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.

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  • What astonishes me, is that we have HUGE debates over issues that have been "brought to our attention", yet ignore the fundamental requirements of BS 7671 in the general case.

    The requirement of 133.1.1 (and 511.1) is that all electrical equipment conforms to a relevant standard.

    That is anything you use, effectively ... including insulating tape, crimp connectors, ferrules etc.

    511.1 adds the additional requirement of not simply conforming to a standard of another country, but one that aligns with IEC requirements. This is for a very good reason, because, for  example, standards for USA and Canada are not aligned and require additional designer precautions to use in a BS 7671 installation.

    SO ...

    Do you check your insulating tape, ferrules, ring crimps, tiewraps, etc, are conformant to a standard?

    And if so, which ones?

    Do you keep records?

    Could any of the above be used against you if anything were to go wrong (overheating, say of an accessory that caused a house fire)?

    You see, when you sign the "certification" to say you conform to BS 7671, you are signing for all of the above ...

  • When considering personal liability in terms of compliance from tape to EV chargers…. In most cases we as the installer/designer rely on what you might call common sense, I know for example that if I go to my wholesalers or let’s say toolstation and ask for an RCD it is going to be BS7671 compliant in that it will be made to one of the previously mentioned standards. The onus is on them to sell products that conform to our standards, however I also know that it is my responsibility to choose say a type B over a type A from within those standards…. You simply don’t expect reputable suppliers to be stocking something that wouldn’t be compliant provided the designer chooses correctly within the standards according to the circuit design.

    Right now my local place which happens to be a Kew Electrical (shout out to them, they’re very helpful), has dozens of RCDs on the shelf, some sold separately others as part of a kit (say a pre loaded consumer unit). Out of all those RCDs there is only ONE in the entire place that does NOT have a BSEN number stamped on the side, and it’s the one inside the last Zappi charger they have in the place… That is very telling.

    Now why did they stock the Zappi in the first place? Because the MyEnergi rep let them believe that their product was fully compliant with BS7671 in terms of RCD protection (and other reasons to, such as PEN fault protection). Why did so many installers buy Zappis? Because in good faith they believed it was fully compliant with BS7671 in terms of RCD protection ect (actually if you went on the Zappi course, they directly told you that fitting an upfront RCD wasn’t just unnecessary, but that it may be non compliant with BS7671 as there would be no selectivity between the upfront and in product devices). And why has the last one sat there for ages and not been sold? Because installers talk to each other, we become mates at the wholesale counter, we help inform each other regarding RCD compliance. And now many of us voted with our feet and prefer to either purchase a charger that is compliant (as in you can see the RCD , you can push the test button, you can read BSEN 61008 stamped on the side) or you buy a cheaper charger and buy the RCD separately. Why? Because we recognise (unlike MyEnergi) the value in taking responsibility for what we sell to our clients, we want to do a good job, we want products that we know are fully compliant, we don’t want products that fall into a grey area forcing the manufacturer to release a confusing statement that may contradict itself to continue with a misinformation campaign that is designed to conceal the fact that the Zappi RCD actually failed to meet the 61008 standard yet was advertised as “fully compliant”. 

  • You simply don’t expect reputable suppliers to be stocking something that wouldn’t be compliant provided the designer chooses correctly within the standards according to the circuit design.

    I have to strongly disagree. I was able to purchase a product from a common industry supplier, that one would generally consider 'reputable', and available also from other suppliers that are considered 'reputable'. The product was from a brand one would normally consider 'reputable', and was declared to meet the relevant standard.

    Sadly, there was a mistake in product marking - in this case, the marking is required by a standard mandated for the product in legislation. Quite simply, the product did not conform to the standard, and therefore if one were to install the product, also therefore it would not conform to BS 7671.

    You would have thought marking was 'obvious' to see - it was large and clear enough to see without reading glasses - but I wonder how many have actually been installed and certification issued?

    I'm sure   could tell us how easy it can be for barristers to demonstrate lack of diligence on behalf of an installer, or possibly fraud if an EIC were issued declaring full conformity with BS 7671.

    Luckily, there were no apparent safety issues with the product ... although there was a second non-conformity with BS 7671 with some internal "pre-wiring" (that the manufacturer's instructions included a warning that these are provided for convenience and the installer is to check connections) - tinned conductors in screw terminals - that could be addressed by an installer quite easily of course, with some ferrules, but another trap for the unwary installer.

    Caveat emptor.

    ADDENDUM

    Before anyone asks, I will not name the product (or stockists of it) , because I don't think this meets the rules of conduct we sign up to when using this Forum. There is no need to name suppliers, or specific products, to illustrate my point. However, I do have evidence. I also think that contributors to this Forum, or indeed social media, ought to exercise caution when discussing products by name or designation.

  • you can push the test button,

    We need to be very careful at this point. BS EN 61008 does not require a "test button". It requires a "test device", and the 'means of instigation' of the 'test device' to be marked with 'T' - there is no mention of a physical 'button' I'm afraid. Having said that, guidance from some organizations has indicated that, with the the presence of a physical test button marked 'T', at least you know there is a 'test device'.

    There are different ways of interpreting what is written in BS EN 61008, and only a court can interpret a standard.

    failed to meet the 61008 standard yet was advertised as “fully compliant”.

    What does the Declaration of Conformity say? That is the legal declaration and that is what you need to refer to in terms of what is declared as 'compliant' ('conformant' is perhaps the correct word in the 'assurance' discipline of our profession).

Reply
  • you can push the test button,

    We need to be very careful at this point. BS EN 61008 does not require a "test button". It requires a "test device", and the 'means of instigation' of the 'test device' to be marked with 'T' - there is no mention of a physical 'button' I'm afraid. Having said that, guidance from some organizations has indicated that, with the the presence of a physical test button marked 'T', at least you know there is a 'test device'.

    There are different ways of interpreting what is written in BS EN 61008, and only a court can interpret a standard.

    failed to meet the 61008 standard yet was advertised as “fully compliant”.

    What does the Declaration of Conformity say? That is the legal declaration and that is what you need to refer to in terms of what is declared as 'compliant' ('conformant' is perhaps the correct word in the 'assurance' discipline of our profession).

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