[Question] Basic Compliance requirements

[hartdev@hotmail.com]

Hi Guys
I am now going to ask a few questions to which I already thought i knew the answers, but have recently had some doubt ...
I have been doing C.O.Cs for a few years now for residential properties.
I'm one of these guys who take the law and quality of work seriously, perhaps too seriously at times.
One thing that I am often questioned about is this:
I have always been under the impression that to issue a COC every electrical device should be working
eg.
Every light
every plug socket
Pool pump
chlorinator
geyser
intercom
Timers
fans
lights within fans

excluding: garage door motors which are plugged in
extractor fans which are plugged in
alarm systems

I can't seem to find anywhere that specifically states that everything must work, but this is how I have always understood it to be.
I have estate agents telling me that I am quoting for unneccessary work and I'm losing out on jobs because there are other electricians repairing far less..
Another thing is that I always install double pole isolators for fans which are not on earth leakage.

I know estate agents have their own agendas but I also don't want people to think that I am trying to rip them off.
I thought I knew this but now i'm not so sure...
Any advice would be greatly appreciated

[Dave A]

The variety of applied interpretation for section 9.2(b) COC's across the industry is a topic that has fascinated me for some time already. Before I put in my 2c worth though -

I can't seem to find anywhere that specifically states that everything must work, but this is how I have always understood it to be.

Could I ask you to think hard as to what the source of that understanding might be?

Original training?
A COC refresher course, or regs update training perhaps?
Or from another IE?

[hartdev@hotmail.com]

Hi Dave
I did my COC course some time back so perhaps I need a refresher course...
The electrician I worked under in the past (many years ago) always quoted to repair any plug sockets, light fittings etc which were not working.
Another reason I work to this standard is that I issued a COC on a house about 2 years ago. I missed a plug socket which a cupboard was in front of ,which happened to not be in working order. The new owners acted like I had killed their children or something They also complained bitterly about a plug socket which required slightly more force than normal to push in the plug top.
I replaced both of these plug sockets at my expense without asking any questions. I live in a small town and don't need a bad reputation.

I have since started charging R1050 for a COC inspection, I check everything and do all tests (eg. PSC, earth electrode, earth continuity etc), and I clearly state that if I uncover any other problems while doing repairs I will sort them out at my own expense.
The problem is my competitors are charging R500 for the inspection. However new owners of homes are contacting me saying they have bought a house and light fittings etc are not working and they want to hire me to do inspections for them so that they can argue with the electrician or estate agents.
I don't want to be in a position where I am criticizing other electricians work, but it seems I can't avoid it if I want to keep my business afloat.
What a conundrum

[Dave A]

Let's start with what's on the COC document itself. In SANS 10142-1 on page 281, NOTE 3 states -

This report covers the circuits for fixed appliances, but does not cover the actual appliances, for example stoves, geysers, air conditioning and refrigeration plant and lights.

From that it might seem that fixed appliances are excluded entirely from examination; if only life were so simple.

Looking at the definitions of an electrical installation per the Electrical Installation Regulations (R 242 of 2009), we find -

"electrical installation" means any machinery, in or on any premises, used for the transmission of electricity from a point of control to a point of consumption anywhere on the premises, including any article forming part of such an electrical installation irrespective of whether or not it is part of the electrical circuit, but excluding
(a) any machinery of the supplier related to the supply of electricity on the premises;
(b) any machinery which transmits electrical energy in communication, control circuits, television or radio circuits;
(c) an electrical installation on a vehicle, vessel, train or aircraft; and
(d) control circuits of 50 V or less between different parts of machinery or system components, forming a unit, that are separately installed and derived from an independent source or an isolating transformer;

Now looking at the point of consumption, we find -

"point of consumption" means any point of outlet or the supply terminals of machinery which is not connected to a point of outlet and which converts electrical energy to another form of energy: Provided that in the case of machinery which has been installed for any specific purpose as a complete unit, the point of consumption shall be the supply terminals which have been provided on the unit of machinery for that purpose;

And I need to dash - I'll come back to this later.

[Dave A]

So let's try to answer this question now -

One thing that I am often questioned about is this:
I have always been under the impression that to issue a COC every electrical device should be working
eg.
Every light
every plug socket
Pool pump
chlorinator
geyser
intercom
Timers
fans
lights within fans

excluding: garage door motors which are plugged in
extractor fans which are plugged in
alarm systems

I can't seem to find anywhere that specifically states that everything must work, but this is how I have always understood it to be.

Here are some extracts from the ECA (SA)'s information brochure on the Certificate of Compliance and Test Report -

As part of the answer to the question "I have a Certificate of Compliance (CoC) and the installation is not functioning properly, what should I do?"

It is important to bear in mind that the CoC and Test Report certifies the safety of the installation. It is possible that an electrical installation might not be fully functional (e.g. some lights or plugs don't work), but the installation is safe and the CoC and Test Report is valid.

