Concurrence with two codes

[D Skelton]

I'm currently inspecting an installation which has a small TP pump submersed in a tank which is not readily accessible. The control panel is in an area accessible to staff who according to the on site maintenance team loved just hitting the e-stop because the pump was loud, this caused damaging flooding on numerous occasions. Rather than educating the numpties, the maintenance guys have bunged a thin perspex panel in front of the control buttons. The pump runs automatically so the controls are 'never' needed unless it needs re-setting, but the e-stop is covered too.

Firstly, the e-stop can still be operated if the perspex is pushed firmly enough.

My intuition tells me however that an e-stop isn't neccessarily needed for this particular set up, in fact I'm sure it isn't.

The only regs I can come across that cover this are BS 7671s requirement for a fixed electric motor to have a readily accessible means of switching off and BS EN 60204s requirement for an e-stop to be readily accessible (which may or may not come into play depending on whether the e-stop is required in the first place).

My gut tells me C2, but I am struggling to find any element of danger posed to anyone by the pump or motor, nor any reason why it would need to have a readily accessible means of switching off other that the regulation that demands it. Overcurrent protection is adequate in the event of a fault and the circuit is isolatable (not locally [in order to have another method of a readily accessible means of switching off]) for maintenance purposes.

C3 just seems too lax but am happy to receive opinons to the contrary.


The second issue is with exposed live parts. They are out of reach (above 2.5m) and are only accessible by the two maintenance guys, one of whom is a qualified electrician. They are the terminals on ballasts for fluorescent tubes that are not enclosed but instead left secured in an extended coving providing a light wash on the ceiling. They are accessible by ladder, the only people who have access to are the maintenance guys. My quibble is three fold;

1. The 'installation' is accessible by anyone, regardless of the exposed live parts being out of reach. Something prohibited (depending on your definition of the word 'installation') when using placing out of reach as a protective measure.

2. If you take 'installation' to mean the part of the circuit which contains live parts, then it may conform with the requirements for using placing out of reach as a protective measure, but, there is no requirement (in their job description) for the maintenance guys to be electricians, one of them just happens to be so. This means should he retire or move on to greener pastures, the 'installation' may not be restricted only to a skilled or instructed person.

3. The exposed live parts are less than 2.5m from an exposed conductive part, however there is an obstacle in the way (the extended coving) that would almost certainly prevent any object or person coming into contact with both at the same time.

My gut says C2 as there is no immediate danger present. I can't personally see this warranting a C1 although it is niggling in my mind due to there being exposed live parts that are potentially not covered by any protective measure. I guess some confirmation that I'm making the right decision is what I'm after? Again, happy to receive opinions to the contrary.

 

[Plonker 3]

Can't really comment on the motor as not got much experience in that area to comment on it.

As for the exposed parts being placed out of reach, who has access to that area and how is access controlled to it? I would say if only the 2 people you mention then maybe a C3 as you could use the skilled or instructed persons? If anyone has access I would go C1 as you never can say what could happen in that area.

just my ideas, but as you already know it's you --- on the line if the brown stuff hits the fan.

 

[telectrix]

IMO, a C3 for the first and a C2 for the second.

 

[dingledong]

I'm currently inspecting an installation which has a small TP pump submersed in a tank which is not readily accessible. The control panel is in an area accessible to staff who according to the on site maintenance team loved just hitting the e-stop because the pump was loud, this caused damaging flooding on numerous occasions. Rather than educating the numpties, the maintenance guys have bunged a thin perspex panel in front of the control buttons. The pump runs automatically so the controls are 'never' needed unless it needs re-setting, but the e-stop is covered too.

Firstly, the e-stop can still be operated if the perspex is pushed firmly enough.

My intuition tells me however that an e-stop isn't neccessarily needed for this particular set up, in fact I'm sure it isn't.

The only regs I can come across that cover this are BS 7671s requirement for a fixed electric motor to have a readily accessible means of switching off and BS EN 60204s requirement for an e-stop to be readily accessible (which may or may not come into play depending on whether the e-stop is required in the first place).

