Plastic consumer units and how to code them

[DPG]

So are we saying provided the plastic C/U satisfies certain criteria regarding thermal damage and location. And because it was designed pre AMD 3 of the 17th. The inspection Schedule section 4 ref 4.4 would not be applicable in this instance. ??
As an example !!
If you own a classic car, there is no legal obligation for it to be fitted with seat belts. And yet these days its considered a major safety requirement and more so, a legal requirement.
Not an exact comparison, but in principle !!

The problem with the car/seat belt analogy is that OEM seat belts aren't readily available for most classic or vintage cars, whereas replacement metal consumer units are.

 

[Soi disant]

Quoting Electrical Safety First

And we'll stop right there until we answer the question "What authority do they have to override the Wiring Regulations?"

 

[old man sparky]

The problem with the car/seat belt analogy is that OEM seat belts aren't readily available for most classic or vintage cars, whereas replacement metal consumer units are.

Ahhh !! But then the comparable analogy could be your replacing an old classic car, with a new car, because you cant get seatbelts for it. ??

 

[DPG]

Ahhh !! But then the comparable analogy could be your replacing an old classic car, with a new car, because you cant get seatbelts for it. ??

Haha, almost but not quite, yes!

 

[old man sparky]

And we'll stop right there until we answer the question "What authority do they have to override the Wiring Regulations?"

Not overriding more like which version is applicable, given the regs are not retrospective.

 

[Soi disant]

The only version which is applicable is only ever the one current at the time.

Installations are not judged wrt the edition in force when they were created.

 

[old man sparky]

The only version which is applicable is only ever the one current at the time.

Installations are not judged wrt the edition in force when they were created.

The point is you cant Judge all installations on the current version of the regs. Because an older installation wont necessarily comply with that version. So when assessing the topic subject, ie plastic consumer units. Its either non compliant with code 3 minimum. Or not applicable to a regulation that came into force after it had been installed to a version of the regs whereby it was fully compliant at that time. So we know a consumer unit designed before AMD3 wont comply with a regulation specifically for after AMD3 consumer units were introduced So we ask why would such a regulation even be applicable to those older consumer units.
Thats the question. What do you consider to be the correct response to 4.4 where plastic is in use.

 

[Soi disant]

The point is you cant Judge all installations on the current version of the regs.

You have to.

No other edition exists any more. All the previous ones are obsolete. They have been replaced. They have zero validity. They mean nothing. They are dead and buried.

Because an older installation wont necessarily comply with that version.

Indeed not.

So when assessing the topic subject, ie plastic consumer units. Its either non compliant with code 3 minimum. Or not applicable to a regulation that came into force after it had been installed to a version of the regs whereby it was fully compliant at that time.

It may have been compliant at the time.

It is no longer compliant. Its previous status is a matter of nostalgia only.

Inspections and codings etc can only ever be done to the edition in force at the time. Compliance with earlier editions is of zero value.

So we know a consumer unit designed before AMD3 wont comply with a regulation specifically for after AMD3 consumer units were introduced

Indeed not.

So we ask why would such a regulation even be applicable to those older consumer units.

It's the current regulation which applies to all consumer units. There are no other regulations to decide to use.

What do you consider to be the correct response to 4.4 where plastic is in use.

Ah - well now.

If you decide that you are going to use the model schedule of inspections on pp481-482 of the regs, then you simply cannot give it anything other than a C2 or a C3, as it simply does not comply. (Again, I'm ignoring the other options for the same reasons as before.)

So, may you decide not to use that schedule, and create your own which omits items which are troublesome/contentious?

the example schedule in appendix 6 is merely a generic example, many on-line tools differ quite significantly, they only have to be based on the example, not rigid to it.

This is noted in 651

You don't need to include things that don't comply with the latest regs, only those which don't comply, which may give rise to danger.

The reporting is all based around what has been tested/inspected and anything that leads towards a dangerous condition

We have to consider the "reality" which exists within the context of the regulations.

