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?
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 ...
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 ...
