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Older boards and availability/compatibility of devices

psychicwarrior
I know, I know, its been a subject of many threads over the years...but I am bringing it up again.  More a moan I think over the inflexibility (perhaps with good reason I accept sometimes) at times.


Old Volex board - not even split load...all MCB.   In good order, all aspects look lovely.   Ideally, time for a board change....well if you think so ;-)


Now then,  some minor works (circuit extension) would dictate  the requirement for RCD protection.   Solutions, shift the circuit to small outboard BS61008 enclosure; new board...or source and fit RCBO, which seems perfect and is the most cost-effective and simplest...other than...it seems that using another manufacturer RCBO is seriously frowned on... by Volex at least (and I am sure others).   Well I've known this for a while, but never faced a situation where doing so would be the most feasible option.


Is it really that bad to fit another brand device into an old board...what really are the *real* safety risks if the thing is secure and fits.  I cant really think of any other than fluff - assuming its same rating etc and sits nice.


I've heard the phrase type tested and I take it that means that everything in a consumer unit was tested to perform to standards etc when it was made up.  Then putting in a different RCBO means that is now 'broken' as such.


My question and I am just trying to understand the technical and regulatory issues here:  is it not possible at all, to issue a MEIWC to current Regs as a result of putting in a different branded RCBO (I cannot re-do the type testing etc of course!) and where might/is that prohibition backed up in the 'frustrating' Regs Book please ?




  • 0
    Good to hear you found a workable solution.

    It makes me wonder how we would get on now compared to when we used to just chuck a big component order to RS & Farnell and just assemble stuff straight out of the box/jiffy bag. We never used to bother with all of the paperwork nonsense mentioned in this thread. It either worked or it didn't. We learned by doing rather than endless analysis. That is not saying that we were just guessing in terms of product functionality, it just meant that if a panel was built, and component 'A' failed regularly, we'd go for component 'B' from a different manufacturer.

    Right now, I have to make up a small panel to enable a cap start/cap-run single phase motor to run in both directions. This will entail buying a couple of contacters, and overload unit, an enclosure and some 6 x core cable plus glands.

    Am I a manufacturer? Or am I a mere Assembler?
  • 0
    @roy bowdler "...However, coming from that perspective, should the principal be applied, that a suitably qualified and experienced person, exercising reasonable skill and care can make a decision?..."


    I would hope the answer should be yes, but its more of how you document/prove that     and perhaps the above comments show its not easy for the general electrician to do so, as they do not have access to a setup to do it.  Personally, I think a lot of devices could be (and perhaps are) interchangeable and there ought to be a [easier] mechanism to allow it for practicality, cost and reducing uneccessary waste.


    Anyway,


    Its been really interesting reading all the comments - thank you everyone !   Fortunately, I have secured confirmation from Volex of an approved device.  I am glad because outside of that most feasible solution, the others seemed prety unattractive all things considered.
  • 0
    The last couple of posts gave me pause for thought, when I was first taught the wiring regulations (14th Edition) my Chartered Engineer trainer, emphasised that “engineering judgement” by a “suitably qualified person” was needed when applying regulations and standards.


    As others have noted, fear of litigation and liability is much stronger these days. However, coming from that perspective, should the principal be applied, that a suitably qualified and experienced person, exercising reasonable skill and care can make a decision? Asking the question shows diligence, professionalism and open mindedness towards understand the potential risks whilst seeking to resolve the problem at reasonable cost, which is surely the opposite of being  “gung-ho” or negligent?      


  • 0
    Rather as is the case if you change the lamps in your car from filament to LED, the chaps that do the MOT will decide if the change is enough to invalidate the approval or make the machine unroadworthy.

    It is more interesting for cars over 40 years old, as there is not only no approval, but no compulsion to have an MOT either.  Most vehicles of that era are also tax exempt as well.

    It could make things quite fun if there was a similar exemption for 40 years old or older electrics.?
  • 0
    Just a random thought ...


    A new car is supplied with tyres which have been specified by the manufacturer. Some years later, those tyres may no longer be available 'cos technology has improved. Do you fit new tyres, or scrap the car? ?
  • 0
    Manufacturers of things that must meet the European machinery directive are required to be able to create a technical file on demand, but don't need one initially.

    http://www.hse.gov.uk/work-equipment-machinery/technical-file.htm


     As far as I am aware however, this does not apply to things where just the LVD applies, like switch gear- there a file must exist before CE marking and placing on the market.

    However for a small product, a TCF need not be particularly arduous typically a few sides of A4, maybe less for a box with a switch in it.
    • Description ( may be combined with a labelled sketch and the circuit diagrams)

    • General Arrangement drawing (if complex enough to need one and a photo won't do.)