However well we know the "real reality" of how the requirement for non-combustible CUs came about, the fact is that, within the context of the regulations, compliance/conformance/non-compliance/non-conformance is being adjudged, and I truly do not see how anyone could realistically argue that a requirement for non-combustible CUs is there for trivial or aesthetic reasons, or for some vague nicety like good materials and workmanship.

I truly do not see how anyone could realistically argue that non-combustible CUs are mandated for any other reason except safety, that plastic ones are unacceptable because of their combustibility.

So given that that is the "reality" constructed by the regulations, I truly do not see how anyone could realistically argue that in that reality a combustible CU cannot give rise to danger.

So as there's no escaping the fact that in the context of the regulations a combustible CU enclosure may give rise to danger, 651.2 (vi) makes it mandatory to do the check in 4.4.

 

[DPG]

I've just liked one of Soi's posts. I must be going soft ?

No offence intended. I think this bottle of Old Crafty Hen has mellowed me!

 

[old man sparky]

You have to.

No other edition exists any more. All the previous ones are obsolete. They have been replaced. They have zero validity. They mean nothing. They are dead and buried.


Indeed not.



It may have been compliant at the time.

It is no longer compliant. Its previous status is a matter of nostalgia only.

Inspections and codings etc can only ever be done to the edition in force at the time. Compliance with earlier editions is of zero value.



Indeed not.



It's the current regulation which applies to all consumer units. There are no other regulations to decide to use.



Ah - well now.

If you decide that you are going to use the model schedule of inspections on pp481-482 of the regs, then you simply cannot give it anything other than a C2 or a C3, as it simply does not comply. (Again, I'm ignoring the other options for the same reasons as before.)

So, may you decide not to use that schedule, and create your own which omits items which are troublesome/contentious?


We have to consider the "reality" which exists within the context of the regulations.

However well we know the "real reality" of how the requirement for non-combustible CUs came about, the fact is that, within the context of the regulations, compliance/conformance/non-compliance/non-conformance is being adjudged, and I truly do not see how anyone could realistically argue that a requirement for non-combustible CUs is there for trivial or aesthetic reasons, or for some vague nicety like good materials and workmanship.

I truly do not see how anyone could realistically argue that non-combustible CUs are mandated for any other reason except safety, that plastic ones are unacceptable because of their combustibility.

So given that that is the "reality" constructed by the regulations, I truly do not see how anyone could realistically argue that in that reality a combustible CU cannot give rise to danger.

So as there's no escaping the fact that in the context of the regulations a combustible CU enclosure may give rise to danger, 651.2 (vi) makes it mandatory to do the check in 4.4.

I agree with all you say. Of course the current version of the regulations is the only one you can base your judgement on. But we do Judge against older versions where older installations are concerned. As an example you would leave an older version of a consumer unit in service and conditions permitting be happy to do so. But you wouldn't install one of those units today from scratch. So a judgement is made based on this. As for plastic consumer units giving rise to danger !! No more than touching a metal one if there's a PEN fault on PME, I suppose.
I'm not disagreeing with you in any way, as said I code 3 plastic and mark 4.4 as C3 with a comment. And happy to do so. Even though I feel that often no code is necessary I feel I have to cover myself on this one, reluctantly. After all your the one signing so you have to be happy with your decisions.

 

[old man sparky]

I've just liked one of Soi's posts. I must be going soft ?

No offence intended. I think this bottle of Old Crafty Hen has mellowed me!

He makes some valid points so why not. ??

 

[Soi disant]

I agree with all you say. Of course the current version of the regulations is the only one you can base your judgement on. But we do Judge against older versions where older installations are concerned. As an example you would leave an older version of a consumer unit in service and conditions permitting be happy to do so. But you wouldn't install one of those units today from scratch.

No, and no more would you necessarily replace it.

