MyEnergi release statement implying that regulation134.1.1 supersedes regulation 722.531.3.101.


My energi released the following statement online www.myenergi.com/.../

While zappi features a built-in 30mA Type A RCD, given the complexity and changeability of wiring regulations and that zappi is sold in more than 20 international markets, we updated the manual accordingly in February 2021 to state that local wiring regulations should be consulted to confirm whether an additional RCD is also required.

Although our operation and installation manual has been clear since February 2021 that local wiring regulations should be consulted as to whether an upstream RCD is required, we have previously communicated that an external RCD was not required, because the internal RCD meets the safety and protection requirements within the relevant standard, and in some ways exceeds them, for example by automatically self-testing the internal RCD before each charge cycle, rather than relying on a user pressing a physical test button.

As section 134.1.1 of BS 7671 states that ‘The installation of electrical equipment shall take account of manufacturers’ instructions’, it is our view that any zappi installed according to our instructions and installation guidelines should be compliant with the regulations. Importantly, the zappi remains safe to use, even for installations without an additional RCD installed, provided it is installed in accordance with the manual.”

 What I find interesting is they still claim “the internal RCD meets the safety and protection requirements within the relevant standard” yet their RCD has no BSEN number recognised by regulation 722.531.3.101?

Discuss.

Parents
  • So, the manual was updated to recommend that users consult local wiring regulations ( In our case BS 7671) to assess whether an additional RCD is required. So does The absence of a recognized BSEN number means a non-compliance with BS 7671 ? Is this type of charger used where BS 7671 is not the prevailing wiring standard ? Confusing! But they then refer to BS 7671 stating  it complied with Reg 134.1.1 but like you said doesn’t comply with 722. So therefore, in my opinion it’s doesn’t comply ! 

Reply
  • So, the manual was updated to recommend that users consult local wiring regulations ( In our case BS 7671) to assess whether an additional RCD is required. So does The absence of a recognized BSEN number means a non-compliance with BS 7671 ? Is this type of charger used where BS 7671 is not the prevailing wiring standard ? Confusing! But they then refer to BS 7671 stating  it complied with Reg 134.1.1 but like you said doesn’t comply with 722. So therefore, in my opinion it’s doesn’t comply ! 

Children
  • So does The absence of a recognized BSEN number means a non-compliance with BS 7671 ?

    Not always ... Regulations 133.1.3 and 511.2 could be used, if the 'designer' is happy to provide the confirmation based on the manufacturer's declarations and instructions (and, perhaps as necessary , other information)?

    Further, legislation such as the Electrical Equipment (Safety) Regulations does not mandate standards are used ... a technical construction file can be compiled and referenced by the manufacturer on the Declaration of Conformity ...

  • Both 133.1.3 and 511.2 put the onus on the circuit designer not the manufacturer, this is also reliant on a declaration of conformity which as far as I can tell with regards to the RCD iin the UK s non existent. Would you not agree Mr Kenton?

    134 mentioned in the original post specifically applies to “erection and initial verification” and not selection of protective devices. 

    722 does apply to selection.

    all of this makes me wonder if the person writing the statement for MyEnergi entirely understands how to read BS7671 as an informative document?

  • Both 133.1.3 and 511.2 put the onus on the circuit designer not the manufacturer

    Yes, to satisfy themselves that the situation is no less safe than BS 7671. If the Designer is satisfied that the documentation provided by the manufacturer provides that assurance, the question simply becomes whether the Designer is able to rely on manufacturer's Declarations of Conformity that says they comply with relevant legislation such as the Electrical Equipment (Safety) Regulations.

    Since DofCs are legal documents provided in accordance with specific legislation - for example the Electrical Equipment (Safety) Regulations - we need to look at what the legislation itself says. If we were to agree that there are no relevant standards for RCD functionality provided by a product in the manner intended by the manufacturer, then Regulation 37 of the Electrical Equipment (Safety) Regulations might be appropriate:

    37(1) Where there are no designated standards, electrical equipment which complies with relevant international safety provisions is to be presumed to be in conformity with the principal elements of the safety objectives unless there are reasonable grounds for suspecting that the electrical equipment does not so comply.

    There is always 'buyer beware' (caveat emptor) situation ... so due diligence to verify whether there are "reasonable grounds for suspecting that the electrical equipment does not so comply" before you specify it.

    I make no comment about any individual specific product.