I'm a little concerned about the focus on "why not the loft", given other "in plain sight" issues that the PAS highlights.

For example, it's not unusual at the moment to see a gG NH-type fuseholder, that can be simply pulled on-load, even by children, to be installed. Or monoblocs (sometimes simply placed on the floor) plugged together using the Amphenol-type "press and pull" battery terminals, again accessible to just anyone, including children or young people, to open on-load.

These practices are also non-conformant to PAS 63100, and affect systems not installed in lofts too.

I guess people are obsessing with lofts because it is going to prevent a lot of installations going forward on a cost basis. Personally I'm more bothered by the prohibiting of siting in basements that don't have access to the outside of a building (i mean what basements do? Oh of course the ones in America)
I was surprised that the issue of weight of batteries in lofts was not dealt with by enforcing a structure report similar to that required of solar panels on pitched roofs. I get the compartment issue but again theres a lot more lithium ion batteries in the US which is probably why they prefer locating the battery outside.

Also seems a little excessive to enforce LD2 level fire detection throughout the building if installing an inverter in the loft, or a battery in a permitted place indoors. I would have thought LD3 “plus” an additional linked detector where the ESS is sited would be adequate. 

All items that could be more realistically adopted and easily explained to the consumer.

Id prefer an evidence led cost benefit approach to managing risk. 

Im more worried about toddlers sticking usb leads in their mouths than i am with their ability to remove an Amphenol connector. You need strong hands for those. That said i take your point about being able to remove ‘on load’.

DA said:

i mean what basements do? Oh of course the ones in America

Basement flats in cities?

DA said:

Im more worried about toddlers sticking usb leads in their mouths than i am with their ability to remove an Amphenol connector. You need strong hands for those. That said i take your point about being able to remove ‘on load’.

It's not toddlers per-say, children covers up to age 18 at the moment. Equally relevant in this consideration, is that Intentionally causing an arc can be used to intentionally cause a fire, which is far less of a problem with most of our AC stuff ... but more problematic if you provide easy access to a source of DC arcs.

DA said:

Id prefer an evidence led cost benefit approach to managing risk. 

There's a huge issue with that. By definition, to get the evidence, we have to wait until things start going wrong, perhaps people losing their lives.

And then we are quick to say "we are always too late in the UK".

However, isn't there evidence in the fact that some insurance companies are starting to see increased risks in EV, Solar and Battery?

DA said:

Also seems a little excessive to enforce LD2 level fire detection throughout the building if installing an inverter in the loft, or a battery in a permitted place indoors. I would have thought LD3 “plus” an additional linked detector where the ESS is sited would be adequate. 

But this is already in BS 5839-6, as noted in the 2nd Edition of the IET CoP for EESS ... so it's already in standards, and nothing new!!!!

The system by definition can no longer be LD3 once you put the "additional detector" in there. You've added a "high risk room".

Why would a standard for fire protection of domestic battery storage installations not align with the provisions of the standard for domestic fire detection and fire alarm systems?

DA said:

i mean what basements do? Oh of course the ones in America

Basement flats in cities?

DA said:

Im more worried about toddlers sticking usb leads in their mouths than i am with their ability to remove an Amphenol connector. You need strong hands for those. That said i take your point about being able to remove ‘on load’.

It's not toddlers per-say, children covers up to age 18 at the moment. Equally relevant in this consideration, is that Intentionally causing an arc can be used to intentionally cause a fire, which is far less of a problem with most of our AC stuff ... but more problematic if you provide easy access to a source of DC arcs.

DA said:

Id prefer an evidence led cost benefit approach to managing risk. 

There's a huge issue with that. By definition, to get the evidence, we have to wait until things start going wrong, perhaps people losing their lives.

And then we are quick to say "we are always too late in the UK".

However, isn't there evidence in the fact that some insurance companies are starting to see increased risks in EV, Solar and Battery?

