Wiring Regs scope, inside 19" rack cabinets?

Hi everyone,

The US-based company I work for needs to send a 19" rack cabinet of computers, PLCs and network equipment to the UK for temporary installation in a research facility. We've been advised (quite rightly) that we need to ensure compliance with UKCA marking requirements and be able to provide a technical file for this. It's been a while since I was involved in compliance things, but my understanding is that the technical file is normally just about demonstrating compliance with the harmonised norms, e.g the low voltage directive. However as this will be a cabinet "installed", i.e. fixed, in position, with power distributed within it, I wondered if it is also in scope of the BS 7671?

Advice much appreciated on this, especially from anyone with practical experience of a similar situation.

Thanks,

Will

Parents
  • The US-based company I work for needs to send a 19" rack cabinet of computers, PLCs and network equipment to the UK for temporary installation in a research facility. We've been advised (quite rightly) that we need to ensure compliance with UKCA marking requirements and be able to provide a technical file for this.

    Is that true for all temporarily installed equipment - I'[m sure there are 'opt-outs' for temporary test, R&D, etc equipment? I guess it depends on the actual purpose, and of course checking to see if the essential requirements are met is always recommended at least for H&S reasons ... certainly, on the safety side, if the normal UK safety standards are not met, other measures would need to be put in place to mitigate any hazards.

    However as this will be a cabinet "installed", i.e. fixed, in position, with power distributed within it, I wondered if it is also in scope of the BS 7671

    Possibly, at least in part.

    Certainly the earthing should be checked for compliance with Section 543.7 of BS 7671 (although note this changed in 2022, for example 'dual earth terminal' is not longer a requirement, but of course can still be selected by a designer), and also earthing checked to BS EN 50310 at installation (ultra-low resistance ohm-meter or micro-ohm-meter test).

Reply
  • The US-based company I work for needs to send a 19" rack cabinet of computers, PLCs and network equipment to the UK for temporary installation in a research facility. We've been advised (quite rightly) that we need to ensure compliance with UKCA marking requirements and be able to provide a technical file for this.

    Is that true for all temporarily installed equipment - I'[m sure there are 'opt-outs' for temporary test, R&D, etc equipment? I guess it depends on the actual purpose, and of course checking to see if the essential requirements are met is always recommended at least for H&S reasons ... certainly, on the safety side, if the normal UK safety standards are not met, other measures would need to be put in place to mitigate any hazards.

    However as this will be a cabinet "installed", i.e. fixed, in position, with power distributed within it, I wondered if it is also in scope of the BS 7671

    Possibly, at least in part.

    Certainly the earthing should be checked for compliance with Section 543.7 of BS 7671 (although note this changed in 2022, for example 'dual earth terminal' is not longer a requirement, but of course can still be selected by a designer), and also earthing checked to BS EN 50310 at installation (ultra-low resistance ohm-meter or micro-ohm-meter test).

Children
  • Much of what we do is R and D or temporary ,and the legal advice has always been to always UKCA or CE mark if there is money or benefit in kind changing hand, even business to business when the recipients do not want or need the marking for their own purposes.

    That said, the technical effort behind deciding it is OK to stick the label on varies a lot between organizations ,and on how much the components involved have already been tested by others.

    Free-issue loan or demo equipment, is less important but as I understand it, there is no exception in law for things that have a price, temporary or R and D.

    The exception we do occasionally use is for self assembly kits - if the customer gets a bag of bits and then builds it themselves in some way then, apparently, they are the manufacturer, not us.

    However, a legally very dim view is taken of trivialization of this route- such as supplying near complete kit but without a plug or a single lead that the user fits,  it has to be fairly "significant assembly", whatever that really means in practice.

    Mike.

    typos edited for clarity.

  • Thank you Graham, very helpful.

  • I wanted to avoid looking for "loopholes" as we don't want to risk the equipment being rejected. Technically this is neither a loan nor a demo, nor a sale or benefit in kind or anything like that. The equipment will remain in the possession of our company and will be installed for testing purposes at the research facility of the host. The host will provide us with space, access, power and networking. I think the key thing for us is to understand how they will provide the power and what their site-specific requirements for our cabinet are.

  • Much of what we do is R and D or temporary ,and the legal advice has always been to always UKCA or CE mark if there is money or benefit in kind changing hand, even business to business when the recipients do not want or need the marking for their own purposes.

    Yes, that's always the recommended approach. However, exceptions are permitted, for example see Regulation 3(2) of the EMC Regulations 2016 (as amended): www.legislation.gov.uk/.../3

  • I wanted to avoid looking for "loopholes" as we don't want to risk the equipment being rejected.

    Yes, this is definitely the best approach, and, like Mike, with the exception of individual experimental circuits in a suitable lab or workshop, something I would always follow myself.