My gut tells me C2, but I am struggling to find any element of danger posed to anyone by the pump or motor, nor any reason why it would need to have a readily accessible means of switching off other that the regulation that demands it. Overcurrent protection is adequate in the event of a fault and the circuit is isolatable (not locally [in order to have another method of a readily accessible means of switching off]) for maintenance purposes.

C3 just seems too lax but am happy to receive opinons to the contrary.

It can be stopped but you have to press firmly I think that's the point if it's just firm c3 if it's really firm c2

The second issue is with exposed live parts. They are out of reach (above 2.5m) and are only accessible by the two maintenance guys, one of whom is a qualified electrician. They are the terminals on ballasts for fluorescent tubes that are not enclosed but instead left secured in an extended coving providing a light wash on the ceiling. They are accessible by ladder, the only people who have access to are the maintenance guys. My quibble is three fold;

1. The 'installation' is accessible by anyone, regardless of the exposed live parts being out of reach. Something prohibited (depending on your definition of the word 'installation') when using placing out of reach as a protective measure.

2. If you take 'installation' to mean the part of the circuit which contains live parts, then it may conform with the requirements for using placing out of reach as a protective measure, but, there is no requirement (in their job description) for the maintenance guys to be electricians, one of them just happens to be so. This means should he retire or move on to greener pastures, the 'installation' may not be restricted only to a skilled or instructed person.

But a competent person surely otherwise he wouldn't be a maintenance man

3. The exposed live parts are less than 2.5m from an exposed conductive part, however there is an obstacle in the way (the extended coving) that would almost certainly prevent any object or person coming into contact with both at the same time.

My gut says C2 as there is no immediate danger present. I can't personally see this warranting a C1 although it is niggling in my mind due to there being exposed live parts that are potentially not covered by any protective measure. I guess some confirmation that I'm making the right decision is what I'm after? Again, happy to receive opinions to the contrary.

I thought c1 and c2 were both failures anyway

 

[davesparks]

I thought c1 and c2 were both failures anyway

What is that supposed to mean? There is no pass or fail on an EICR, only observations and recommendations with an overall assessment of either satisfactory or unsatisfactory.

There is a big difference between C1 and C2 and it is important to use them correctly.

 

[D Skelton]

Any thoughts Dave?

 

[HandySparks]

These exposed live parts, are they touchable directly with a finger, or would it require a prod with an un-insulated screwdriver?

 

[D Skelton]

These exposed live parts, are they touchable directly with a finger, or would it require a prod with an un-insulated screwdriver?

If you prodded them with your finger firmly they'd be touchable.

 

[HandySparks]

If you prodded them with your finger firmly they'd be touchable.

I think I'd have to give it a C1 then. If outside maintenance contractors or decorators are ever used who are unaware of the danger, there's a real risk of shock and a fall off a ladder.

 

[davesparks]

Any thoughts Dave?

Yes, I'm trying to work out how to write them down at the moment.

I'm inclined towards C2 for the first one from the point of view that you are reporting on the condition of the installation as-is. So as it stands at the moment there is an emergency stop button which has been prevented from being operated as intended.
However it does sound like it is not required in the installation so the remedial work could be to remove the e-stop, but I don't know enough about 60204 to say if this is allowed.

For the second one I would say C2 also, but am struggling to justify this in regulations at the moment as it is based more on instinct.
I want to say that this is not a situation that placing out of reach would normally be expected to be used for and if it is the kind of thing I am picturing in my mind I doubt the installers would have even considered this.
But we can't go coding things because of instincts or perceived intentions of the regulations!
I would suggest asking the maintainance guys if they are aware of this situation and if they have a system in place for instructing anyone accessing this area.
I think the use of 'skilled and instructed' should require some sort of system for instructing people who aren't skilled prior to accessing such things, eg making it part of the site induction.

I hope at least some of the above makes sense!

 

[davesparks]

I think I'd have to give it a C1 then. If outside maintenance contractors or decorators are ever used who are unaware of the danger, there's a real risk of shock and a fall off a ladder.

See my above post, but if these people are 'instructed' as part of their site induction prior to starting work then that would have a bearing on the situation.

 

[Marvo]

I'd guess that...and please not this is a guess because I have no specific UK regs knowledge, the covered e-stop should be fine even with a cover if it still operates when pressed. I'd guess the E-STOP in the scenario you've described wouldn't be necessary but if there is one present it should work because in an emergency it would be expected to do so by anyone on hand.

