Hi guys does anybody please have a template risk assessment for the omission of RCD protection? Or does anyone know where I may locate one? Many thanks in advance.
- Thread starter SparkyAndGeorge
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- assessment rcd risk
I boy George will not install a RCD cause you do not needed it if you need one call me .
so tell us in one word that one is not required ,on a stamp to co, the electrical forum @ the worlds end ,earth.
There may be one at one of the electric design companies but there is nothing on here that I could find.
I Suggest you use a simply 5x5 matrix table. You need to specify the relevant Clause No. of BS7671, and state why there is a necessity to depart from the requirement.
Then list the various hazards that an RCD would address and compare how your proposal ensures that you reach the same level of safety or better.
I did start to make one of these up in response to a recent discussion on here but I suffered an stupid accident at home and tore the ligaments in my knee and have been out of work and in pain since, and to be honest I have not felt like doing the RA.
If you like I can send you some worked examples but they will not deal with that subject but will give you an idea. Email me if you want me to send you anything.
me too, next to me knee cap.
boy hit F/HURTS .
T
The Ghost
As I understand the regs omission RA requires a template from HSE as it is governed by S.I. 19 (off the top of my head would have to look!) and must comply with HSE requirements. This is not a common or garden RA.
Let the client do it they are best placed. If someone was to get hurt or killed and the lack of additional rcd protection contributed to it your risk assessment could be used in a court of law with you justifying it.
T
The Ghost
Actually I think that has been removed in the 18th and replaced with appendix 2 item 11 re INDG163 on HSE site
Those sites are relevant to employees and public risk. The RA to be done here is a CDM designers risk assessment.
Under the EAWR the client cannot do this unless they are suitably competent to understand and identify the risk and propose the remedial action.
In this case the OP is proposing a departure from BS7671 which is permitted as the OP would be deemed to be a competent designer, however a suitable RA needs to be done and attached to the documentation in accordance with BS7671.
Under the EAWR the client cannot do this unless they are suitably competent to understand and identify the risk and propose the remedial action.
In this case the OP is proposing a departure from BS7671 which is permitted as the OP would be deemed to be a competent designer, however a suitable RA needs to be done and attached to the documentation in accordance with BS7671.
If the OP undertakes a RA stating additional rcd protection has been omitted then he needs to satisfy the installation is no less safer than if it was provided. It is likely to be a clear departure from BS7671 and I have no idea why someone would leave themselves wide open by doing so.
N
Nigel
It is not leaving anyone wide open if done competently. We regularly RA out the requirement for RCD protection and I will happily stand in court and back it.
I, and many others, in the telecoms sector are having big issues with this at the moment.
Our customers don't want RCD protection on their equipment due to the risk of nuisance tripping and the loss of service to their customers. Not a massive problem to knock of 250,000 internet subscribers in one hit however as a lot of networks are now IP based there is a risk that blue light services could be effected at a critical moment.
It has been suggested that we connect their equipment using hard-wiring however they wish to retain the functionality of socket-outlets as you can send a poorly paid FLM engineer to swap a piece of faulty kit rather than a sparky, it all boils down to cost and ease.
Now these socket-outlets aren't just commando sockets under the floor or high level mounted ones, the requirement for additional protection also applies to any power rails, C13, C19 etc, that my also be installed.
It's a massive can of worms and we're currently losing a lot of work as no one is willing to do the risk assessment.
Removing one line has create a massive headache for us, we used to be able to use the following up until the introduction of the 18th:
(b) for a specific labelled or otherwise suitably identified socket-outlet provided for connection of a particular item of equipment.
These are circuits in secure switch rooms with heavily restricted access, no chance of Doris plugging in her curling tongs or lawn mower, these circuits are for dedicated racks that will be there for the next twenty years.
W
Wilko
AFAIK where RCD has worked no deaths have been recorded and this gives me pause for thought on RA, just saying.