I know what you're getting at with the argument that something used to be OK so we should think about that when evaluating it vis-a-vis the current regs, but I'm not sure how well it works. Life is full of things where we used to think they were OK but now we don't, either because new knowledge has shown us that they were never OK, like smoking, or because our standards have changed and we no longer consider the harms as acceptable as we once did, like crash helmets for motorcyclists, or because other factors have conspired to change the risk of something, like increased traffic volumes meaning that a road where it was OK to have a 60mph limit, now it isn't. (As an aside, if ever you're on a speeding charge re a road where the limit had been reduced, good luck with arguing that your speed would have been OK last year ? ).

So a judgement is made based on this. As for plastic consumer units giving rise to danger !!

Well, JPEL/64, in their "wisdom"

have decreed that a mandatory requirement for CU enclosures to be non-combustible comes under the heading "Protection For Safety".

As dubious as the evidence and case provided by the LFB were, and no matter how much JPEL/64 have embarked on a course of chasing ever-more marginal improvements which I'd bet they never subject to a proper cost-benefit analysis, it is what they have done.

So not giving it a C2 is saying that you do not accept that people's safety may be at risk if a safety requirement isn't complied with.

Hmmm.

No more than touching a metal one if there's a PEN fault on PME, I suppose.

Or a metal one where some numpty has carelessly wired in a TT supply and there's a line-to-case fault upstream of the RCD.

I'm not disagreeing with you in any way, as said I code 3 plastic and mark 4.4 as C3 with a comment. And happy to do so. Even though I feel that often no code is necessary I feel I have to cover myself on this one, reluctantly. After all your the one signing so you have to be happy with your decisions.

For the record, I think the whole thing is an utter farce, from the underlying 421.1.201 through to all the gyrations over how to code a contravention.

It's an area where I think we should all be grateful that, however specious their authority is, there are Best Practice Guides from (officially) respected organisations which allow a failure to meet a requirement which the regulations say is mandatory for safety to be coded as only "requires improvement" and not "potentially dangerous".

 

[Lister1987]

No, and no more would you necessarily replace it.

I know what you're getting at with the argument that something used to be OK so we should think about that when evaluating it vis-a-vis the current regs, but I'm not sure how well it works. Life is full of things where we used to think they were OK but now we don't, either because new knowledge has shown us that they were never OK, like smoking, or because our standards have changed and we no longer consider the harms as acceptable as we once did, like crash helmets for motorcyclists, or because other factors have conspired to change the risk of something, like increased traffic volumes meaning that a road where it was OK to have a 60mph limit, now it isn't. (As an aside, if ever you're on a speeding charge re a road where the limit had been reduced, good luck with arguing that your speed would have been OK last year ? ).



Well, JPEL/64, in their "wisdom"

have decreed that a mandatory requirement for CU enclosures to be non-combustible comes under the heading "Protection For Safety".

As dubious as the evidence and case provided by the LFB were, and no matter how much JPEL/64 have embarked on a course of chasing ever-more marginal improvements which I'd bet they never subject to a proper cost-benefit analysis, it is what they have done.

So not giving it a C2 is saying that you do not accept that people's safety may be at risk if a safety requirement isn't complied with.

Hmmm.


Or a metal one where some numpty has carelessly wired in a TT supply and there's a line-to-case fault upstream of the RCD.


For the record, I think the whole thing is an utter farce, from the underlying 421.1.201 through to all the gyrations over how to code a contravention.

It's an area where I think we should all be grateful that, however specious their authority is, there are Best Practice Guides from (allegedly) respected organisations which allow a failure to meet a requirement which the regulations say is mandatory for safety to be coded as only "requires improvement" and not "potentially dangerous".

Fixed that for you.

Page 2 of the regs tells us that while the contributors and publishers believe that while the information to be correct and accurate therein, that all parties must rely on thier skill and judgement when making use of it, so all this take of it takes decisions out of our hands is hokkum. Then we've the HSEs arse-covering exercise at the rear stating that compliance with the regs doesn't guarantee compliance with EAWR, so either way you're damned if you do and damned if you don't.

