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

[ban-all-sheds]

"You seem to have changed your opinion. I thought it was your view that we should completely ignore 421.1.201, since it was requiring something that was a physical impossibility (a "non combustible" material), and therefore was 'invalid'. You now seem to be saying that if some other Standard contains a definition of that "physically impossible" concept, it is acceptable to apply that to BS7671. Is that a correct statement of your new position?"

421.1.201 is impossible to comply with as written.

IMO ignoring it entirely is valid, but I accept that many people would have a problem doing so. The requirement is for a "non-combustible" enclosure. If it is made of a material which a standard defines as significantly non-flammable or self-extinguishing etc, and that standard is relevant because it applies to materials used in buildings, then I see no problem with someone who installs one saying that it complies. The impossibility of complying strictly with 421.1.201 as it is written guarantees that there is no method which someone else could point to and say "you should have done that".

I repeat my challenge - please put forward a convincing explanation of why someone who did what I said could be shown to have not exercised reasonable skill and care and to not be justified in believing to the best of his knowledge that he had complied with 421.1.201?

 

[ban-all-sheds]

I don't agree. It would not be permissible to connect into a combustible domestic DB from next year.

Why not?

Because such work carried out after 1/1/16 would not comply with BS 7671.

FGS.

 

[ban-all-sheds]

As has been said, if your interpretation correctly reflected the intent of Amd3, the consequences would be horrendous.

John - please remember that you are dealing here with someone so hard of thinking that he cannot tell the difference between one country and another, and does not even know which one he lives in.

 

[Lectrician]

I thought somewhere, perhaps an artical, non combustible was dictated by the 900deg glow wire test, and the AMD3 was to exceed this?

As ever, the reg is poorly worded with no backup or examples. It's a good job they don't write contracts.

As for the OP, I recently did a new kitchen extension which required 4 new circuits, meaning the existing CU was too small. I could of added a second CU, but opted to quote for a new 15 way AMD3 one. Shoot me.

Regarding cables 50mm deep. This is not the norm at all. I suspect with your alterations, there are cables which are going to end up out of zones, and the requirement for something like steel conduit would then be required, or burying deeper than 50mm (which on a block wall is foolish).

 

[JohnW2]

I repeat my challenge - please put forward a convincing explanation of why someone who did what I said could be shown to have not exercised reasonable skill and care and to not be justified in believing to the best of his knowledge that he had complied with 421.1.201?

I'm not sure why you are repeating your challenge but, since you are, I can but repeat the answer I gave the first time you issued it ....

As I said, I do not doubt that anyone who did what you have said would have 'done their best to comply' - but, as above, that is different from the question of what they are actually meant to be complying with.

That seems clear enough to me but, if it helps you to understand .... yes, I agree that someone who did what you said would have "exercised reasonable skill and care" and would be justified in believing "to the best of his/her knowledge" that (s)he had complied with 421.1.201 - BUT that does not really help us to understand what 421.1.201 is attempting to require.

Kind Regards, John

 

[ban-all-sheds]

I believe the latter is irrelevant. Unless you can find a way to show that the person had not exercised reasonable skill and care, and was mistaken in their belief, because of what the regulations say, then their EIC would be valid. Nobody could challenge it, and nobody could have a legal basis on which to deny its validity.

And that would be it, until such time as 421.1.201 was changed to specify something which people could actually do, and everybody could get on with their lives, fitting either metal CUs or reputable plastic ones which comply with a relevant standard which defines a material as being considered non-combustible for the purposes of whatever if it passes a whatever test.

421.1.201 is not just problematic wrt "non-combustible", but also with the term "and similar switchgear assemblies". Do we have to use metal FCUs now?

 

[JohnW2]

I thought somewhere, perhaps an artical, non combustible was dictated by the 900deg glow wire test, and the AMD3 was to exceed this?

I'm currently struggling to find the article but, IIRC, it was someone related to the London Fire Brigade (who seemingly were the source of pressure which resulted in the Amd3 change) who expressed the opinion that existing Standards for 'combustibility resistance' were inadequate. If JPEL/64 had wanted to buy into that idea, they obviously should have spelled out what they actually did require. As you go on to say...

As ever, the reg is poorly worded with no backup or examples. It's a good job they don't write contracts.