The bare wires require a 'tool' to access them (in the form of stepladders) so for me this would exempt them as a hazard entirely if there was a warning sign indicating shock hazard.

I do have a question though, do your UK domestic EICR certifications actually extend to installations that would be installed to the machine regs rather than the 7671 regs?

 

[shanky887614]

I'd guess that...and please not this is a guess because I have no specific UK regs knowledge, the covered e-stop should be fine even with a cover if it still operates when pressed. I'd guess the E-STOP in the scenario you've described wouldn't be necessary but if there is one present it should work because in an emergency it would be expected to do so by anyone on hand.

The bare wires require a 'tool' to access them (in the form of stepladders) so for me this would exempt them as a hazard entirely if there was a warning sign indicating shock hazard.

I do have a question though, do your UK domestic EICR certifications actually extend to installations that would be installed to the machine regs rather than the 7671 regs?

the eicr cert is the same for all installs

the eicr only really covers fixed wiring but everything needs to have a minimum of ip 44 (cant get fingers in) if i remember right unless a tool is needed to gain access etc.


if it didnt then all our panels would fail because live cables in trunking that cant be isolated locally etc (bms side usually)

 

[davesparks]

I do have a question though, do your UK domestic EICR certifications actually extend to installations that would be installed to the machine regs rather than the 7671 regs?

Good question, and like all things bs7671 you have hit a point which could be considered a grey area and open to interpretation.
The EICR is not domestic specific, it covers all installations not subject to other statutory regs.
Bs7671 does state that where statutory regs or other standards apply that they be adhered to.
So if an installation does not comply with the machinery regs when it should it could be considered to not comply with bs7671.

But I can see that turning in to a massive debate about the precise wording and intention of the regs.

 

[HandySparks]

See my above post, but if these people are 'instructed' as part of their site induction prior to starting work then that would have a bearing on the situation.

I take your point, but I think that it would be preferable to provide alternative ballasts with integral terminal covers or a suitable enclosure for the existing ones rather than to add a warning to the maintenance procedures about exposed live parts. (Sort of admits to a situation that shouldn't exist!)

 

[davesparks]

I take your point, but I think that it would be preferable to provide alternative ballasts with integral terminal covers or a suitable enclosure for the existing ones rather than to add a warning to the maintenance procedures about exposed live parts. (Sort of admits to a situation that shouldn't exist!)

You've missed the point, we are not discussing how to improve the situation or what should or should not have been installed.
We are merely discussing how to assess the installation for its compliance in its current condition.
And placing out of reach is a current method of protection so you can't just say outright that the situation shouldn't exist!

 

[D Skelton]

I take your point, but I think that it would be preferable to provide alternative ballasts with integral terminal covers or a suitable enclosure for the existing ones rather than to add a warning to the maintenance procedures about exposed live parts. (Sort of admits to a situation that shouldn't exist!)

My thinking too, but I am of two minds on this one.

1. It's a C2 because no one is at any immediate risk.
2. It's a C1 because there are exposed live parts that are still technically accessible by anyone and they may not neccessarily be covered by a protective measure depending on what your interpretation of the word 'installation' is.

I'm leaning towards the former, but still haven't made my mind up. It certainly doesn't seem to be a straight forward decision whichever way you look at it though!

 

[Plonker 3]

If you are still unsure, I believe NICEIC provide tech support to non members so may be worth a call to them in the morning as I have found them quite helpful in the past.

 

[HandySparks]

..And placing out of reach is a current method of protection so you can't just say outright that the situation shouldn't exist!

You'd have to be convinced that adequate controls are in place so that only skilled persons or instructed persons under the supervision of skilled persons are allowed access(410.3.5). I think I'd want to see documented evidence of this before allowing Placing out of Reach as a means of protection. Or do you just assume that any workplace can use this means of protection?

 

[D Skelton]

If you are still unsure, I believe NICEIC provide tech support to non members so may be worth a call to them in the morning as I have found them quite helpful in the past.

Appreciate the thought but I'd rather burn out my own eyes with hot pokers lol.

