Again, as I and Ragner have been trying to explain, modern editions of BS7671 are not written from scratch for the UK. they are based on an IEC standard modified to reflect UK practices and thinking. Even in the UK, lighting circuits with no CPCs are not unheard of, and I'm pretty sure there are places in the world where you will find power circuits with no CPCs.
Yes, I understand all that. However, when it came to creating UK regulations, I don't think the fact that they were 'based on an IEC standard' really excuses:
1... Having two regs which are literally contradictory - one saying that an RCD is an acceptable device for providing fault protection in a TN installation, and the other saying that an RCD alone is not acceptable
OR
2... Writing UK regulations which, at least in my opinion, defy electrical common sense. Yes, RCDs can do other things as well, but in terms of 'fault protection' in the normal sense (i.e. as provided by an OPD), and RCD cannot only do the same as an OPD but can, in some senses, do it better - AND can be regularly/routinely tested to confirm that satisfactory protection persist - which is not the case with an OPD.
Use of earth fault protection as a mitigation for missing CPCs is certainly something that is done in some countries.
I do somewhat struggle to understand the common sense of that. In the absence of CPCs, exposed-c-ps of equipment can become live due to a fault and, if not 'earthed' via a CPC will remain live 'for ever', hence presenting 'for ever' the risk of electric shock if they touch it and simultaneously manage to touch something which
is earthed. An RCD cannot clear such a fault any more than can an OPD, so the only sense in which it 'mitigates' the absence of CPCs is that, the absent CPCs having increased the risk of someone receiving a shock, it offers the possibility that the RCD may prevent the shock being fatal.
I think I would prefer the ''protection' to have made it much less likely that I would get a shock, rather than decreasing the risk of dying if I did
Somewhat agreed, but the question is how likely is a fault that is both
* High enough impedance not to rapidly trip a OCPD.
* low enough impedance to result in a dangerous "touch voltage" on a TN supply.
One can obviously argue about actual probabilities, but I would say 'fairly likely'.
The problem arises with fault impedances which are 'very low', but not quite low enough to achieve magnetic tripping of an RCD (quite likely given that some circuits often have Zs which is only just low enough for magnetic tripping the e face of a zero-impedance fault). In that situation, the 'very low' (but not quite low enough for the OPD) fault impedance could mean that (depending on relative CSAs of L conductor and CPC) not a lot less than half the supply voltage.
OTOH on TT supplies it seems the risk of a fault that was low enough to create dangerous touch voltages, but high enough not to cause a trip was a risk they decided needed to be addressed, resulting in the requirement that the impedance to earth multipled by the RCD trip current must be less than 50V.
Yes, but that merely requires that (for a 30mA RCD) the TT earth have an impedance less than 1667Ω, which is always going to be the case if it's compliant. In this case, it doesn't really matter what the fault impedance is, since, whilst just 'a fraction of an Ohm' can be enough to prevent magnetic tripping of an MCB, it would require 'a good few Ohms' to make any noticeable difference in a TT installation !