BS7671 or Wiring Regulations?

Chris Pearson:

 

So the reason I didn't mention this, is that it only requires periodic verification to BS 7671, not full compliance (although that could be inferred by having to address defects, it could be debated that only "make safe" not "fully comply" is required).

ESQCR 2002:

Switched alternative sources of energy

21.  Where a person operates a source of energy as a switched alternative to a distributor’s network, he shall ensure that that source of energy cannot operate in parallel with that network and where the source of energy is part of a low voltage consumer’s installation, that installation shall comply with British Standard Requirements.


That's pretty wide - I wonder how many Standards would apply in addition to BS 7671?

It's not as wide as the simple words of the particular Regulation would have you think -  have a look under Regulation 1(5), which defines "British Standards Requirements" as "the British Standard Requirements for Electrical Installations BS 7671"


Interestingly, the ESQCR requires amending regularly, because when originally made, and at each amendment, a specific version of BS 7671 is cited.

Dutch of the Elm:
Hi Graham, I’d like to agree with you with regards to the PRS Regulations, only I think that another, much more onerous interpretation may be easily adopted.  I.e. that the installation is required to meet the requirements of BS 7671:2018. 

That interpretation is one which a hypothetical (or real!) prosecution could quite reasonably and easily adopt. 

See Regulation 3(1)(a) of Part 2 (excerpt provided below for clarity), which says “ensure that the electrical safety standards are met. . .”


“Electrical safety standards” are clearly defined in Part 1 as meaning those of BS 7671:2018.



I think we all would agree that the wording of the PRS Regulations is poor and ill thought out, but I just wanted to make the point that simply testing in accordance with BS 7671:2018 will likely not be good enough given the wording of this statutory document.  Anyone choosing to interpret the statutory document according to what they think it should have said, is taking quite a risk. 

 

Well this is interesting. Have a look at my previous post, and then consider that, if the premises has Solar PV or similar grid-connected generation, the ESQCR currently requires BS 7671:2008, so we have two pieces of legislation that are otherwise incompatible ,,, unless there's some scope for interpretation permitted in this area. There is no other interpretation, otherwise conforming to ESQCR means a landlord with local grid-connected generation may not be able to conform to the PRS Regulations (or, vice-versa) - which is clearly nonsense.

gkenyon:

Dutch of the Elm:
Hi Graham, I’d like to agree with you with regards to the PRS Regulations, only I think that another, much more onerous interpretation may be easily adopted.  I.e. that the installation is required to meet the requirements of BS 7671:2018. 

That interpretation is one which a hypothetical (or real!) prosecution could quite reasonably and easily adopt. 

See Regulation 3(1)(a) of Part 2 (excerpt provided below for clarity), which says “ensure that the electrical safety standards are met. . .”


“Electrical safety standards” are clearly defined in Part 1 as meaning those of BS 7671:2018.



I think we all would agree that the wording of the PRS Regulations is poor and ill thought out, but I just wanted to make the point that simply testing in accordance with BS 7671:2018 will likely not be good enough given the wording of this statutory document.  Anyone choosing to interpret the statutory document according to what they think it should have said, is taking quite a risk. 

 

Well this is interesting. Have a look at my previous post, and then consider that, if the premises has Solar PV or similar grid-connected generation, the ESQCR currently requires BS 7671:2008, so we have two pieces of legislation that are otherwise incompatible ,,, unless there's some scope for interpretation permitted in this area. There is no other interpretation, otherwise conforming to ESQCR means a landlord with local grid-connected generation may not be able to conform to the PRS Regulations (or, vice-versa) - which is clearly nonsense.

So if you built a house today, which had grid connected PV, you would apply BS 7671:2008 throughout the whole installation?  Not BS 7671:2018?  I guess you could then use a plastic consumer unit.  Or would you rather understand that ESQCR was written when BS 7671:2018 did not exist, and so could not have cited it.  I don't think that this gives us the right to decide that the most applicable standard is one that predates the one that is explicitly stated.  When the 19th Edition arrives, we may have a similar scenario with the PRS regulations but in that case, we will still be requiring compliance to the 18th, or perhaps the 19th but not previous editions.

 

so we have two pieces of legislation that are otherwise incompatible

Or would you rather understand that ESQCR was written when BS 7671:2018 did not exist, and so could not have cited it.

gkenyon:

Chris Pearson:

 

So the reason I didn't mention this, is that it only requires periodic verification to BS 7671, not full compliance (although that could be inferred by having to address defects, it could be debated that only "make safe" not "fully comply" is required).

ESQCR 2002:

Switched alternative sources of energy

21.  Where a person operates a source of energy as a switched alternative to a distributor’s network, he shall ensure that that source of energy cannot operate in parallel with that network and where the source of energy is part of a low voltage consumer’s installation, that installation shall comply with British Standard Requirements.


That's pretty wide - I wonder how many Standards would apply in addition to BS 7671?

It's not as wide as the simple words of the particular Regulation would have you think -  have a look under Regulation 1(5), which defines "British Standards Requirements" as "the British Standard Requirements for Electrical Installations BS 7671"


Interestingly, the ESQCR requires amending regularly, because when originally made, and at each amendment, a specific version of BS 7671 is cited.

Ah yes, if in doubt read the definitions! 


ESQCR 2002 originally BS 7671: 2001 (16th+1); amended 2006 to 16th+2 (2004) which took only a couple of years; and last amended 2009 to 17th in just over a year. The SoS for Energy (and whatever else) needs to pull his socks up! I wonder whether to write to my MP again? ?

I wonder whether to write to my MP again?

AJJewsbury:

Or would you rather understand that ESQCR was written when BS 7671:2018 did not exist, and so could not have cited it.

They could have simply referred to the 'current' version of BS 7671 - and I gather that was suggested during the review process - and rejected. Apparently Parliament have a principle that they and only they make the (statute) laws of the land - and don't like to give that power directly to the likes of the IET or BSI - which would effectively be the case if anything written in BS 7671 automatically became law. They describe such as thing as "ambulatory" legislation (presumably in the sense that it isn't fixed but can move about) and don't like it one bit. The result is a deliberate policy of examining changes to BS 7671 and only adopting them if they like it (as and when they get around to doing say that it ... which they don't seem too efficient at).


   - Andy.

Yes, I think you've nailed this one. Apparently, any reference documents in legislation must be dated (as is the legislation itself). I think this is at least as much to do with how the legislation is used in court proceedings, as much as wanting "control", but then again you'd never know?

gkenyon:

AJJewsbury:

They could have simply referred to the 'current' version of BS 7671 - and I gather that was suggested during the review process - and rejected. Apparently Parliament have a principle that they and only they make the (statute) laws of the land - and don't like to give that power directly to the likes of the IET or BSI - which would effectively be the case if anything written in BS 7671 automatically became law. They describe such as thing as "ambulatory" legislation (presumably in the sense that it isn't fixed but can move about) and don't like it one bit. The result is a deliberate policy of examining changes to BS 7671 and only adopting them if they like it (as and when they get around to doing say that it ... which they don't seem too efficient at).

Yes, I think you've nailed this one. Apparently, any reference documents in legislation must be dated (as is the legislation itself). I think this is at least as much to do with how the legislation is used in court proceedings, as much as wanting "control", but then again you'd never know?

Something like the Interpretation Act 1978?


In this day and age, it shouldn't be difficult for somebody in each Govt. Dept. to maintain a database of legislation which has date specific references to standards, etc.


It's not so much "control" as the sovereignty of Parliament - you wouldn't want to muck about with that, would you?