N
Nigel
Why don’t you guys just do the RA? On one hand you have the risk of loosing 999 service coverage for maybe millions of people or the other the ever so slight, if any risk of a contractor being electrocuted?
I would look at possibly installing T Earth sockets with labels on stating these sockets are for ‘x’ equipment only. Maybe even possibly putting a general use socket adjacent, again suitably labelled saying this is for general use and is RCD protected.
To me it is really quite simple or am I missing something????
It boils down to our customers stating they don’t want RCD protection but not willing to state that in a documented risk assessment. If we installed RCD protection then technically we’re in breach of contract and liable for any outage costs and fines that can run into the hundreds of thousands per hour.
N
Nigel
But surely as the competent people (electrically) only you can do the RA. It needs to have some technical back-up to it and cannot just be at the client’s request but in this instance I can see it being quite simple to RA RCD protection off certain sockets.
This has come from the customers various design and engineering departments, they’re classed as electrically skilled and normal carry out the circuit designs yet expect us to raise and sign the RA. Peeing into the wind is the norm in telecoms.
There is another way.
Why not get the Customer to instruct - "confirm" - in writing that they wish RCDs to be excluded for operational purposes.
Your Company then produces a RA that demonstrates that there is no danger created as a result of excluding the RCD. They submit the RA to the client stating that "...in accordance with your Instructions, and in compliance with the requirements of BS7671, we have produced the relevant risk assessment to remove the use of RCDs in the locations/circuits identified by you. Please let us know within xx days, (whatever), if you do not agree with the risk assessment, otherwise we will proceed along as Instructed by you...."
All that the law requires is that :-
* the risk assessment has been carried out using personnel who are competent and aware of the hazards and risks ;
* that the risk associated with the hazards have been assessed against the existing BS7671 requirements and that where necessary suitable and sufficient control measures have been put in place that achieve the same or a better level of safety, and ;
*that the risk assessment has been documented
You have now complied with BS671 in respect of departures from the requirements in proving that this request has not resulted in a reduction in safety.
Remember HSE are NOT looking to second-guess the RA, they want to see that the issue has been recognised and appropriate measures taken. There is no legal requirement to be 100% correct in a risk assessment and HSE would not take enforcement action in the event that a genuine error had occurred - as long as you have followed the principles.
Why not get the Customer to instruct - "confirm" - in writing that they wish RCDs to be excluded for operational purposes.
Your Company then produces a RA that demonstrates that there is no danger created as a result of excluding the RCD. They submit the RA to the client stating that "...in accordance with your Instructions, and in compliance with the requirements of BS7671, we have produced the relevant risk assessment to remove the use of RCDs in the locations/circuits identified by you. Please let us know within xx days, (whatever), if you do not agree with the risk assessment, otherwise we will proceed along as Instructed by you...."
All that the law requires is that :-
* the risk assessment has been carried out using personnel who are competent and aware of the hazards and risks ;
* that the risk associated with the hazards have been assessed against the existing BS7671 requirements and that where necessary suitable and sufficient control measures have been put in place that achieve the same or a better level of safety, and ;
*that the risk assessment has been documented
You have now complied with BS671 in respect of departures from the requirements in proving that this request has not resulted in a reduction in safety.
Remember HSE are NOT looking to second-guess the RA, they want to see that the issue has been recognised and appropriate measures taken. There is no legal requirement to be 100% correct in a risk assessment and HSE would not take enforcement action in the event that a genuine error had occurred - as long as you have followed the principles.
I am currently having discussions with a client about a similar matter.
they have several pieces of equipment that are often moved about a factory floor to different machines or locations.
most positions that they would like to plug the equipment in are close to an outside door, most are near large tanks of water, water on the floor is a likely hazard.
equipment involved is mostly single phase but some 3 phase, inverter drives and servo drives in a lot of them.
what they are finding is that the rcd's are tripping when being used.
so customer asks me, can you put in some sockets that are not rcd protected for the equipment we move about?