DA said:

Also seems a little excessive to enforce LD2 level fire detection throughout the building if installing an inverter in the loft, or a battery in a permitted place indoors. I would have thought LD3 “plus” an additional linked detector where the ESS is sited would be adequate. 

But this is already in BS 5839-6, as noted in the 2nd Edition of the IET CoP for EESS ... so it's already in standards, and nothing new!!!!

The system by definition can no longer be LD3 once you put the "additional detector" in there. You've added a "high risk room".

Why would a standard for fire protection of domestic battery storage installations not align with the provisions of the standard for domestic fire detection and fire alarm systems?

Well we can disagree that an evidence led approach to regulation is inherently wrong. Regulations can be devised responsibly without “what ifs”.

That said, i also want to be responsible in my installations and offer customers safety and value for money. I totally agree with the addition of a smoke detector for battery systems.

My point was (and i may have read it wrong) that the PAS document seems to suggest that an installer MUST upgrade or install to an LD2 system into the house as a result of the ESS. This was only ever a recommendation for existing LD3 or less in the COP 2nd edition for ESS.  

Insisting it has to be LD2, regardless of  normal processes for designation of fire categorisation means the designer now has to survey the whole house so as to comply with LD2. So a previous LD3 now needs detectors in the kitchen, utility room, any rooms with fires in etc. Not just an additional detector in the battery storage area.
I put “plus” in italics to suggest a LD3 “plus one”. 
Its semantics to say Ive created a high risk room and so it becomes LD2 automatically as the previous advice in the COP for LD3 or below was to strongly recommend installation to the customer. It made no assertion that by installing an ESS you are now defacto an LD2.
 
With regards to insurance companies. Sure of course they see increased risk. Its their business model.

I am disappointed in the restrictive direction the PAS has taken.

That said there are good bits to it eg the assemblies of monoblock and fusing. And non combustible housings. Hopefully it hasnt priced too many people out of the market.

DA said:

My point was (and i may have read it wrong) that the PAS document seems to suggest that an installer MUST upgrade or install to an LD2 system into the house as a result of the ESS. This was only ever a recommendation for existing LD3 or less in the COP 2nd edition for ESS.  

Does the installer have an option as soon as a detector is linked that is not associated with an LD3 system? It's no longer LD3, and is being "upgraded" or "enhanced", so over to BS 5839-6 ?

DA said:

With regards to insurance companies. Sure of course they see increased risk. Its their business model.

I was only referring to that in respect of evidence that didn't involve hurting or killing anyone, or anyone suffering undue loss.

DA said:

Hopefully it hasnt priced too many people out of the market.

It's difficult. In discussions on safety and legislation, it seems that the "Sword of Damocles" is being held over standards makers, safety professionals, etc., because "Climate Change is killing us all" is seen to trump the right to a safe place of work and working environment and practices that are enshrined in legislation.

There MUST be a better balance between innovation and safety.

I 100 % don't believe it's "if you want Renewables, it's this, take it or leave it" ... we are Engineers. In the Engineering Council Statement of Ethical Principles, to which I as a Registered Engineer am bound, respect for life, law and the public good are given equal status. More importantly, I don't want to drop Principle 3 ("accuracy and rigour") to try and elevate one part of Principle 2 over another. We have had some development in Renewables, but the Principles as a whole need to be balanced to provide the best solutions for society.

gkenyon said:

Does the installer have an option as soon as a detector is linked that is not associated with an LD3 system? It's no longer LD3, and is being "upgraded" or "enhanced", so over to BS 5839-6 ?

Yes, they have an option. A risk assessment covering the justification for the additionally sited detector within the LD3 category. It doesn't have to be LD2 because of the additional detector.

Categories are assigned based on physical properties of the dwelling, not on the existence of “high risk” appliances.

This is in line with the COP 2nd edition for ESS.

The PAS is different in that it insists on LD2.

Lets take for example a typical 20th century 2 storey owner occupied house that has an LD3 system installed as per current existing regs. If we are rewiring during a refurbishment it then it should be upgraded to LD2. It makes sense to upgrade to the current standard for new homes during these large scale works.