    • List of standards that apply

    • Records of any risk assessments and assessments to standards - may include the fact that some parts are already meeting some other standards, and have been tested by makers in similar containment structures. Now for something complex, this part may include loads of tests and a full fault tree exploring all failure modes,  but for a switch in a box, it is more of a looking at datasheet values and verifying safe operational area is not exceeded.

    • Description of the logic for any controls with interlocks or relays. (if this occurs, then that happens.. Again, this can expand into a whole chapter if it is a controller for a chemical plant or something.)

    • Datasheets for all critical sub-assemblies - especially those that are bought in as meeting other standards.

    • Part list

    • Copies of any markings and labels

    • Copy of any instruction leaflet  or handbook  you create to go with it, (user, maintenance, installation)

    • Test results, and descriptions of method of test if not obvious, and any QA commissioning procedures


    Then the killer for the indemnity insurance is the signed  bit of paper saying I (name) hereby certify that (thing) described in this file meets the requirements of the relevant directives which are .. (list)


    and then for the next decade you need to be able to produce that file again on demand.

    Which almost never happens, which is good, as I am sure a great many things exist for which the TCF would not stand up to scrutiny.







  • Former Community Member
    0 Former Community Member
    FWIW my take on this is that you can mix and match if the manufacturer of both the enclosure and existing devices, and the new device states that they are compatible.

    e.g. Schneider making a statement with regard to their new breakers and their older Merlin Gerin range.


    The issue lie outside BS 7671 it lie in the Electrical Equipment (Safety) Regulations, UK law and how the manufacturers comply with this regarding their consumer units and devices.


    The manufacturers take the presumption of conformity route, bu designing, manufacturing and testing in accordance with the harmonised standards.

    They do this for their range of devices and product that they foresee as being required to be utilised together.

    This gives them a type tested assembly and offers compliance with the law.

    So, anything that moves away from this manufacturers type tested assembly, either has to be declared as safe by them, e.g. the example above, or the person who modifies the assembly must ensure that it meets the requirements of the law.

    They are placing a new assembly onto the market which is now no longer type tested and thus, must be verified as compliant with the requirements.


    Now there is a British Standard that you can follow for the modification of distribution boards which is around £200 IIRC.

    This covers device substitution in a type tested assembly as part of its remit, however, the standard states that following the guidance does not guarantee compliance with EN 61439, or any preceding standard.


    The final issue that may be experienced as that as the unit is a type tested assembly, you would be looked on as the product supplier of this new, type tested assembly, and, may not have product liability insurance for the design, manufacture and supply of products into the market place.

    Then you would have the technical file to compile and present to HSE, if there were an issue, and the devices/board OEM would not have to legally provide you with any information over and above that in the public domain.  Which would be inadequate to compile a technical file.


  • 0

    AJJewsbury:




    because from what you say it seems to imply that if any work is done then everything must be brought up to current Regs



    I don't think it's quite as bad as that - by my reading at least it's only when you're adding devices not specified by the original assembly manufacturer - if you could find an MCB that was officially compatible then you're fine (and the assembly only needs to remain compliant with its original standard). As I read it it's just saying that if you add in "wrong" devices today, you need to ensure that the overall result complies with today's standards.


      - Andy.

     




    I think so too.  What I was meaning is that I could see someone trying to argue that making any changes in the board means that what ever is done meets todays Regs (inc. assembly, selection standards and so forth).  At the least, I am happy that changing a device or adding a new device in an old board is fine so long as the original manufacturer supports/approves/confirms/whatever , 'it'. 

  • 0

    because from what you say it seems to imply that if any work is done then everything must be brought up to current Regs



    I don't think it's quite as bad as that - by my reading at least it's only when you're adding devices not specified by the original assembly manufacturer - if you could find an MCB that was officially compatible then you're fine (and the assembly only needs to remain compliant with its original standard). As I read it it's just saying that if you add in "wrong" devices today, you need to ensure that the overall result complies with today's standards.


      - Andy.
  • 0
    Actually it is not even clear if it is always deemed to comply when all the bits are bought from the same source.
    an example of more restrictive conditions.

    Although we do supply all our components as separate items on our invoice, we can and do ship the the components already assembled, if you wish us to, at no extra cost. Where the resulting Distribution Board, as designed by you, is not certified to BSEN61439-3, it should comply with BS7671:2008, AMD3, 421.1.201 and/or 133.1.3.

     




    Which I read as ' you decided what to put in it, so it is your responsibility'.

    And of course it will be fine in practice, and even if it wasn't it is not non compliance with some EU standard that matters, but the fact it has burnt the wall paper or whatever.

     


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