I say no, it cant be done unless sockets are over 32A, or a documented risk assement is done.
can you do a risk asses for me?
I say, I can but you wont like the result.
they are quite pragmatic about it, end of the day they need to move stuff around to manufacture what they make.
Is the simple answer to provide 32A sockets all over the shop floor to power these pieces of equipment and as such remove the rcd requirement?
p.s. they are probabley 6A single phase or 3A 3 phase requirements.
I understand that the supply cable from plug to machine will need to be made bigger and may well need some over current protection adding to the machine.
they have several pieces of equipment that are often moved about a factory floor to different machines or locations.
most positions that they would like to plug the equipment in are close to an outside door, most are near large tanks of water, water on the floor is a likely hazard.
equipment involved is mostly single phase but some 3 phase, inverter drives and servo drives in a lot of them.
what they are finding is that the rcd's are tripping when being used.
so customer asks me, can you put in some sockets that are not rcd protected for the equipment we move about?
I say no, it cant be done unless sockets are over 32A, or a documented risk assement is done.
can you do a risk asses for me?
I say, I can but you wont like the result.
they are quite pragmatic about it, end of the day they need to move stuff around to manufacture what they make.
Is the simple answer to provide 32A sockets all over the shop floor to power these pieces of equipment and as such remove the rcd requirement?
p.s. they are probabley 6A single phase or 3A 3 phase requirements.
I understand that the supply cable from plug to machine will need to be made bigger and may well need some over current protection adding to the machine.
The risk assessment isn't to decide whether additional rcd protection is or isn't required but to justify its omission.
Why not a 32A plug with an in-line FCU?
But yes, the whole thing is a bit stupid. There are many cases when non-RCD sockets are needed or desirable and in locations where the risk is managed, having them labled ought to be the first step even if it is backed up by a risk assesment justifying why the are omitted and what steps (training, lables, extra bonding, shorter PAT testing times, etc) are in place to help mitigate the risk.
This was actually the reason I bought Codebreakers, Part 2 explains the process of risk assessing omission of RCD’s and gives some useful examples of the things to look for as well as a model form for this particular RA.
It’s not a complete example, but it gives a step for a hint in terms of likelihood and severity and the options the client has depending on the level of risk.
Looks like I need to get a copy of the latest Codebreakers then!
In terms of 32A plugs and equipment not needing that much you can get stuff like this:
https://www.essentialsupplies.co.uk/power/adaptors/32a-adaptors/twin-13a-socket-32a-in.html
In terms of 32A plugs and equipment not needing that much you can get stuff like this:
https://www.essentialsupplies.co.uk/power/adaptors/32a-adaptors/twin-13a-socket-32a-in.html
W
Wilko
I would want to understand this aspect too. Is it normal for the 6A machine to have 30mA of leakage? Or is it that there’s several m/c on one circuit?
IIRC the PowersThatBe are looking to remove the RA exception from 18 Amd 2.
Vortigern
Arms
Maybe a monitoring device to detect what an RCD detects which then signals a relay alarm in the absence of RCD so that if there is the kind of fault the RCD would have detected then there would be an alarm/notification to key workers. i.e. mobile phone alert/audible alarm etc. Not so fantastic as Schneider do such a module that fits onto an existing MCB.
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If you're omitting RCD protection, use sockets that are not standard 1363 ones, some come with a T shape pin, that way only modified equipment can be used, any attempt to circumvent this then puts the onus on the modifier (modifee?) and not the spark as they took methods to ensure a degree of protection (using nonstandard sockets/plugs)
Look up the definition of a socket-outlet in the regulations, sadly you can't use this method to get around the problem.
Non-standard plugs & sockets have some uses, e.g. to prevent arbitrary stuff being plugged in to protected supplies in hospitals, etc, but otherwise are a pain as they make testing stuff or using it in other locations a problem.
