Requirements for RCD protection on a 32a Socket supplying Mobile Equipment

I have been presented an EICR with a code 2 referencing Regulation 411.3.3, no 30mA RCD protection for socket outlets under 32amp. The 32a socket has a 100mA Time Delay RCD fitted, as it's being used to supply a local DB within a cabin. My initial thoughts were this was satisfactory and shouldn't have been coded a C2 due to the requirement for discrimination between the RCD's to avoid nuisance tripping, now I am not so sure. 

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  • C2 is the guidance from Electrical Safety First's BPG4: https://www.electricalsafetyfirst.org.uk/media/2149/bpg4-1.pdf 

    See page 16, 4th item down.

    Why was the 32-amp socket installed and why is it being used to supply the cabin, instead of the cabin supply being hard wired?

    What type of premises is it installed at and how are the premises and the cabin used?

    Good question, but if it was designed as a mobile & Transportable unit ... a number have a BS EN IEC 60309 series appliance inlet fitted to them.

    I might be misreading it but it seems to say an RCD can be ommitted with a documented risk assessment in this sort of situation.

    Not according to Regulation 411.3.3, this is item (iii) usage, and the risk assessment exception applies only to (ii).

    Perhaps if those trotting out code 2’s were asked to fully explain the potential danger, there would be less of them issued. Blind code hugging must be a significant burden to British industry!

    Yes, although if it's a metal-framed or container-type mobile/transportable unit, I wouldn't be happy without RCD protection, given the risks of rodent damage. That said, as   pointed out, would a different selection of cable/connection type be more appropriate, particularly if the cabin is going to be there long-term ... especially considering this case: www.independent.co.uk/.../turney-sue-logan-fire-calder-vale-b2843032.html

  • "which investigators said could have been caused either by a carelessly discarded cigarette end or an electrical fault relating to wiring leading to a freezer"

    So, £350k for a possibility?

    Whilst it was not done properly, where is the proof that this caused the fire? Could it not also have been a fault in the freezer itself?

    Never happy to see poor installation, but also not happy to see people convicted by "it might have been".

  • Never happy to see poor installation, but also not happy to see people convicted by "it might have been".

    Not a conviction, but essentially a dispute between the neighbours' insurers as to who should pay for the loss to the neighbouring property. So, balance of probabilities applies.

    I am unimpressed by the judge's reasoning as to the standard of care required by an ordinary householder: §§ 112 - 122. He refers to Part P at § 120 and BS 7671 at § 121, but clearly an extension lead is not part of the installation, so out of scope of both.

    The reasoning appears to be that the defendants were negligent because they failed to call in an electrician either to install a permananet circuit, or inspect the DIY arrangement.

    There must be plenty of similar lash-ups around the country and this one had lasted 13 years, which must have seemed reassuring to the householder. There is, however, no mention of an EICR during that period.

    Judgement available here.

  • would a different selection of cable/connection type be more appropriate, particularly if the cabin is going to be there long-term ... especially considering this case

    Not quite sure how that case is relevant to this discussion.

  • Connecting a 'long-term' unit to an installation via a flexible cable might be considered 'less suitable' than, say, an SWA alternative.

    The case cited makes it plain that a flexible cable might not always be considered suitable. The rodents didn't know whether the cable was 'posted through a drilled hole' or were 'connected to an outdoor socket-outlet' ?

    Although, I also accept that the rodents wouldn't know the difference between the cable going from the house to the shed, vs the flexible cable between the socket-outlet of the 'extension lead' in the shed vs the flexible cable between socket-outlet in the shed and the fridge-freezer for a more 'permanent' installation !

    Which is one of the reasons I brought this case up in this thread ... it has, potentially, far-reaching connotations if considered alongside guidance for EV installations adjacent to 'combustible materials' as cited in RC59 (if one wanted to make that parallel) ?

  • This caught my attention too: "...effectively destroyed by the fire, which investigators said could have been caused either by a carelessly discarded cigarette end or an electrical fault relating to wiring leading to a freezer in one of the couple's garden sheds..."

    'could'   but also ,   which was it -  a cigarette or an electrical fault ... the investigators didn’t know but the judge did.   Perhaps I missed the clarification somewhere, or is it a poor journalist report.

  • 'could'   but also ,   which was it -  a cigarette or an electrical fault ... the investigators didn’t know but the judge did.   Perhaps I missed the clarification somewhere, or is it a poor journalist report.

    I think this excerpt explains the decision: 

    He added that an expert assessing the evidence had found that “the simplest and most straightforward explanation for the fire is that it resulted from an electrical fault on the extension lead’s cable” and that “taking the evidence as a whole … a defect on the electrical cable, arising from it not being of a suitable standard for the purpose to which it was put, provides the most likely accidental cause of the fire”.

       might be able to comment from a better position of understanding, but I believe that two principles would be used in a non-criminal case like this:

    1. Burden of proof is the 'balance of probabilities' rather than the more onerous 'beyond reasonable doubt' required for a criminal case; and
    2. The principle of Occam's razor (basically, the simplest explanation is most likely to be true) being applied to competing hypotheses.
  • It appears that the judge chose to find that the extension lead was in fact part of the "installation", rather than an appliance or plug-in accessory.  From the judgement, it appears that this decision was made at least partially on the permanence of the arrangement.  It is unclear whether the fact that the extension lead was permanently attached to the installation (plug removed, cable fed through hole, plug reattached) played a part in that thinking - the judgement suggests that it did not.

    Even if the extension was not part of the "installation" then it appears that the judge feels that standard flex is not suitable for use where rodents may be present and that householders ought to know this (to the point where they incur legal liability by not knowing).

    If this was a precedent setting court then manufacturers of appliances would be updating their manuals with big warnings that they are unsuitable for use where rodents may be present.

    The judgement certainly should be a reminder that just because something is not part of the installation as electricians might see it, you may still be expected to comply with the regulations when plugging stuff in on the basis that either (a) your plugged in arrangement is "permanent" and therefore in fact is part of the "installation" and/or (b) the regulations are common sense which everyone should possess.

    I suspect the judge has erred in his assessment of what knowledge can be expected of the general public but I don't know whether that error would affect the outcome of the case - the fact (as decided by the judge) remains that the extension lead burnt down the neighbour's house.

  • Replacing the connector arrangement with a hard wired arrangement in SWA whilst retaining the 100mA RCB might be the most appropriate compliant solution.

    An alternative way to achieve compliance would be to uprate the supply to 40A or larger (assuming the cable and downstream DB can accommodate it) and replace the 32A connector with a 63A connector (labelling the connector as only to be used to supply the portable building to reduce the risk that someone might plug in a 63A appliance causing overload).  Not sure that is in the "spirit" of the regulations though!

    If a socket is really needed and regulations compliance is absolutely required then the above might a solution but I'd look at using a cable with an earthed screen to increase the likelihood that cable damage would be more likely to be quickly detected (and of course retain the 100mA RCD).

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  • Replacing the connector arrangement with a hard wired arrangement in SWA whilst retaining the 100mA RCB might be the most appropriate compliant solution.

    An alternative way to achieve compliance would be to uprate the supply to 40A or larger (assuming the cable and downstream DB can accommodate it) and replace the 32A connector with a 63A connector (labelling the connector as only to be used to supply the portable building to reduce the risk that someone might plug in a 63A appliance causing overload).  Not sure that is in the "spirit" of the regulations though!

    If a socket is really needed and regulations compliance is absolutely required then the above might a solution but I'd look at using a cable with an earthed screen to increase the likelihood that cable damage would be more likely to be quickly detected (and of course retain the 100mA RCD).

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