If needed to, what would your defense be for not installing them per the recommendation?
Cost? Questionable efficacy? Space constraints in the DB cupboard?

I know it is not a "requirement" but I'm leaning towards it being a standard item unless there is a documented statement from the client whereby they accept that not installing them is outwith the recommendation of the Regs.

The whole thing about recommendations being just one of several possible ways to skin a cat only holds water when there actually are other ways of skinning it. There just isn't when it comes to AFDDs.

(Assuming they actually work) Nothing else you can readily do will provide the same type of protection against the risk of fire, therefore the recommendation holds.

Whilst a recommendation is not a requirement, the legal implications should something go wrong down the line are potentially rather expensive. Certainly worth the cost of drafting a statement for clients to sign that: explains the clause, the possible implications of not installing AFDDs, and their acceptance of that.

The fact there's debate about this, and the new escape route clause, suggests that there's work to be done on making the language and intent of the regulations clearer.

pww235 said:

The fact there's debate about this, and the new escape route clause, suggests that there's work to be done on making the language and intent of the regulations clearer.

I think the fact that the "helpful" Guidance on the language used in BS 7671 has now been included on Page 18 of BS 7671:2018+A2:2022 has led to the debate; as I pointed out in my earlier response on this thread, the language of the "recommendation" hasn't changed in 2022 ...

Such language is used throughout British (and CENELEC and IEC standards), so moving away from that isn't really an option for JPEL/64.

pww235 said:

The fact there's debate about this, and the new escape route clause, suggests that there's work to be done on making the language and intent of the regulations clearer.

I think the fact that the "helpful" Guidance on the language used in BS 7671 has now been included on Page 18 of BS 7671:2018+A2:2022 has led to the debate; as I pointed out in my earlier response on this thread, the language of the "recommendation" hasn't changed in 2022 ...

Such language is used throughout British (and CENELEC and IEC standards), so moving away from that isn't really an option for JPEL/64.