Sometime it seem BS/IET have their heads up there rears when it comes to issues like this. There are plenty of cases when a plug & socket is far more usable for high leakage current or critical equipment than having them hard-wired, so the apparent plan to drop the exemption completely seems crazy.
A perfect example is a data centre where is you have UPS with 16A or 32A commando feeding them then any of the usual technicians on duty at the time can swap thing in an emergency. Otherwise you have to get someone electrically qualified to rewire things who may not be available at 03:15 or whenever something is playing up. Also that makes supporting a generator easy if you have a modest planned outage, etc.
What is needed is much clearer guidance on how to manage exemptions, making clear when it is tolerable (e.g. factory equipment in dry areas, data centre, etc) and when it would be unacceptable (e.g. outdoors when water ingress is always a risk, and contact for anyone with the Earth much more likely) , as well as making it clear there must also be a technical justification for doing so (i.e. not because of RCD installation or on-going testing cost, etc).
Sometime it seem BS/IET have their heads up there rears when it comes to issues like this. There are plenty of cases when a plug & socket is far more usable for high leakage current or critical equipment than having them hard-wired, so the apparent plan to drop the exemption completely seems crazy.
A perfect example is a data centre where is you have UPS with 16A or 32A commando feeding them then any of the usual technicians on duty at the time can swap thing in an emergency. Otherwise you have to get someone electrically qualified to rewire things who may not be available at 03:15 or whenever something is playing up. Also that makes supporting a generator easy if you have a modest planned outage, etc.
What is needed is much clearer guidance on how to manage exemptions, making clear when it is tolerable (e.g. factory equipment in dry areas, data centre, etc) and when it would be unacceptable (e.g. outdoors when water ingress is always a risk, and contact for anyone with the Earth much more likely) , as well as making it clear there must also be a technical justification for doing so (i.e. not because of RCD installation or on-going testing cost, etc).
I realise it’s a slightly older thread, however I’m looking for some help and advice regarding 3 phase sockets that were solely installed for welders in welding bays, they were fitted to interlocking sockets and are plugged in and left in, the only reason they were not hardwired is to allow for easy replacement on the production line if one breaks down, unfortunately they were not installed using rcd protection. However another company has since come in and told the client that essentially the equipment is dangerous as it doesn’t comply with BS7671, unfortunately the original designer of the installation has been let go and no risk assessment was prepared. I myself have never had much experience in the paperwork side of things as I’ve spent my life on the tools, any possible advice or help would be really appreciated. Thank you in advance.
What rating are these sockets and when were they installed.
They are 32 amp 3 phase N&E interlocking sockets and were installed last year, I’m well aware myself that BS7671 states that they need to be on rcds, however as reg 411.3.3 states that rcds can be omitted with a risk assessment. I’m guessing people are going to maybe come back and say they should be rcd protected, however what is the difference if the same piece of equipment was to be installed on a rotary isolator without rcd protection.
Hard wiring an appliance is certainly a way around this. A risk assessment should be carried out by the client if additional rcd protection is going to be omitted.
This is an rce risk assessment for our current design project, it's across 2 pages bit each line/row is a circuit.
L
loz2754
Agreed, but bear in mind Appendix 2 item 11, which states that "for the purposes of BS7671 a risk assessment should involve an appropriate electrically skilled person."
As has been said in this thread, it would be interesting to see an example of such a risk assessment.
Can I just ask what is the difference in the safety aspect if the same piece of equipment is hardwired, apart from the one time the plug is inserted then the inbuilt rotary isolator is turned on, everything else is exactly the same, the same piece of equipment will still be sat there with the same piece of wire connecting it to the isolator, all be it one has a plug and one doesn’t. Also does it have to be the client that has to produce the risk assessment or can it be an installer or designer that can produce the RA. Only ask as previous posters in this thread have mentioned they have added RA’s before.
I've given an example just as you posted this ? it's from a design project
L
loz2754
The difference is you have no control over what someone may plug into a socket outlet, whereas with fixed wiring you know exactly what it is supplying.
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