If these are part of Machinery as defined in the Supply of Machinery (Safety) Regulations, then this his a moot point, because the standard is BS EN 60204-1 not BS 7671 ... and this applies to all of the control wiring and power out to the motors. BS 7671 stops at the incoming mains supply to the Machinery. Test parameters may well be different - for example on the protective bonding circuit continuity is a different test entirely to the continuity of protective conductors test in BS 7671.

More to the point, the manufacturer's recommendations apply.

The duty holder should have the relevant information to maintain the Machinery under the relevant legislation (including PUWER and Section 6 of the H&S@Wetc Act.

HVAC is 'Machinery' as defined (this was clarified a number of years ago), but can also apply to other motors if they are doing something that comes under the definition of 'machinery'.

The extent of 'Machinery' includes the controls as well as the parts actually performing the process or movement.

Auryn Morgan said:

Some consultants are suggesting otherwise which on the face of it doe not appear a reasonable approach.... they are even suggesting that the control wiring is a requirement. 

If it is determined that the control wiring comes under BS 7671, this is absolutely the case, they are either LV, FELV, SELV or PELV circuits and ought to be tested accordingly ...

Just to add to this, the reference in BS7671 is 110.2 (xi) which excludes machines covered by BS EN 60204.

And the scope for BS EN 60204 states;

"This part of IEC 60204 applies to electrical, electronic and programmable electronic
equipment and systems to machines not portable by hand while working, including a group of
machines working together in a co-ordinated manner"

"The equipment covered by this part of IEC 60204 commences at the point of connection of the
supply to the electrical equipment of the machine"

"This part of IEC 60204 is applicable to the electrical equipment or parts of the electrical
equipment that operate with nominal supply voltages not exceeding 1 000 V for alternating
current (AC) and not exceeding 1 500 V for direct current (DC), and with nominal supply
frequencies not exceeding 200 Hz"

Then again from the point of view of the Electricity at Work Regulations "All systems shall at all times be of such construction as to prevent, so far as is reasonably practicable, danger." - so if something is excluded from an EICR it'll need to be included in something else (e.g. PAT in old school parlance). What constitutes a reasonable approach in the circumstances is of course debatable, but the answer to that may well be pretty similar whether it was done under an EICR, In-service Inspection and Testing of Electrical Equipment, or something else of the Duty holder's invention.

   - Andy.

AJJewsbury said:

What constitutes a reasonable approach in the circumstances is of course debatable, but the answer to that may well be pretty similar whether it was done under an EICR, In-service Inspection and Testing of Electrical Equipment, or something else of the Duty holder's invention.

Agreed, although specifically the reason I pointed to BS EN IEC 60204-1 and manufacturer's instructions, is that there is (in the standard at least) an onus on the manufacturer to provide recommended procedures (and periods) for functional testing and maintenance activities.

In this recent installation on a dairy farm, the electrical contractor left isolators for connection of motors and control equipment by a specialist milking parlour contractor. The photo shows only a small part of a fairly extensive system. An EIC was required as part of an application for a sizeable government grant. The electrical contractor duly provided this but only up to the isolation points. Not one stick of certification was provided for the installation on the other side of same. 
Seems to be a very common situation throughout all types of industrial installations. 

Not one stick of certification was provided for the installation on the other side

It's not just in commercial/industrial situations - typically the same happens in domestics for central heating systems (which getting far more extensive these days with per-room zoning etc) - it seems to fall under the heading of "too hard" for the typical electrician and "dunno about electrical testing" for the plumber.

  - Andy.

lyledunn said:

The electrical contractor duly provided this but only up to the isolation points. Not one stick of certification was provided for the installation on the other side of same. 

For an EIC to BS 7671 I think  that is correct.

However, there ought to be evidence, as required by BS EN IEC 60204-1, for installation and commissioning tests of the machinery according to manufacturer's instructions. This may include tests for the protective bonding circuit, and insulation resistance, on-site.

It's the duty holder's responsibility to make sure the machinery installer provides this.

