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Rules regarding buried earth cables

Nothing I can see in the regs differentiates between an earth cable and T&E when it comes to the rules regarding buried cables.

But what I can't work out is why it's OK to run a T&E in EARTHED conduit outside of safe zones, but NOT an earth cable, since from the perspective of a nail/screw penetrating into the wall and catching the cable or conduit - there is no difference.