Quite so.

In passing, what appears to have excited the LFB are these figures which they quote, relating to the numbers of fires in the LFB area which allegedly originated in CUs:

If one assumes (and it's a very big assumption) that these figures do accurately reflect the number of fires that originated in CUs, then common sense would suggest that the recent considerable increase was due to something other than the fact that the CUs were plastic. Plastic CUs have been very widely used for very many years and, to the best of my knowledge, nothing about them suddenly changed in ~2011 (and, even if it did, one imagines that most of the 'CU fires' during 2011-2014 probably related to CUs which were installed long before 2011).

What, if anything, resulted in this apparent increase from 2011 is anyone's guess. I must say that my suspicion would be that it might have been an increase in the number of fires ascribed to CU origination, rather than an increase in those which actually did originate in CUs - but who knows?!

Kind Regards, John

 

[JohnW2]

I believe the latter is irrelevant. Unless you can find a way to show that the person had not exercised reasonable skill and care, and was mistaken in their belief, because of what the regulations say, then their EIC would be valid.

As I've been saying/implying, I don't disagree with any of that.

Nobody could challenge it, and nobody could have a legal basis on which to deny its validity.

Maybe no-one should challenge it, but I'm quite sure that many implicitly will. Given what BS7671 does (and does not) say, I would imagine that a high proportion of EICRs undertaken after 1.1.16 will 'code' any plastic CUs - and if they were installed after 1.1.16, that is likely to aggrieve many householders.

I think you are missing the most important practical (rather than academic/legal) point. Electricians want a quiet and simple life, and don't want the hassle of having to justify what they have done (particularly if it is at variance with what most others are doing, and believe they should be doing). Amidst all the multiple inadequacies of 422.1.201 as written, the only thing which is effectively certain is that no-one who installs a ferrous metal CU will be accused of not having complied with 422.1.201. Hence, stupid though it may be, that is surely what is going to happen - unless/until BS761 is considerably clarified, to all intents and purposes only ferrous metal CUs will be installed.

The members of JPEL/64 cannot be unaware of all the confusion and debate which has resulted from their wording of this new reg. Although one gets the impression that they are still under considerable pressures from LFB, one would hope that they will have become aware of the need for clarification in the next Amendment/edition of BS7671. Much as I think it would be a pity, unnecessary and possibly the cause of an overall reduction in safety, even if they mandated that all new CUs had to be made of ferrous metal, at least we would 'know what we were doing'

Kind Regards, John

 

[ban-all-sheds]

If one assumes (and it's a very big assumption) that these figures do accurately reflect the number of fires that originated in CUs, then common sense would suggest that the recent considerable increase was due to something other than the fact that the CUs were plastic.

Not just common sense, but also science, engineering etc.

The case of a CU cannot possibly be the cause of a fire. Some may well burn too readily when ignited, but even the cheapest and nastiest do not self-combust. If those figures do accurately reflect the number of fires that originated in CUs then what we are seeing is a marked increase in fires which start either because of poor quality internals, or poor workmanship when installing, or a combination of the two.

Addressing that by requiring the boxes not to catch fire when there's a fire inside is a bit like trying to cure obesity by buying larger trousers.

 

[ban-all-sheds]

Maybe no-one should challenge it, but I'm quite sure that many implicitly will. Given what BS7671 does (and does not) say, I would imagine that a high proportion of EICRs undertaken after 1.1.16 will 'code' any plastic CUs - and if they were installed after 1.1.16, that is likely to aggrieve many householders.

That may be so, but of practical consequence?

I think you are missing the most important practical (rather than academic/legal) point. Electricians want a quiet and simple life, and don't want the hassle of having to justify what they have done (particularly if it is at variance with what most others are doing, and believe they should be doing).

And sadly many of their number have a marked disinclination to actually think.

Amidst all the multiple inadequacies of 422.1.201 as written, the only thing which is effectively certain is that no-one who installs a ferrous metal CU will be accused of not having complied with 422.1.201. Hence, stupid though it may be, that is surely what is going to happen - unless/until BS761 is considerably clarified, to all intents and purposes only ferrous metal CUs will be installed.