Neither of the above removes the requirements under PUWER and EAWR for the duty holder to ensure adequate provision during installation, and, maintenance to prevent danger. This would, I think we'd all agree, and certainly supported by industry standards and guidance, include suitable electrical tests for at least continuity of protective conductors ("protective bonding circuit" according to some standards) and some form of insulation resistance test, as well as a thorough inspection.

As we have seen in recent cases, in the UK, if anything goes wrong and sadly someone receives an electric shock, particularly if it's fatal, the relevant public prosecuting authority, supported by HSE/HSE(NI), would have little hesitation in prosecuting any and all concerned where deficiencies are evidenced (initial installer of the Machinery, the manufacturer of the Machinery, the company responsible for the premises in which the Machinery is installed, and maintainers of the Machinery).

Absence of records such as lyledunn  has provided examples of, would be seen as grounds for suspicion of one or more (criminal) safety offences, particularly if an Expert could pinpoint deficiencies that testing could have highlighted, and thus been rectified preventing the incident.

Afternoon All,

Agree with what lyledunn says and also Graham, I have come across countless properties, industrial, commercial where 99.9% of electricians and electrical contractors will only carry out an EIC or EICR from the distribution boards to the final accessory or isolator. Doing "PAT" testing as we all know doesnt and didnt help as many including Duty Holders felt that only applied to things with a plug top on. The In Service C.O.P certainly in my mind clears that up. So from the isolator to a control panel, the internal wiring and everything from that panel needs inspected and tested by someone at a regular interval. Obviously manufacturers guidance takes preference,  but also is that HVAC or MCC classed under the machinery directive or A.N.Other standard in some ways doesnt matter, its electrical with conductors and electrical parts.

My understanding and reading of Reg 4(2) of the EAWR 1989 indicates that " As may be necessary to prevent danger, all systems shall be maintained so as to prevent, so far as is reasonably practicable, such danger". Of course the word "Maintenance" in a legal context means a regular period of test and inspection.

The "Duty Holder" as such if a person receives an electrical shock or there is a accident, fire etc from the MCC, HVAC ,Refridgeration panel or parts therein or supplied from those enclosures, then the question posed to the "Duty Holder" will be to prove that things had been maintained in a satisfactory condition.

I guess from a legal perspective you cant have something that falls into "No Mans (Or any other gender!) land".

So Duty Holder and/or their appointed agent needs to make sure everything is covered, so could be an electrical contractor does indeed cover from the utility meter to all D/B's and final circuit wiring, accessories and isolators. But the fire alarm company does the internal wiring/parts of the fire alarm panel and all connected circuits and accessories. The HVAC and Refridgeration company does everything from the point of connection (Outgoing Isolator cable) and everything within their panel and all wiring from that and items of equipment/control/measure connected to that wiring. DATA or IT company does the power racks and comms cabinets etc. I appreacaite manufacturer of certain enclosures and panels may be the manufacturer and/or their appointed agent does certain panels and MCC's. A lift company I would hope does all the lift wiring and control panels etc 

The paperwork issue should clearly demonstrate who the entity was that issued the paperwork, the name/s of the inspector/tester, their quals/competency and what it is that that inspection/test report actually covers and any items of deficciency and time to next inspection.

Personally Majority of Duty Holders dont understand their responsbilities and thing the electrical contractor/electrician covers everything, we know they dont.

I walk round a premises point out everything "Electrical" to the Duty Holder and would expect to be given an inspection report for it. If they cant, to me there is a weakness, it just cant fall between a crack in the floorboards somebody needs to regularly inspect it.

Based on probability what is more likley to cause an electrical shock, fire or incident an electrical installation and/or piece of equipment that is regularly "Maintained" and one that isnt??

Another anology is we all "Maintain" our cars according to manufacturers guideleines, so what car is more likley to have bald tyre, worn breaks, lights not working or even the engine seizing? the car that has been maintained or the car that is simply driven every day?

Projects are handed over and CDM says that details must be provided to the Duty Holder to explain how they look after and maintian what they have just purchased, reality is nobody really does things the way regs, C.O.Ps and guidance have been written.

GTB