Is this legal to install in the UK?

[Ric2013]

Hi, plumber here so please be gentle (or take the p-ss ),

I am supposed to be installing a UV water steriliser for a customer. I have some concerns about the suitability of the product that the filter company (a UK manufacturer) has supplied me with.

Essentially it's a UV tube inside a quartz sleeve that zaps the water as it goes through a stainless tube mounted to the wall with a separate transformer unit. There is an earth connection that earths the metal cases together (not connected in my photos, but you get the idea).

The installation instructions recommend an FCU or plug connection (but it isn't fitted with a plug: naughty naughty but let's let that one slide).

I don't have concerns regarding the primary side of the switch-start fluorescent ballast, as that is a sheathed flexible cable to an earthed metal enclosure, but the secondaries (230VAC IIUC) seem to be single-insulated to the lamp connectors. There is some heat-shrink over the single-insulated wires but this is unshrunk and does not 100% cover the insulated conductors. Finally, the lamp connectors simply push on to the lamp and, once fitted, are not inside any kind of enclosure.

My concern is that, while the stainless steel water tube is earthed, someone could get a shock off the secondaries quite easily as the single-insulated wires are vulnerable, and quite likely earth themselves too, so the shock could pass right across the chest. And that, since the shock would be from the secondaries of the lamp transformer, this would mean the RCD protection on the circuit would be negated.

Am I being finickky, or does the whole thing need to go inside an electrical enclosure to be safely and legally fitted in the UK, which isn't exactly practical in a domestic environment?

Many thanks for any help you may be able to give me.

 

[pc1966]

Do you have any manufacturer's information about this?

It should go inside some sort of an enclosure as the cables to the tube have the primary insulation exposed (i.e. the part covering each core) so that should not be accessible without the use of a tool. A wooden box with screwed on lid would suffice, so long as a finger or similar can't get in any holes.

It is not clear, but I suspect the stud/nut at the end might be intended to have an earth wire attached as well, unless the other side has some extra cable from the white box to the metal tube assembly.

If the tube is earthed via the supply then you could just put a 13A plug on it and connect to any suitable socket. As you say this should be RCD protected, and most houses now are (if rewired in last decade or two) but worth checking first.

 

[davesparks]

That does not appear to comply with current product standards, is it UKCA marked (post-brexit replacement for the CE mark)?

 

[Ric2013]

Do you have any manufacturer's information about this?

https://silverlineuk.co.uk/wp-content/uploads/2020/02/NEW-UV-DS-Instructions-for-fitting-unit-Website.pdf

https://silverlineuk.co.uk/wp-content/uploads/2020/02/UV-DS30_WRAS.pdf

It should go inside some sort of an enclosure as the cables to the tube have the primary insulation exposed (i.e. the part covering each core) so that should not be accessible without the use of a tool. A wooden box with screwed on lid would suffice, so long as a finger or similar can't get in any holes.

It is not clear, but I suspect the stud/nut at the end might be intended to have an earth wire attached as well, unless the other side has some extra cable from the white box to the metal tube assembly.

Putting an enclosure in isn't something I'd quoted for to be honest and I'm not really sure it would fit in the customer's property (supply from well pump comes in to the kitchen near the sink). The fact that it said it could be fitted with a plug made me think it would be a reasonable assumption that it would meet UK requirements as anything that can be plugged in would normally just be plugged in by the householder. EDIT - bear in mind tube replacement means withdrawing a 30W tube lengthways, so probably not really designed for anything but a large enclosure.

And you are correct that the stud would connect the (earthed) casing of the white box to the metal tube. I just hadn't done it for the photo.

 

[Ric2013]

That does not appear to comply with current product standards, is it UKCA marked (post-brexit replacement for the CE mark)?

No, it isn't. Do we use the UKCA mark for electrical appliances? Is that what I should expect to see? I thought British electrics never had meant harmonised standards purely for electrical safety, but perhaps that is just for plugs and sockets. I get lost by what standards actually mean what, and having BSI behind a paywall doesn't help.

 

[pc1966]

Normally goods would have either the European CE mark, or post-Brexit the UKCA mark. But now politics have seen sense and have accepted continuation of CE indefinitely.

I found a web site for them and they claim WRAS certification (UK water standard) but say nothing about electrics. Might be worth an email to ask?

 

[Ric2013]

Normally goods would have either the European CE mark, or post-Brexit the UKCA mark. But now politics have seen sense and have accepted continuation of CE indefinitely.

I found a web site for them and they claim WRAS certification (UK water standard) but say nothing about electrics. Might be worth an email to ask?

'Death sticks' have the CE mark. Apparently they can because they meet the standard for a screwdriver...

