If you do certify it, and it kills someone, will your insurance cover you?
 
I'm not sure that I fully understand what you're suggesting. In particular, when do you think that 753.411.3.2 would apply? It appears to be giving very specific instructions about what has to be done
My post was not quite clear. As I read it, that regulation is supplementary to chapter 411, for Automatic Disconnection of Supply. So I would only read it if I am applying that protective measure.

If I am applying 412 Double or Reinforced Insulation, then I look at regulations under 753.412 to supplement what I read in 412. Etc for other protective measures.

If the IET wished any of the chapter's regulations to be regarded as a general rule, it would surely be supplementary to another, more general chapter.
 
My post was not quite clear. As I read it, that regulation is supplementary to chapter 411, for Automatic Disconnection of Supply. So I would only read it if I am applying that protective measure. ... If I am applying 412 Double or Reinforced Insulation, then I look at regulations under 753.412 to supplement what I read in 412. Etc for other protective measures.
Right, I now understand what you're saying and, on consideration, think that you are probably right. I must confess that I don't recall ever having read that bit at the start of Section 700 in the past.

If this interpretation is correct then, if RF's installation is relying on 'double insulation', and if he can somehow (could be difficult!) satisfy himself that the product had been installed with a polyester/polythene film as specified in the manufacturer's letter, then he may agree with the manufacturer's view that this amounts to the "Class II construction or equivalent insulation" as required by 753.415.1.

If, as well as that, RF also feels that he can regard the kitchen as a 'dry location', then it could be that the installation is actually compliant.

I have to say that this strikes me as unsatisfactory, as far as the writing/presentation of the regs are concerned. At first sight, as most/all of us previously assumed, 753.411.3.2 appears to simply be 'a regulation' which, in itself, has to be complied with - and nothing in Section 753 suggests otherwise. Only if one looks 76 pages earlier in the regs does one find the comments in Section 700 which indicate the (probably correct) interpretation which you have now suggested. IMO, that's not ideal - at the very least one might expect a 'warning' at the start of each 7xx Section.

Kind Regards, John
 
I think if every section of the regulations repeated the 'general' for that part then it would be a very hefty book indeed! The problem I feel is that to most people 7xx are seen as a blanket set of notes, to all be applied at those relevant special installations/locations. What's needed is an understanding that not only are different regulations outside of Part 7 not applicable to every instance, as is usually indicated by chapter headers and preceding regulations, but that this applicability also goes for the Part 7 chapters.

The only way to avoid widespread confusion on this matter is to properly teach the regs. That should be what 2382, 2391 etc are for. However, all they seem to do is teach you to do exactly what Part 7 *isn't* about, i.e. to go to the right chapter but then follow exactly what it says in your answer without thinking about or reading the non-Part 7 chapter it's supplementing.
 
I think if every section of the regulations repeated the 'general' for that part then it would be a very hefty book indeed!
It would, indeed, but I can't think of any other section where this would be as crucial as with Section 700. In any event, one would not have to repeat all of the 'general' section - I don't think it would need more than one little paragraph at the start of each 7xx section to underline the fact that what it contains are 'supplementary' to other sections, hence avoiding the misinterpretation - and that would have minimal impact on the heftiness of the book.
The problem I feel is that to most people 7xx are seen as a blanket set of notes, to all be applied at those relevant special installations/locations.
Indeed, but can you really blame people? Are there any other sections of BS7671 in which the regulations don't 'mean what they say', when taken in isolation?
The only way to avoid widespread confusion on this matter is to properly teach the regs.
As I've suggested, it's not the only way to avoid widespread confusion. I dare say I'll get flak for saying this, but IMO if a set of written regulations are such that one has to be 'trained' in order to avoid widespread misunderstanding/misinterpretation, then there's probably something non-ideal about those written regulations.

Kind Regards, John
 
IMO if a set of written regulations are such that one has to be 'trained' in order to avoid widespread misunderstanding/misinterpretation, then there's probably something non-ideal about those written regulations.
You won't get flak from me Just the opposite, I agree with you.
 

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