 

[Julie.]

The wording of 4.4 does not drive one to mandate certain outcomes, this clear example/explanation was given previously:

1. Is it non-combustible wrt 421.1.201? If no then it does not comply, so it cannot be a "pass". It just cannot.
2. C1/C2/C3 - it can be one of those.
3. LIM - what limitation can you justify for not inspecting the CU?
4. N/V - how do you justify not verifying the condition of the CU?
5. N/A - why would it not be applicable to verify the condition of the CU?

(So CUs we MUST advise the customer to replace [C1/2/3] – no choice)

Well, if this is the case, this SAME process MUST be applied to every other case, so in respect of 5.1

1. Are the cables marked wrt 514.3.1 ? If no then it does not comply, so it cannot be a "pass". It just cannot.
2. C1/C2/C3 - it can be one of those.
3. LIM - what limitation can you justify for not inspecting the CU wiring?
4. N/V - how do you justify not verifying the the CU wiring?
5. N/A - why would it not be applicable to verify the CU wiring?

(So if the cables have old colouring we MUST advise the customer to replace [C1/2/3] – no choice)

This would be just plain ridiculous!

It would also mean that the advice given in the BPG wouldn’t line up, it would also mean the nappit guide wouldn’t line up, GN3 which advises similar though not specifically this point, would also not be in line, it would also mean you are not producing a report in line with regulation 653.2. – the list goes on

If however you took the advice/recommendations to report in line with 653.2, and apply codings reflecting the condition of the installation: pass, C1/2/3, lim, N/V, N/A on a per point basis then all the guidance note, BPG and Nappit guides would all basically line up with each other (not in terms of the actual choice, but in principle of allowing the same choices) and allowing the inspector the ability to apply their expertise.



Given the choice between interpreting the regulations of chapter 65 in the former, where it generates ridiculous outcomes, or the latter which appears to be how all the supporting documentation for chapter 65 interprets it – the latter appears the most sensible.

 

[loz2754]

The wording of 4.4 does not drive one to mandate certain outcomes, this clear example/explanation was given previously:

1. Is it non-combustible wrt 421.1.201? If no then it does not comply, so it cannot be a "pass". It just cannot.
2. C1/C2/C3 - it can be one of those.
3. LIM - what limitation can you justify for not inspecting the CU?
4. N/V - how do you justify not verifying the condition of the CU?
5. N/A - why would it not be applicable to verify the condition of the CU?

(So CUs we MUST advise the customer to replace [C1/2/3] – no choice)

Well, if this is the case, this SAME process MUST be applied to every other case, so in respect of 5.1

1. Are the cables marked wrt 514.3.1 ? If no then it does not comply, so it cannot be a "pass". It just cannot.
2. C1/C2/C3 - it can be one of those.
3. LIM - what limitation can you justify for not inspecting the CU wiring?
4. N/V - how do you justify not verifying the the CU wiring?
5. N/A - why would it not be applicable to verify the CU wiring?

(So if the cables have old colouring we MUST advise the customer to replace [C1/2/3] – no choice)

This would be just plain ridiculous!

It would also mean that the advice given in the BPG wouldn’t line up, it would also mean the nappit guide wouldn’t line up, GN3 which advises similar though not specifically this point, would also not be in line, it would also mean you are not producing a report in line with regulation 653.2. – the list goes on

If however you took the advice/recommendations to report in line with 653.2, and apply codings reflecting the condition of the installation: pass, C1/2/3, lim, N/V, N/A on a per point basis then all the guidance note, BPG and Nappit guides would all basically line up with each other (not in terms of the actual choice, but in principle of allowing the same choices) and allowing the inspector the ability to apply their expertise.



Given the choice between interpreting the regulations of chapter 65 in the former, where it generates ridiculous outcomes, or the latter which appears to be how all the supporting documentation for chapter 65 interprets it – the latter appears the most sensible.

Excellent arguments put forward here @Julie.