Query regarding Amendment 3, 2015 to the Wiring Regulations (England)

[stillp]

Your box full of raspberry pies, arduinos, etc is not within the scope of the standard for switchgear and controlgear assemblies.

So what does "and similar switchgear assemblies" in 421.1.201 mean?

If the scope of BS EN 61439-3 is relevant to 421.1.201 does that mean:

a) We can use BS EN 61439-3 as a guide to what "non-combustible" means?

b) I could indeed assemble my enclosure, MCBs, RCBOs, RCDs, switches, E & N distribution blocks etc and use it in place of a CU and not have to worry about 421.1.201 because that distribution board is not similar to a CU?

It means switchgear assemblies that are similar to a CU.

a) You can. Whether that is sufficient or not, I don't know. I thought I did, but...

b) If you assembled an enclosure with components that are switchgear, and are typically used as components of a CU, then you've built something that is similar to a CU, or perhaps is a CU.

 

[ban-all-sheds]

So how similar does it have to be to be similar in the context of 421.1.201?

 

[PBC_1966]

You might have noticed that I was talking about manufacturers.

Fair enough - I thought the general topic was somebody making up a box for use in his own home, such as I might do.

The requirement to demonstrate conformity only applies if the equipment is used "in connection with a business", so if you make something for your own use, in your own home, you only need to make sure it is safe. However, if you intended to use it to demonstrate your ability to make such a 'thing', in the hope of selling more of them, then I suppose it would fall under the Regulations.

Although if you made up a trial version for your own home just to try it and decide whether you might turn it into something marketable, nobody can second-guess your intent anyway, so it would be rather academic.

 

[stillp]

So how similar does it have to be to be similar in the context of 421.1.201?

Sufficiently similar that the designer of the installation decides it comes under 421.1.201.

 

[ban-all-sheds]

You might have noticed that I was talking about manufacturers.

Fair enough - I thought the general topic was somebody making up a box for use in his own home, such as I might do.

Or somebody else's home, but not in a way which any normal person would regard as "manufacturing".

The requirement to demonstrate conformity only applies if the equipment is used "in connection with a business"

Is there any threshold of volumes made?

What if you run a business where you provide, possibly inter alia, home automation consultancy and the construction of bespoke, every-one-is-different control systems?

 

[stillp]

Is there any threshold of volumes made?

What if you run a business where you provide, possibly inter alia, home automation consultancy and the construction of bespoke, every-one-is-different control systems?

No, there is no threshold. Do you think that if someone only rewires one house, they can ignore the wiring regs and Part P?

If you run a business, then you have to comply with the laws relating to that business.

 

[ban-all-sheds]

No, there is no threshold. Do you think that if someone only rewires one house, they can ignore the wiring regs and Part P?

No.

If you run a business, then you have to comply with the laws relating to that business.

Indeed.

On a more serious note, I wonder if they've thought of the implications for the more custom end of the home automation spectrum?

 

[stillp]

On a more serious note, I wonder if they've thought of the implications for the more custom end of the home automation spectrum?

Which "they" are you talking about?
But anyway, if someone was to offer for sale a one-off home automation controller, wouldn't you want them to be required to prove it was safe?

 

[ban-all-sheds]

Which "they" are you talking about?

The ones decreeing that similar switchgear has to comply with BS EN 61439-3.

But anyway, if someone was to offer for sale a one-off home automation controller, wouldn't you want them to be required to prove it was safe?

I would want them to use components known and appropriately certified to be safe. I would want them to have the appropriate skills to design it. I would want them to use good workmanship in constructing it.

Although I don't know the details of them, I doubt that the processes needed for them to prove that it complies with BS EN 61439-3 would be realistic.

 

[PBC_1966]

Although I don't know the details of them, I doubt that the processes needed for them to prove that it complies with BS EN 61439-3 would be realistic.

Maybe I've lost track of it in the dozen or so pages of debate, but is there anything in law which says that it must comply or that you must somehow prove that it complies anyway? If so, where?

 

[ban-all-sheds]

What has "in law" got to do with it?

 

[PBC_1966]

What has "in law" got to do with it?

I thought that was the whole issue? If there's no legal requirement (except for it to be reasonably safe), then what does it matter whether or not a custom one-off device complies with BS EN-whatever? (Or if it does anyway, whether or not one can somehow prove such compliance.)

 

[ban-all-sheds]

It matters a great deal to someone who wants, or needs (e.g. for contractual reasons) to comply with BS 7671.

 

[PBC_1966]

It matters a great deal to someone who wants, or needs (e.g. for contractual reasons) to comply with BS 7671.

Fair enough. I was being led by earlier comments, e.g.:

If you run a business, then you have to comply with the laws relating to that business.

If there is no law which says that the one-off custom device you're selling must comply with BS EN-whatever then there's nothing to stop you selling it. If the person thinking about buying your services in designing and making such a device has some desire to follow BS7671 and referenced standards, that's another matter.

I think it's clear that when it comes to certain one-off devices such as we're discussing, there's simply no reasonable way to comply with all the standards compliance and testing, and anyone going down such a path needs to accept that. As you said, the "official" route of demonstrating compliance for any one-off device is simply far too bureaucratic, time consuming, and expensive to make it viable.

 

[ban-all-sheds]

But then with the best will in the world you may be unable to comply with BS 7671.