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Unintended consequences and Amd 2

There seem to be many unintended consequences generated by the Amd 2 DPC. I wonder why it is US who sees them and not JPEL/64? Is it the lack of experience of JPEL/64 or is it something else?
  • I am of course suggesting that these consequences are unintended. Anything else is certainly the area of serious conspiracy theories.


    Among the consequences I see are:


    1. A vast increase in the costs of all electrical installations.

    2. The public becoming even warier of electricians, and subsequent effects on actual safety.

    3. An increase in poor quality DIY modifications.

    4. The whole electrical system becoming dangerous, both in age and it's structure.

    5. Building control measures appearing in BS7671 (foundations), which is exactly the wrong place.

    6. EICRs becoming virtually impossible because defects are hidden, or unfixable, or both.

    7. Inspection giving a list of "defects" which are only the stroke of a pen, and not dangerous at all.

    8. Total loss of faith in electricians because all these things are outside their control, with consequent reduction of work.

    9. Failure to update the EICR chapter, with advice on exactly how to treat lack of AFDDs, Foundation electrodes, and SPDs in existing installations.


  • If we are not careful, this thread will have (if not already) the unintended consequence of breaching a couple of the Rules of Conduct
  • They say you can't put a price on safety, but when that price is £1000+ for an old £500 board change the price of safety becomes hard to swallow for the customer. Especially if their dual RCD split load board has given them 10 years of faultless service. Electricians will just be made out to be the money-grabbing rogue traders that the public already half expect of us. JPEL/64 aren't the ones having to convince customers that its the regulations now and your not trying to fleece them are they?
  • gkenyon:

    If we are not careful, this thread will have (if not already) the unintended consequence of breaching a couple of the Rules of Conduct


    Will it?  How so?  Calling out problems is the first step to solving them.  I note rule 9.  Which rules are you referring to?


  • 3 and 13 ... so we need to be careful how this discussion goes.


    No need to assert others have a lack of experience, for example.


    The DPC is a "draft for public comment" - not a "dispensation for persistent complaint" - provide constructive comment and informed argument if there's something that doesn't sit right. More importantly, provide a suggestion of what you'd like to see a particular Regulation say, and how you think things should work..



    To assist the discussion, I will have a go at the list:

    1. A vast increase in the costs of all electrical installations.
    I guess this is about AFDDs. That was the argument against RCDs for a long time. Is there a stack of evidence against the introduction?

     

    2. The public becoming even warier of electricians, and subsequent effects on actual safety.

    Is there evidence for this, or is this really point 1?

     

    3. An increase in poor quality DIY modifications.

    Is there evidence for this, or is this really point 1?

     

    4. The whole electrical system becoming dangerous, both in age and it's structure.

    What do you mean by this? If it's the public network, then let's have some suggestions how to deal with this? I'm sure as an Institution, if something could, or should, be done, we can mobilise the correct sort of discussion and support to make it happen?

     

    5. Building control measures appearing in BS7671 (foundations), which is exactly the wrong place.

    Well, potentially - although I think there's a counter-argument for this (relating to PEIs and replacement of metal water and gas pipes in those networks) . The opportunities for additional "fortuitous earthing" via extraneous-conductive-parts are diminishing ... through no fault of anyone directly, because our metallic service pipes for gas and water are being replaced for safety and public health reasons respectively. This is not the fault of the electrician, the DNO, or the installation owner, but it's still a fact. It's also a fact that we can't make PME disappear overnight - just like replacement of the cast iron service pipes, it would take 10s of years.


    So, in the mean-time, what is to be done? Let's have some constructive ideas ... and it could be said Foundation Earthing is perhaps one of those. Having said that, it might not be.


    Why can't electricians sort out stuff to do with Foundation Earthing - they are involved in other works involving Civils such as cable trenches etc., and sometimes might need to call in other construction disciplines to help with those too?"

    More effective earthing will be necessary for PEI - and that has nothing to do with DNOs and PME, or EV.

     

    6. EICRs becoming virtually impossible because defects are hidden, or unfixable, or both.

    I think this is a good point - and of course we will be moving to a place where testing to uncover defects (other than protective conductor continuity) is becoming more difficult. See also Draft Regulation 826.7 in the Amendment 2 DPC.

    So again, how should we combat this? Things are only going to get more difficult in that area.


    7. Inspection giving a list of "defects" which are only the stroke of a pen, and not dangerous at all.

    Inspectors assigning C1 or C2 to things that should have a C3? Discussion thread this week on "shall" requirements case in point ... yet the guidance is already there in BS 7671 (relating to RCDs).


    8. Total loss of faith in electricians because all these things are outside their control, with consequent reduction of work.

    Is there any evidence for this? What's your point of view based on?


    9. Failure to update the EICR chapter, with advice on exactly how to treat lack of AFDDs, Foundation electrodes, and SPDs in existing installations.

    I think that's pretty clear - FI or C3.

    SPDs isn't an easy one outside dwellings and smaller commercial installations - for example, if you have a building with a lightning protection system to BS 6651, the effectiveness of SPDs would be unknown, and would require the existing LPS to be re-assessed against BS EN 62305. Not that this directly relates to BS 7671, because if the building has an LPS, it's effectively "de-scoped" from BS 7671 and BS EN 62305 must be used in any case ...

  • gkenyon:

    3 and 13 ... so we need to be careful how this discussion goes.