I can certainly enquire about CE or UKCA approval, but if it proves as irrelevant as the WRAS approval (compliance with the so-called Water Regulation is not mandatory on a private supply, and WRAS approval is not mandatory anywhere, but it is one way of showing that a product is suited for use with drinking-water), then it isn't a reason for rejecting the filter. I can't say 'I cannot fit this' if it isn't a legal requirement. Also, if it isn't safe, then I still don't want to install it whatever certification it may have. But the question is, is it a legal requirement?

What I have asked the manufacturer so far is about the single insulation and the need for an enclosure. To be honest, my feeling is that anything that can be fitted with a plug can just be plug and play (following manufacturer's installation instructions) and I wasn't banking on this job requiring electrical installation work. After all, I can buy an IP64 electrical site light and plug it in and use it externally without any special qualification and this filter isn't even designed to be used externally, so it should be far lower risk (in theory, but not if it's essentially unsafe outside an enclosure).

Not that I'm against calling out a spark, but I find they [the bad ones] either just throw anything in so long as you pay them (and all you're paying for then is the signature and what good is covering your backside when you have a dead customer on your conscience?) or they [the good ones] aren't available when you need them, because tradesmen can be busy people. I need to know it's safe to wire before I plumb it in regardless of who actually wires it.

 

[Avo Mk8]

Interesting question about one's responsibility here!

As has been said, the steriliser doesn't meet accepted standards for electrical safety. I believe the product would come under BS EN 60335-1 "Household and similar Electrical Appliances - Part 1 Safety - General Requirements" and there is a specific part for this sort of device "IEC 60335-2-109:2016 Household and similar electrical appliances – Particular requirements for UV radiation water treatment appliances". (BS/EN and IEC standards generally equivalent/interchangeable)
If Silverline had submitted a sample of their product to a test house to get evidence of compliance for CE marking, I don't think they would have got it with the single insulated wiring and exposed end caps they are using now. (I suppose it's possible originally it was assembled differently, and they've changed the end-caps/wiring).
By accident I came across the test report template for this type of product IECEE TRF 60335-2-109D:2019. Yours for £1k!

So what to do?

If the customer had bought the device, and asked you to fit it, you might feel you should explain to the customer you believe it's not very safe. But then if the customer still wanted it fitted, you might rest fairly easy knowing that liability for the product's safety primarily lies with Silverline. I see there are instructions and Video's on Silverline's website, showing customers how to safely change the tube etc (ie turning the power off before removing the end caps etc.)

But it sounds as if you bought the product, and now are rightly concerned about fitting it.
The potential hazards could be alleviated by replacing the tube end-caps with, for example, waterproof versions that properly insulate the assembly with the flex properly terminated. But while possibly making it 'safer', you would be modifying the product and so would assume some liability for the products safety. That is perhaps an unreasonable risk.

Basically I think you have bought a product that ought to have a CE mark (and have a UK plug on it when supplied), but it doesn't. It's definitely worth talking to Silverline. They may be naive, or may have an explanation (if so I'd like to hear it!).

 

[HappyHippyDad]

Hi @Ric2013 ,

The best advice I can give is fully explained in the following link. It should help quite a lot.
www.youtube.com/watch?v=mViO9mnCTBo

 

[Ric2013]

Interesting question about one's responsibility here!

As has been said, the steriliser doesn't meet accepted standards for electrical safety. I believe the product would come under BS EN 60335-1 "Household and similar Electrical Appliances - Part 1 Safety - General Requirements" and there is a specific part for this sort of device "IEC 60335-2-109:2016 Household and similar electrical appliances – Particular requirements for UV radiation water treatment appliances". (BS/EN and IEC standards generally equivalent/interchangeable)
If Silverline had submitted a sample of their product to a test house to get evidence of compliance for CE marking, I don't think they would have got it with the single insulated wiring and exposed end caps they are using now. (I suppose it's possible originally it was assembled differently, and they've changed the end-caps/wiring).
By accident I came across the test report template for this type of product IECEE TRF 60335-2-109D:2019. Yours for £1k!

So what to do?

If the customer had bought the device, and asked you to fit it, you might feel you should explain to the customer you believe it's not very safe. But then if the customer still wanted it fitted, you might rest fairly easy knowing that liability for the product's safety primarily lies with Silverline. I see there are instructions and Video's on Silverline's website, showing customers how to safely change the tube etc (ie turning the power off before removing the end caps etc.)

But it sounds as if you bought the product, and now are rightly concerned about fitting it.
The potential hazards could be alleviated by replacing the tube end-caps with, for example, waterproof versions that properly insulate the assembly with the flex properly terminated. But while possibly making it 'safer', you would be modifying the product and so would assume some liability for the products safety. That is perhaps an unreasonable risk.

Basically I think you have bought a product that ought to have a CE mark (and have a UK plug on it when supplied), but it doesn't. It's definitely worth talking to Silverline. They may be naive, or may have an explanation (if so I'd like to hear it!).

