Just out of interest; the regs state do they not that the designer/installer (that's us) is liable for the correct operation of the kit... Zappi or matt:e or whomever are presumably not liable if their kit fails and kills someone in the case of an open neutral or similar? It's us who are liable. (So I was told by NAPIT...).
John Peckham:
Andy
I think Mr Fox and NAPIT are referring Note 5 to Regulation 722.411.4.1. As these novel O PEN type devices have no BS or BS EN or harmonised standard they have to be designed in and installed as a Departure in accordance with 133.1.3 and 511.1 and 511.2.
JP
Ah, reassuring it's not thought to be a general requirement.
The note reads:
NOTE 5: See Section 511. BS 7671 does not deal with the safety requirements for the construction of electrical equipment. Where equipment to be used is not covered by a British or Harmonized Standard or is to be used outside the scope of its standard, it is the responsibility of the electrical installation designer or other person responsible for specifying the installation to establish that the manufacturer of the equipment has ensured that the equipment satisfies the safety objectives of the relevant Directive(s), as it will not benefit from a presumption of conformity afforded by the appropriate product standard.
John Peckham:
Yes Andy as the Note says, "it is the responsibility". So the designer or the specifier needs to demonstrate due diligence in the selection of the device. I think that obtaining a Declaration of Conformance listing compliance with all the standards specified in 722 and compliance with the Statutory provisions of the Low Voltage and EMC Regulations would provide a good level of protection for the designer. Of course if a manufacturer cannot do this you might want to look elsewhere. of course the products are required to be marked CA or CE or UKNI to be placed on the market for sale.
JP raised this important issue. I went to NICEIC for some further advice. This is their reply;
"Regulation 722.531.3.101 of BS 7671: 2018 amended 2020, requires that unless the protective measure of electrical separation is used, each charging point shall be protected by a 30mA Residual Current Device. Within the same Regulation it states that the RCD shall comply with one of the following British Standards; BS EN 61008-1, BS EN 61009-1, BS EN 60947-2 or BS EN 62423.
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