However if we are not doing large scale refurbishments then it is currently deemed unnecessary to upgrade. The PAS contradicts this rationale by directing an LD2 approach rather than a risk assessment approach as per BS5839-6. This is hard to justify to customers who don't want invasive works throughout their house.

Its not about the doing the right thing engineering wise, or succumbing to environmental pressures at the expense of safety. It’s about consistency of approach with standards.

Just to add Graham, I dont say any of this with a view to installing the “minimum standards”. 

DA said:

The PAS is different in that it insists on LD2.

I'm sure the PAS does NOT "insist" on it ...  LD2 is a "should" in a Note to clauses 6.5.6 and 7.2. In a specification type standard, notes are informative not normative, and should is a recommendation - you can declare conformity to PAS 63100 (Clauses 6.5.6 and 7.2) without an LD2 system ... the "shall" is conformity to BS 5839-6.

DA said:

The PAS contradicts this rationale by directing an LD2 approach rather than a risk assessment approach as per BS5839-6.

Again, the PAS does not "direct LD2". See above

DA said:

Just to add Graham, I dont say any of this with a view to installing the “minimum standards”. 

I can follow your explanation, but I have also heard the views of others that say the system is no longer LD3 when you put on the additional detector.

I openly admit to using 'minimum standard' as a very strong term, after the statements about "evidence-based" and "pricing out of the market" ...

However, as I've said in this post, there is no requirement ("shall") for a full upgrade to LD2 in order to conform to PAS 63100.

Coming back to "evidence-based", this is always a difficult issue in standardization. First, people expect standards makers (and Engineers) to take risks they know about into account. Unfortunately, some hazards suffer from poor "risk perception" (both ways - some things are "over-cooked" because people get a bee in their bonnet about a particular issue, some are "too lax" because a serious route to hazard, or use-case, was missed, that seems all too obvious once something has gone wrong.)

gkenyon said:

I'm sure the PAS does NOT "insist" on it ...  LD2 is a "should" in a Note to clauses 6.5.6 and 7.2. In a specification type standard, notes are informative not normative, and should is a recommendation - you can declare conformity to PAS 63100 (Clauses 6.5.6 and

I did say i may have read it wrong. So thank you for clearing it up. Im aware what “should” means on a normal day! 

gkenyon said:

I can follow your explanation, but I have also heard the views of others that say the system is no longer LD3 when you put on the additional detector.

Its not really my explanation. Its written in BS5839-6.

gkenyon said:

I openly admit to using 'minimum standard' as a very strong term, after the statements about "evidence-based" and "pricing out of the market" ...

I didnt think you had used the term minimum standard… until now. 

You have an engineering perspective and I have a cost benefit perspective. Both are equally recognised ways of development. I used the term ‘minimum standard’ to make you aware that im not approaching this issue from a “cheapest option is best”. Simply, that im aware that, given little evidence of issues with BMS operated LifePo4 batteries, this PAS standard will remove access to ESS for a portion of the market.

I understand its difficult to produce standards, and thank you for taking the time to respond to my questions.

David

No, I think I implied through the posts that some thing are indeed that, even if I didn't use the actual term. Apologies for the confusion.

DA said:

given little evidence of issues with BMS operated LifePo4 batteries, this PAS standard will remove access to ESS for a portion of the market.

The "not in the loft" issue (and ventilation etc.) applies equally to all battery chemistries. It's not just about the battery being a cause of fire, but also the potential for the battery to be a victim of fire.

DA said:

I understand its difficult to produce standards, and thank you for taking the time to respond to my questions.

It's a pleasure.

I don't make these things up all on my own, by the way! Experts come together, we list the issues and discuss them, and reach a consensus.

It is a similar process for the IET Code of Practice for Electrical Energy Storage Systems, the 3rd Edition of which I believe is due to start shipping next week: shop.theiet.org/code-of-practice-for-electrical-energy-storage-systems-3rd-edition