Chris Pearson said:

I can see that a risk assessment for inaccessible sockets or those in restricted areas might permit the absence of RCD protection, but not where an ordinary person might plug in a piece of office equipment, a portable power tool, or a vacuum cleaner, etc.

Well, even then, you need to demonstrate that the risks are limited (e.g. access to the equipment powered is also limited, and/or some other precautions taken) ... see my previous post.

Chris Pearson said:

So how long do we allow for a building to be upgraded?

Not the point, the issue is that a new machine is being connected up, so the question gets asked at that point, 'Do we fit an RCD now as required by the current version of BS 7671, or are there other mitigating measures in place that means it's safe so far as reasonably practicable'

Of course, if the manufacturer of the machinery recommends or requires RCD protection, you've not really got a leg to stand on in any case, under Section 6 of H&S@Wetc.Act, and PUWER.

This question is the sort that will never get a simple answer.

The obvious answer is "yes, of course it is".  But nobody actually wants to stick their neck out and say it.

It's like asking "are polar bears white?"  Nobody is going to say "yes".  Instead, they will all try to find reasons why the answer is "no" or "maybe".

• Their fur isn't really white.  It's transparent, so it scatters the light.  It only looks white from a distance.  And looking at a polar bear from a long way away is probably the best place to be.
• They always look a bit off-white when I see them on TV.
• They won't be white if they have been swimming through an oil slick.  Or algae, or whatever.  So they are usually white.
• And so on...

Simon Barker said:

The obvious answer is "yes, of course it is".  But nobody actually wants to stick their neck out and say it.

Give or take the issues of correct overcurrent protection (according to the manufacturer's requirements), whether the socket-outlet is RCD protected, and whether the machine requires additional cpc arrangements because of high protective conductor currents.

Everyone is entitled to their opinion on whether those issues are important for safety ... but a court might not agree with your decision if someone is exposed to danger that could have easily been prevented for the want of checking, and, if necessary, fitting/upgrading when the machine is put into / returned to service.

gkenyon said:

Chris Pearson said:

So how long do we allow for a building to be upgraded?

Not the point, the issue is that a new machine is being connected up, so the question gets asked at that point, 'Do we fit an RCD now as required by the current version of BS 7671, or are there other mitigating measures in place that means it's safe so far as reasonably practicable'

With respect, I beg to differ. Surely the time to do the risk assessment is when the socket is installed? The assumption at that time ought to be that anything could be plugged in unless access is restricted.

The alternative is that whoever plugs in equipment must do a risk assessment, which wouldn't suit Mrs Mop with her floor buffer.

Perhaps the middle ground is when periodic I&T is undertaken? There is no reason why a factory owner should be aware of a change in BS 7671 until then. Of course, if the factory owner ignores the EICR, and injury arises, then he (or she) can fully expect a hard time from the victim's lawyers.

And this rather depends on the type of socket. The cleaner will not want a 32 A 5 pin socket for a floor polisher.  

A 13A socket and perhaps a 3 pin 16A CEEform single phase, "caravan plug",  the the assumption that almost anything may be plugged in is pretty good,

Less so for the socket that is on dedicated radial and is very clearly only intended for the adjacent large lump of 3 phase machinery that screws to the floor.

Enter the deviation ...

Mike.

Chris Pearson said:

With respect, I beg to differ. Surely the time to do the risk assessment is when the socket is installed?

Yes ... but that risk assessment might not be able to foresee use (or protection requirements) by a later machine ... AND the risk assessment should be reviewed when standards change.

In a workplace, we can't assume all socket-outlets are "general purpose".

Think about it ... this thread asks specifically about a piece of work equipment., in particular a machine.

Then have a look at Section 6 of the H&S@W etc Act, 1974, and the Provision and Use of Work Equipment Regulations, and the Supply of Machinery (Safety) Regulations ... I'm sure nowhere in that legislation says you can omit some of your responsibilities just because there's a socket-outlet that's convenient to use, without checking that socket-outlet has the relevant provisions in place (like the correct overcurrent protective device ratings, and RCD, as applicable)?

Yes, you could (unless the manufacturer requires one) risk assess that an RCD was not necessary (if you felt you could stick your neck out that far depending on what else is in place) ... but to simply say "go on, just connect it" without checking these things is surely irresponsible in a discussion forum on a professional engineering institution's web-site, given what the legislation actually says?.