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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?
Parents
  • 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.



Reply
  • 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.



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