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
  • I would happily sign an EIC with a Zappi at the end of a circuit without an upstream RCD, providing Zs was ok. MyEnergi is a UK success story with the Zappi being one of the best chargers on the market. If needs be stick it in the departures section and worry not one jot about it!

  • Even though they have this in their FAQs? https://www.myenergi.com/installers-centre/

    text from link copied and pasted bellow.

    Does the zappi require any RCD protection?

    zappi 2 has an A-Type RCD with 6mA DC leakage protection built in, however it’s important to check the local wiring regulations to confirm what is required. For instance, in the UK, the Wiring Regulations still require a separate 30mA Type A RCD to BS EN 61008 or BS EN 61009 to be installed upstream of each EV charge point.”

  • A recommendation to install a type A is OK, it would be the installation of  an upstream type B that requires an overdraft !
    Mike

  • A While ago a priced to install a ROLEC 22kW charger installation, it was marketed as having built-in RCD protection, Open PEN protection etc. However, upon closer examination and a conversation with the manufacturer, it became evident that an RCD upstream was necessary. This came as a surprise to the wholesalers selling the product.

  • 722 lists all the BS EN standards for the equipment to be installed. For example the RCDs required. Both BS EN 61008 and 61009 to have a used test device marked with a "T". If it has not got one then that is as an indication that the RCD protection fitted does not comply with those standards. Of course you can fit one of these non-compliance devices as a Departure as GK says above. But you have to take on the liability declaring it is no less safe than an approved device. Why an earth would you take on that liability when you can buy equipment that complies with all the standards required by 722 and other BS 7671 requirements? Also you might want to ask your Professional Indemnity insurers if they will indemnify you in the event of a claim.  

    JP

  • Thanks John. Despite my awareness of regulatory requirements, I inadvertently omitted the inclusion of a RCD in my initial pricing. Upon unboxing the product, I noticed the absence of a test button, which prompted further inquiries. Consequently, I installed the RCD adjacent to the distribution board. While I acknowledge my oversight, it’s worth noting that the product had been marketed to me as fully compliant.

  • Depending upon the installation method, the circuit might need RCD protection anyway.

    I assume that this would be a 3-phase installation, so is Open PEN compulsory?

  • And that is what this is all about. Products being marketed in a way that makes you believe it’s fully compliant when perhaps they could be a bit more up front about technicalities so that the installer/designer can make an objective and informed decision at point of purchase.

  • Pen fault devices as far as I’m aware are needed for any installation likely to be connected to PME, so TNCS and almost certainly TNS, the vast majority of chargers have PEN fault protection. The RCD issue aside, I think the Zappi has some of the best PEN fault protection on the market.

  • The big question here would be, if following an incident could the installer/designer argue that they bought the product in good faith believing the RCD protection was sufficient? The problem of liability isn’t an issue until the unexpected and unfortunate happens.

  • Pen fault devices as far as I’m aware are needed for any installation likely to be connected to PME,

    That's one way of conforming to BS 7671 ... there are others.

    the vast majority of chargers have PEN fault protectio

    BS 7671 doesn't recognize PEN fault protection for TT installations ... in fact, with some designs out there at the moment, it is detrimental to the user because the charging point is less reliable (given that open-PEN touch-voltages arguably cannot occur on true TT).

Reply
  • Pen fault devices as far as I’m aware are needed for any installation likely to be connected to PME,

    That's one way of conforming to BS 7671 ... there are others.

    the vast majority of chargers have PEN fault protectio

    BS 7671 doesn't recognize PEN fault protection for TT installations ... in fact, with some designs out there at the moment, it is detrimental to the user because the charging point is less reliable (given that open-PEN touch-voltages arguably cannot occur on true TT).

Children
  • Agreed, you simply shouldn’t need a PEN fault device on a true TT system, I’ve heard some interesting discussions along the lines of, “what if the next door neighbour has TNCS and all bonding is in place, does that effectively mean PME conditions apply? There’s TT for that farm house on the hill and there’s TT for that terraced house in town… In the latter example you would hope that under PEN fault conditions the Installation earth rod would do what it needs to. In practice it was inappropriate for our DNOs to allow a hodgepodge of different earthing systems going in from one building to the next, less of a problem in past times but increasingly a concern now that we all want a tonne of metal on our driveway connected to the PME network! Yet if you contact the DNO and call in a Zs of over 0.35Ω and they often advise the installation of an earth electrode without considering it’s close proximity to other earthing arrangements on the street…. No surprise we are slowly heading towards more and more TNCS arrangements having a supplementary earth rod installed, currently it’s advisable in BS7671, will it evolve over time to be compulsory? I think it may.