    No need to assert others have a lack of experience, for example.


    The DPC is a "draft for public comment" - not a "draft for persistent complaint" - provide constructive comment and informed argument if there's something that doesn't sit right. More importantly, provide a suggestion of what you'd like to see a particular Regulation say, and how you think things should work..



    To assist the discussion, I will have a go at the list:

    1. A vast increase in the costs of all electrical installations.
    I guess this is about AFDDs. That was the argument against RCDs for a long time. Is there a stack of evidence against the introduction?

     



    I'm not so convinced about rule 3 and 13 applying to this thread but there's nothing wrong with being careful.


    It's not my list but I'll comment to your response to item 1.  Yes, a small but noteworthy one.  I have also contributed to the DPC comments process.  I shall PM you. 


  • Whilst I have been quite careful in my comment, the clear reason for a DPC is to engage public discussion by those interested. To suggest that public discussion is in some way harmful to the profession, or the IET, is somewhat strange and if necessary we can move to a much more public forum such as Twitter. That publication of potential costs would cause a storm of protest, probably a lot of it aimed at the IET wiring regulations. The public generally holds the IET's knowledge and capability of its Engineers with high regard, and therefore it looks very responsible. I uphold that responsibility very seriously and am shocked at some of the DPC content. A very strong response IS required, hence the discussion. Keeping quiet is a very depressing option, demonstrating a huge decline in professional standards.


    The comments made on the amendment 1 DPC received extremely little feedback to the commentator, although many changes were made in the final text. Several persons pointed out at that time that the price of AFDDs, in particular, should at least defer the introduction, in the comments section of the DPC BSI web-page.


    Let us consider the cost/benefit analysis of the AFDD. There are roughly 30 million domestic installations. Most have 6-8 circuits. The cost of adding AFDDs to these 500 million circuits is around £50billion assuming a reduction of 50% in the current price, a staggering sum. How many fires would be prevented, considering that experiments find it almost impossible to operate the things? Let's guess and say 10 per year. This is unrealistically expensive by any measure. If someone could show that it would stop all fires of electrical origin then such a cost might be reasonable. Unfortunately, there is no such evidence despite the USA having had them for at least 10 years, plenty long enough to detect a change in the statistics.


    Now the foundation Earthing. What is it for in domestic premises, at 20 Ohms it does very little to nothing? It is not terribly expensive, and would allow all installations to become TT fairly easily, removing the danger of broken PEN conductors in the supply system, but is this the intent? I have seen NOTHING written in such a major change to our Earthing system, the question is why? Is it because PME is dangerous now? That is not the consumer's problem, it is the supply industry's and their fault for maintenance failure. The change is needed to the ESQCR, not BS7671. Transferring the cost of previous failures to the consumer is grossly unfair; although fairly common in Government, but not private industry.


    As I currently understand the law, it will be necessary for all installations in a private rented property to be fully compliant with BS7671 after April 1st 2021. Fully compliant is not a FI or C3, it is a straight fail. Strangely the EICR does not contain such an option, which is impossible for the Inspector. Even if compliant on March 31st, they fail on April 1st, and not because they are in any way dangerous. Perhaps the lack of surge protection or AFDDs may be ignored in existing installations, on the dubious basis that an Inspector may ignore the requirement because the installation is not unsafe. Certainly, my PI insurer would not be happy with that so I am on my own. The IET did not make the law, although they presumably provided advice, or perhaps were not asked? If this is the case, the IET should block the change, or get the law changed, but it is probably too late and considered too difficult.


    I leave others to ask the obvious questions remaining. It is nearly as bad as the "advice" (with fines etc.) on how to stop covid-19 infection of the population.



  • David,


    No problem with discussing things and happy to join in with that.

    ... questioning people's experience just because of a differing point of view, however, is not a good start and certainly not conducive to discussion.


    I don't disagree with statement of cost regarding AFDDs, but I perhaps hold the view that, just like RCDs, the costs will come down and the devices will improve.


    Foundation earthing perhaps requires more discussion - but I don't think it's all about PME. See proposed Chapter 82, local earthing is becoming necessary for PEIs operating in island mode. (Even if Chapter 82 is taken out of BS 7671, PEIs will still happen, and local means of earthing is still necessary.)


    And in terms of legislation ... that's a different pay-bracket to BS 7671.
  • gkenyon:

    I don't disagree with statement of cost regarding AFDDs, but I perhaps hold the view that, just like RCDs, the costs will come down and the devices will improve.

    The big difference from RCDs of course is that one AFDD is required per circuit, and most circuits need protection. Even today many people choose a CU with only 2 RCDs, and a board fully-populated with RCBOs is seen as a bit of a "nice to have" for those who can afford it. So even if AFDDs come down in price to to be comparable with RCBOs, the average cost of a CU replacement has just gone up considerably.
  • Legally, rented properties have to be compliant with BS7671:2018. BS7671:2022 would only become a requirement if and when the Secretary of State, upon prompting by their civil servants, updates the statutory instrument. If this happens, it becomes illegal for a landlord to continue even existing tenancies unless all relevant circuits have AFDDs added. Of course it's possible that at the same time the SoS modifies the SI so that it no longer requires strict compliance with a particular edition of BS7671, and the requirement becomes rather that the installation is safe, as evidenced by a passing EICR to part 6.