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”. 

Martyn said:

If a manufacturer supplies a complete solution, PCE, battery storage, all functional equipment monitoring and management as a ‘certified’ product, does BS7671 care or apply to the internals of said product? 

Just thinking more on this, and the parallel comments on LD2/LD3

Let’s assume such a product is installed outside (including 120minute separated spaces)  or in a detached building. 

Presumably, not being part of an escape route, space connected to, or close to (1m) of an escape route FD could be omitted?

In such cases would the likes of the Google Nest Protect be acceptable as a means of detection with the addition of a something like the tubes from EnviroBurst ? 

Thanks 

Martyn

Martyn said:

tubes from EnviroBurst

They would need to make something quite meaty or special to put out a fire for a battery.(house battery)  Litho battery burn like a firework even under water.  I have seen the tubes from EnviroBurst in CU/DB and they seem to work in the basic tests that people have tried.  A similar concept to putting out a fire on an oil well head. 

There are limits to what we can do with Lithium fires as has been seen from the various fires across social media and the news.

That said if we install in sealed metal cabinets and deplete oxygen on detection with something like the EnviroBurst we can limit the spread to vulnerable areas.   

I like your thinking Martyn.  Battery makers like Sun Sync need to look at their products and make them safer.  Not just for the UK market but for the global market.  Maybe they could have an indoor version and an outdoor version.  The indoor version would have more fire suppression and would cost slightly more and the outdoor version being the cheaper of the 2.  This would then cater for 2 market types.  eg small 2 bed terrace house or flat with no real outdoor space it could use.
Then the people with large dwellings or more abundance of space.  eg a large home in the suburbs.  Could use the cheaper outdoor version.

I have no affiliation for or against Sun Sync.  They were just the first name that popped into my head.  Other battery brands are available.

One thing that a PAS does is establish "best practice" - and failure to comply with it (not retrospectively) can be used against an installer / designer / manufacturer if a case is taken to court.

Hi Graham,

Without wanting to interrogate the author...

The PAS document requires all indoor locations which contain storage batteries to be ventilated to outdoors (6.5.4) and refers to BS EN IEC 62485 for further information. This does not account for various battery compositions - particularly lithium iron phosphate. There is no direct reference to a baseline ventilation rate (62485 has a calc but it's based on older battery chemestry).

Presumably we can take a sensible approach here and follow battery manufacturer's guidance/recommendations with regard to the provision and rate of ventilation?

Regards,

Peter

And if you're aiming for PassivHaus (or even generally good thermal performance), you need air tightness, so the last thing you want is uncontrolled holes in the walls.

Caravans etc have had this problem for while (most incorporate "leisure batteries") - solutions vary from a compartment only accessible from outside to a interior box with a small plastic tube to outdoors (I've no idea how effective that might be in practice). Usually lead acid, so Hydrogen is reasonably likely.

   - Andy.