Far more experience and knowledge on here. We all club together I'm sure we can work it out

I'm happy going C2 for the both really, that is unless someone pipes up with a solid reason as to why another code may apply to either.

 

[davesparks]

You'd have to be convinced that adequate controls are in place so that only skilled persons or instructed persons under the supervision of skilled persons are allowed access(410.3.5). I think I'd want to see documented evidence of this before allowing Placing out of Reach as a means of protection. Or do you just assume that any workplace can use this means of protection?

Is that not what I've said already? Checking to see if anyone accessing it receives instruction.

I never said anything about assuming things, just that they need to be checked.

And again it's not really a case of 'allowing' it but merely of reporting on the current condition of the installation. And as I suggested earlier some weight needs to be given to the likelihood of the original installers intending to use placing out of reach or if they were just bodgers.

What code if any would you give if it was an old farm installation which still had bare overheads? Or even single insulated overheads?

 

[UNG]

In my thinking the pump installation should come under the ISEEI&T as it's really a fixed appliance and therefore not part of the EICR

 

[D Skelton]

Anyone else?

 

[Clive P]

Hi,

Just to put my thoughts forward. I don't have the experience that you guys have with EICR forms as when I was working we used our own in house recording. I'll have a stab anyway.
Scenario 1, It should have an operable E stop if that is what is fitted ( for emergency purposes ). Therefore it has to be removed or the perspex removed. I know, I should be looking at the install as is, as Dave says. for me a C3.

Scenario 2, for me this has to be a C2, from what I understand of the situation; placing out of reach on this occasion is not sufficient and can be rectified quite easily ( OK, we're not looking at that at the moment ). Anyway those are my thoughts.

Regards.

 

[Clive P]

Hi,

To be honest I find these little conundrums quite interesting, BUT what about the RCD.

Regards.

 

[Marvo]

The thing I find interesting is that there's guys here with lots of experience but there's still a wide range of answers. This has also been evident in previous threads of this nature over the years, there's rarely much in the way of consensus on which code to use if it's not a common failure or deficit.

Please don't take this the wrong way, I'm all experienced electricians being able to think for themselves and justify their decisions but is there actually a sufficient framework of guidance for these EICR failure codes? Also is there sufficient clarity on where the EICR does and does not have jurisdiction in a commercial or control environment?

 

[davesparks]

The thing I find interesting is that there's guys here with lots of experience but there's still a wide range of answers. This has also been evident in previous threads of this nature over the years, there's rarely much in the way of consensus on which code to use if it's not a common failure or deficit.

Please don't take this the wrong way, I'm all experienced electricians being able to think for themselves and justify their decisions but is there actually a sufficient framework of guidance for these EICR failure codes? Also is there sufficient clarity on where the EICR does and does not have jurisdiction in a commercial or control environment?

what we need is for the people who write the regulations to scrap them and start again to produce a set of regulations that are clear, easy to understand. Also we could do with people who don't know the particular sections of the regulations jumping in and confusing the issue, or those who can't separate their opinion from the facts.

 

[D Skelton]

The thing I find interesting is that there's guys here with lots of experience but there's still a wide range of answers. This has also been evident in previous threads of this nature over the years, there's rarely much in the way of consensus on which code to use if it's not a common failure or deficit.

Please don't take this the wrong way, I'm all experienced electricians being able to think for themselves and justify their decisions but is there actually a sufficient framework of guidance for these EICR failure codes? Also is there sufficient clarity on where the EICR does and does not have jurisdiction in a commercial or control environment?

Yeah, I saw this one coming to be fair. It's not your every day 'ring that isn't a ring' scenario, or the old 'no main earthing conductor' scenario.

For me, the fact that we have a smorgas board of differing opinions from an experienced bunch of guys makes me comfortable coding it as I planned on doing. I know in my head, no matter who turns up next and looks at my report, they will all have a different opinion of how they would code it. Essentially, whatever I do I'll have done the wrong thing according to the next spark. As long as I can justify my decision making process, no matter whether there isn't a right or wrong answer, I can sleep soundly at night knowing that I've done my job as best I could.

Some interesting opinions that have certainly provoked a bit of thought. Thanks for the input lads