A position which I vehemently oppose. I firmly believe that if you act like a doormat people will trample on you. What's needed here, as in all walks of life it seems, (and increasingly so) a great deal more robustness. What's needed is for the electricians so accused to round on their accuser and demand that they either find a way to get their EIC formally ruled invalid or to f*** off.

The members of JPEL/64 cannot be unaware of all the confusion and debate which has resulted from their wording of this new reg. Although one gets the impression that they are still under considerable pressures from LFB,

What's needed here is a great deal more robustness on the part of JPEL/64. What is needed is for them to round on the LFB and demand that they prove their case. Demand that they show that the problem is occurring in other cities, as the same CUs are being installed there as in London. Demand that they show that the problem is occurring in other countries, as the same CUs are being installed all over Europe, Australia, New Zealand etc. Demand that they show that the problem is caused by the CUs being plastic, and not by the quality of the internals or of the workmanship. Or to f*** off.

 

[JohnW2]

If one assumes (and it's a very big assumption) that these figures do accurately reflect the number of fires that originated in CUs, then common sense would suggest that the recent considerable increase was due to something other than the fact that the CUs were plastic.

Not just common sense, but also science, engineering etc.

Indeed, but I would hope that all such disciplines maintain consistency with common sense.

The case of a CU cannot possibly be the cause of a fire. Some may well burn too readily when ignited, but even the cheapest and nastiest do not self-combust. If those figures do accurately reflect the number of fires that originated in CUs then what we are seeing is a marked increase in fires which start either because of poor quality internals, or poor workmanship when installing, or a combination of the two. Addressing that by requiring the boxes not to catch fire when there's a fire inside is a bit like trying to cure obesity by buying larger trousers.

Indeed - the primary efforts should obviously attempt to address to underlying causes of the fires, not to 'contain' them after they have been started by something else. Having said that, no such efforts would be totally successful, so it's common to have secondary requirements to limit the spread and/or consequences of fire after it has started (however started).

There is also the question of 'perspective'. Even if there are 250 or so fires per year originating in CUs, it's probably the case that few of these result in deaths or serious injuries - and, in the 'real world', one has to wonder how justifiable is a regulation which will come to affect every electrical installation in the country (at very considerable cost) if the number of deaths/injuries is (in relation to 'the big picture') extremely small.

Kind Regards, John

 

[ban-all-sheds]

Having said that, no such efforts would be totally successful

They seem to have been satisfactory up until about 5 years ago.

 

[JohnW2]

Maybe no-one should challenge it, but I'm quite sure that many implicitly will. Given what BS7671 does (and does not) say, I would imagine that a high proportion of EICRs undertaken after 1.1.16 will 'code' any plastic CUs - and if they were installed after 1.1.16, that is likely to aggrieve many householders.

That may be so, but of practical consequence?

As I went on to say, a major (and, IMO, unfortunate) consequence. Since electricians don't want hassle, virtually all of them will (in order to avoid such situations) inevitably install only ferrous metal CUs after 1.1.16

A position which I vehemently oppose. I firmly believe that if you act like a doormat people will trample on you. What's needed here, as in all walks of life it seems, (and increasingly so) a great deal more robustness. What's needed is for the electricians so accused to round on their accuser and demand that they either find a way to get their EIC formally ruled invalid or to f*** off.

As above. Electricians want a quite life, and virtually all of them will do the 'easy thing'. There is, in fact, very little incentive for them to do otherwise - if anyone is to create a fuss, it should probably be consumers and consumer groups.

What's needed here is a great deal more robustness on the part of JPEL/64. What is needed is for them to round on the LFB and demand that they prove their case. ....

I can't disagree, but we live in a complicated world. The LFB are very powerful, and (although I may be misinformed) the impression I get is that they bullied JPEL/64 into the change under threat of their seeking the introduction of specific legislation.

Kind Regards, John

 

[davelx]

421.1.201 is not just problematic wrt "non-combustible", but also with the term "and similar switchgear assemblies". Do we have to use metal FCUs now?

and, of course, no plastic plasterboard or surface mount patress boxes

 

[ban-all-sheds]

In my loft I have a small enclosure containing some DIN rail terminals, a fuseholder and a contactor. If I were installing it next year, would it have to be "non-combustible?

Ditto for Bernard's box of lighting relays.