Given that my 1963 Avo 8 is still within around 1% of the theoretical readings I would have expected from 1% resistors on the resistance ranges, I must say I was looking forward to a helpful reply and you have not disappointed.

As you say, I'm supplying the product and it seems pretty poor from an electrical safety point of view (hadn't seen the videos, and wish I had). I don't have an electrical background (although I did pass my intermediate Radio Society of GB exam which has a fair bit of electronics in it) and the 'mature' electrician running the course was quite happy with my mains plug wiring, but that's as far as I'd want to go in someone else's house. Internal to the enclosure, the ballast is switch-start which seems a waste of energy when a HF ballast would save quite a bit when you consider 24h operation, possibly at the expense of reliability, but that's not the issue here.

I suppose the exposed end caps are not the main problem, given that they are extensively used in other luminaires, but the lack of a proper flex is, and, had I seen something like a 2-core cable terminated inside some kind of plastic end cap to cover where it goes into the lamp-holders, I would not have questioned the rest. What also worries me is that if you mount the tube vertically, the tube effectively hangs from the push-on cap and, in a vertical installation, the weight of the lamp is in line with the pins. Silverline UK says this is not a problem and that no further support (wooden or plastic bracket under the lower lamp-holder) is needed.

But thank you for the BS numbers. That is what I needed to start the discussion. I don't mind wiring a plug or even fitting an FCU for a customer if the circuit seems to be in order, but not if what I am wiring in fails to meet the required standards, and there is no point my calling out an electrician and putting him in the same quandary I am in. Will let you know how this one pans out.

 

[Ric2013]

Hi @Ric2013 ,

The best advice I can give is fully explained in the following link. It should help quite a lot.
www.youtube.com/watch?v=mViO9mnCTBo

Ah... I wish I could get work mending toilets and dealing with leaky taps. You know, those tasks that are essential for a healthy civilisation, but I currently don't have time to advertise (or take on very much work because I seem to spend a third of my time abroad and not out of choice) and so the weird stuff comes my way. I was quite happy to get a UV filter installation job, I just wasn't banking on the filter being not to the required standards for the UK!

 

[Avo Mk8]

Hi Ric2013
Having looked at the UK plugs and sockets regulations:
(The Plugs and Sockets etc. (Safety) Regulations 1994 - https://www.legislation.gov.uk/uksi/1994/1768/contents/made)
I see that this water sterilizer is exempt from the regulation that requires fitting of a 13A plug for all products (to paraphrase - under 2kW ish) for sale in the UK. So forget that bit. No breaking the rules there!
But how they get away without a CE mark and a CE Declaration of Conformity I don't know.

Plenty of Avo's here, from 'DC only' ones onwards!

 

[freddo]

I suppose the exposed end caps are not the main problem, given that they are extensively used in other luminaires

They are used extensively inside other luminaires. All the UVC 'filters' I've ever worked on / installed have all had moulded connectors, most have some sort of splash proof rating. All the recent ones have been single connector using the lamps with all 4 pins at one end.

 

[Ric2013]

They are used extensively inside other luminaires. All the UVC 'filters' I've ever worked on / installed have all had mounded connectors, most have some sort of splash proof rating. All the recent ones have been single connector using the lamps with all 4 pins at one end.

Ah. Now that is helpful to know that other UV filters are usually sealed. Any idea what brand they were, in case I need to find an alternative supplier?

To clarify, I meant that unsealed bulbholders are used for (e.g. kitchen) lighting which may have a bulb cover, but doesn't always, so the non-cable side is often exposed. Obviously I don't know if that is modern standards (and cannot check a catalogue to compare now fluorescents are essentially banned), but had I only seen that, alarm bells wouldn't be ringing in my head.

But while the terminals on a standard fluorescent lampholder might be quite close to a passing finger, they aren't that close (same as series Christmas fairy lights), you can't pull them off as the lamps usually twist off (except older fittings) so you don't have the equivalent of the unsheathed BS1363 socket pins, and they aren't anywhere near an item carrying cold water and thus prone to condensation. In fact, they are usually on a ceiling or wall (or tree).

 

[AJB Temple]

This may help a bit. Practically all Koi (ornamental fish) ponds have UV steriliser devices fitted. The tube fittings and end caps etc are always enclosed in a plastic or alloy tubular container with rubber O rings. 13A moulded plugs fitted generally. Evolution Aqua is a reputable brand, though plenty of choice. Linky: Pond UV Clarifiers - Pond Electrical - Absolute Koi - https://www.absolute-koi.com/pond-electrical/pond-uv-clarifiers/

These are generally installed for continuous use on the return segment of water flow after a pumped or gravity filter (with return pump) has taken water from the pond. Just plugged into RCD protected socket nearby as a rule. Lamps only last about a year so user serviceability is essential. Note that UV light from the bulbs must not be viewed with the naked eye - dangerous to eyesight.