Does a 50m extension lead need to be fitted with an RCD?

Question

I have completed C&G 2377-77 EET / PAT TESTING COURSE and am now seeking some clarification on the code of practice. 
 In the CoP in section 10.10 gives recommended maximum lengths for extension leads, but these can be exceeded if an RCD is fitted. 
 My question is, if I have a 50m extension to test, should I be failing it if it is not fitted with an RCD? 
 If it should have one fitted, why are retailers allowed to sell them without?

gkenyon · Accepted Answer

Christian Ambler said: My question is, if I have a 50m extension to test, should I be failing it if it is not fitted with an RCD? 
 I think the CoP tells us that the answer is no, because it says " this may not be required where RCD protection is provided within the installation " 
 The reality is that there are many off-the-shelf extension lead assemblies are available that exceed the ratings of Table 10.3 of the CoP, that don't have an RCD built in - but the manufacturer has the option to state that the assembly should only be used with an RCD. In addition, the user has an option of providing a PRCD if there is no RCD in the installation itself. The question of whether the product is safe for a particular organisation lies really with the duty holder. You ought to agree with the duty holder in advance of PAT testing, what to do about situations like this. It's really the duty holder's responsibility and decision at the end of the day.

gkenyon · Answer

Further, BS EN 61242 (cable reels for domestic and similar use) has maximum lengths of flexible cable as follows: 
 0.75 sq mm - 30 m 1.0 sq mm - 40 m 1.5 sq mm - 60 m 2.5 sq mm - 100 m 
 BS EN IEC 61316 (industrial cable reels) permits 80 m for cables up to 6 sq mm csa. 
 The standards do not require extension reels to incorporate an RCD (although they may do) 
 Would it be correct to "fail" a product to either of these safety standards, when the standards says they are safe, particularly when the standards are specifically listed as indicating conformity to the essential requirements of the Electrical Equipment (Safety) Regulations 2016 (as amended) ? I really think it's more about PUWER and where and how they are used in the workplace, not "fail because no RCD built-in".

Does a 50m extension lead need to be fitted with an RCD?

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