what to suggest when no circuits have rcd protection

[The Ghost]

Which 13 A socket-outlets in commercial and industrial premises are required to have additional protection by RCD?
Socket-outlets in commercial and industrial premises must have additional protection by means of an RCD if they are rated at 20 A or less and are for general use without the supervision of a skilled or instructed person. An exception is made for a specific labelled/identified socket-outlet for a particular item of equipment.

The decision as to which socket-outlets are provided with RCD protection in accordance with these criteria should be made in consultation with the client’s duty holder under the Electricity at Work Regulations 1989.

As a general principle, it may be considered that socket-outlets in commercial and industrial premises needing to have additional protection by means of an RCD include the following: those in common, circulation and public areas; those in self-catering areas; those intended for use by cleaners; and those that may reasonably be used to supply mobile equipment for use outdoors.

The regulation number governing this matter 411.3.3 From ElectricalSafetyFirst.org

 

[The Ghost]

Can't see why either the code C1 or C2 would be warranted.
Workplaces are legally required to have skilled or supervised workers, and there is no requirement to provide RCD protection for sockets that might be used for equipment outdoors.

Well there is the above. Over the four buildings we work on containing maybe 200 tenants (commercial) there are only a couple of skilled and no supervised workers.

 

[Deleted member 26818]

Out of date, though it was incorrect when in date.
Now required for all, except for specific items of equipment and where there is a documented RA showing it is not required.

If there are no skilled or instructed persons there, you really should consider contacting the HSE.

 

[The Ghost]

What would I say. Oh the council offices in the building just have people who deal with children there are no qualified supervisors ? Or the person who makes cakes only knows how to make cakes ?

 

[Deleted member 26818]

It is a legal requirement for workers to be experienced, have technical knowledge or be under such supervision so as to be aware of the dangers electricity may present.
Or in the parlance of BS7671, skilled or instructed.
If you are stating that there are workers who do not have the experience, technical knowledge or are being adequately supervised, then the employer is breaking the law.
All you need to do is tell the HSE, that Regulation 16 of the EAWR is being breached.

 

[The Ghost]

Yes well they are independent businesses who as I say make cakes do officey things and have little to no interest in electricity etc. There is no employer they are tenants and do their own thing whatever it may be.

 

[Deleted member 26818]

If they are workplaces, then the EAWR applies.
Regulation 16 requires: No person shall be engaged in any work activity where technical knowledge or experience is necessary to prevent danger or, where appropriate, injury, unless he possesses such knowledge or experience, or is under such degree of supervision as may be appropriate having regard to the nature of the work.

In other words, they should not be banging nails in or drilling into walls unless they know to check there are no cables concealed in the wall, that should not be using equipment with damaged plugs or leads and that they should not be using mobile equipment outdoors without RCD protection.

 

[The Ghost]

Yes well you and I may know that but people dont always follow rules. Where I put up barriers and notices saying Danger do not enter or Danger of Death people remove them and go into the area and have to be asked to leave. Although the tenancy agreement stipulates they are not supposed to do anything electrically, they do! So what do you do with such people ? personally I recommend RCD additional protection to save them from themselves.

 

[Deleted member 26818]

If these people are willing to breach statutory requirements, why should they comply with a non-statutory EICR?
Also, if you are not so concerened about the law being broken that you will not report it to the HSE, why would you produce what is in effect a fraudulent report?

 

[The Ghost]

Oh yeh looking at it C1 was for special locations.

 

[The Ghost]

Removal of the exception for socket-outlets for use under the supervision of skilled or instructed persons
Unlike the current version of Regulation 411.3.3, the new version does not permit the omission of RCD protection to a socket-outlet just because the socket-outlet is for use under the supervision of skilled or instructed persons.

The exception for socket-outlets for use under the supervision of skilled or instructed persons was removed because:

• it was no longer seen as having any relevance, given the development in the application of RCDs to the general requirements of BS 7671 over recent years; and
• there had been reports of the exception being abused, such as RCD protection to socket-outlets at a school being omitted on the basis that they were to be used under the supervision of a person instructed by the head teacher.
  
  The person who prepared the risk must be prepared to justify his or her conclusion that RCD protection was not necessary, possibly in a court of law, especially if someone was killed or injured as a result of the RCD protection being omitted.
  

 

[The Ghost]

The above from RCD protection - IET Electrical - http://electrical.------.org/wiring-matters/54/rcd-protection-of-sockets/index.cfm
shows that even under the supervision etc. ommision is not permitted unless a documented RA is undertaken. Given the time taken for RA and the onerous consequences in case your RA is wrong and the costs to the client, would it not be better to say make it C3 and recommend a relatively cheap obviation of danger? In any event the landlord is responsible for the electrical installation in terms of maintenance and safety. In turn he will rely upon his CEO who will rely on appointed people to inform him of the safest options. I would say the time and cost of RA say 150 units with the consequent legal risks is impractical especially compared with just fitting an RCBO and have done with the matter once and for all.

 

[The Ghost]

411.3.3 Additional protection

In a.c. systems, additional protection by means of an RCD in accordance with Regulation 415.1 shall be provided for:

(i) socket-outlets with a rated current not exceeding 20 A, and

(ii) mobile equipment with a current rating not exceeding 32 A for use outdoors.
It would seem regs require RCD and using the RA method for exception is supposed to be a rare occurence. It would not be rare if I RA every Unit and found no need for RCD, and I do not think the CEO would pay for it either.

 

[Risteard]

I would say the time and cost of RA say 150 units with the consequent legal risks is impractical especially compared with just fitting an RCBO and have done with the matter once and for all.

The Risk Assessment is for the client to provide if necessary. I certainly wouldn't be doing it for them - if they believe that an RCD should be ommited then let them justify that view. It is their duty, not yours.

 

[The Ghost]

The Risk Assessment is for the client to provide if necessary. I certainly wouldn't be doing it for them - if they believe that an RCD should be ommited then let them justify that view. It is their duty, not yours.

Yeh but it is not the client that is responsible or even competent it is the CEO who has overarching responsibility

 

[The Ghost]

I was really more hoping for views like the OP about classifying this area, as we have inherited this report for whatever reason and are essentially grappling with the same considerations. I am looking for constructive criticism leading to a fair resolution not accusations of a criminal nature from a trusted advisor most especially in a public arena. For instance if you think it is all C3 including special locations please enlighten with reasons is it not what this forum is for, keeping it polite and professional ?

 

[bigspark17]

It sounds to me V although your approaching this eicr as if it a EIC, you are there to assess safety for continued use! Which scheme are you with?

 

[The Ghost]

This is light commercial, but I am with STROMA but how would you assess safety for continued use where there are showers with no RCD?

 

[The Ghost]

This report we have btw is inherited from a large well known firm. So anything on it is what they have found. We for whatever reason are dealing with the report and their perceptions on RCD's and classifications hence the interest in other views of classification

 

[Risteard]

This report we have btw is inherited from a large well known firm. So anything on it is what they have found. We for whatever reason are dealing with the report and their perceptions on RCD's and classifications hence the interest in other views of classification

I'm a bit confused. Are you saying that the EICR has been compiled by others and you are now carrying out remedial works based on it?