In answer to the question "Are appliances covered by the Certificate of Compliance (CoC)?"

• Appliances such as lights, geysers, stoves, air conditioning units etc (See note 3 on the front page of the Test Report) are not covered by the CoC and Test Report. A non-working appliance does not mean that the CoC is invalid.
• The CoC and Test Report covers the whole installation from the point of control (main switch in the distribution board) to the point of consumption anywhere on the premises (i.e. socket outlets, terminals of light fittings, geysers, stoves etc.)
• The CoC and Test Report certifies the fixed wiring of the electrical installation including the distribution board, light switches, wall mounted isolators, and socket outlets.

On the flip side, I'm reliably informed that at a regs. update training session in KZN some years ago attended by 100s of IEs, the presenter stated that if there's a light, it must work (the self-same person who had a strong hand in the development of the info flyer I quoted from above). No wonder there are conflicting views out there!

Last thought for this evening - The one thing that stands out from your list is "plug socket" as socket outlets are part of the electrical installation - i.e. not a fixed appliance.

[hartdev@hotmail.com]

Dave thanks so much for the information
Firstly I now realize that Intercoms should not form part of the COC and I will exclude that in future.
The issue of light fittings is a confusing one but I will stick with ensuring they work.
I will also ensure all plug sockets work.
I'm still not one hundred percent sure about pool pumps, chlorinators etc though...These are expensive items and I can imagine neither the seller or the buyer of the property will want to pay for repairs.
If the COC is simply a matter of safety it would be alot simpler, but working to that standard just gives my company a bad name when new owners move into a home and half the light fittings etc aren't working.
So I will keep being the pain in the ass who insists everything must work
I think I will just provide the WCAEIA (Western Cape Approved Electrical Inspection Authiority) number to people who ask me to judge another electricians work in future. Its just don't clear enough as far as I understand to argue the point with anyone.

[Dave A]

I have my reservations about the position on some of these things too. Here's another gem, this time from the ECA(SA) FAQ page -

Can fixtures, lights, fans, electrical gates, swimming pool pump etc. be exluded from an Electrical Compliance Certificate?

In terms of the Electrical Installation Regulations 2009 (which are a Schedule to the Occupational health and Safety Act), an “electrical installation” is defined as any machinery, in or on any premises, used for the transmission of electricity from the point of control to the point of consumption anywhere on the premises. The point of control is defined as the point at which an electrical installation on or in any premises may be switched off by the user from the electricity supplied from the point of supply; and the point of consumption means any point of outlet or the supply terminals of machinery which is not connected to a point a point of outlet. A point of outlet is defined as any termination of an electrical installation which has been provided for connecting any electrical machinery without the use of a tool. In other words, a socket outlet is a point of outlet, and anything plugged into that socket is not deemed to be a part of the electrical installation.

The only situations in which something that is “plugged in” becomes a part of the installation is a swimming pool, spa bath etc for which specific provisions are included in the Wiring Code (SANS 10142-1), and extra low voltage lighting. Such Code lays down the minimum safety standards for any electrical installation in South Africa. Insofar as fixtures such as lights, electric gates, cookers and fans are concerned, the installation terminates at their connections. So, for example, if the fan motor is not functioning but the earthing and connections to the fan are safe, it is not a requirement for the electrical contractor to ensure that the fan is working. This would be an issue between the seller and the buyer because the expectation of the buyer is that all he sees is in proper working order.

I suggest there's a huge potential to misunderstand the definition of "point of consumption" in play here. Let me stress this part of the actual definition -

Provided that in the case of machinery which has been installed for any specific purpose as a complete unit, the point of consumption shall be the supply terminals which have been provided on the unit of machinery for that purpose;

It's a catch-all qualification of the preceding sentence, and doesn't an electric gate motor meet this requirement? Hence even if powered off a socket-outlet, the point of consumption remains the supply terminals which have been provided on the unit of machinery...?
And in fact a couple of sentences later the ECA(SA) statement says the same thing too.

You also have to consider 6.16.1.11 of SANS 10142-1, which states -

The wiring between different parts of a fixed appliance that are installed separately is part of a fixed installation, even where it is supplied by a socket-outlet, unless such wiring is less than 3m in length.

So it's simply not true that if something is powered off a socket-outlet, it is automatically not part of the fixed installation.

I'm also a little concerned the piece might be interpreted as suggesting that if a swimming pool pump motor isn't working, it is an electrical CoC issue...

[Sparks]

Just a footnote here to be kept in mind. Although the actual fixed appliance is not covered by the COC, it must still meet the earthing and isolating requirements.

[Stef-Lec]

Hello Gents,

I'm sitting with the same issue on a property where the pool pump installation is run from a plug in one of the bedrooms going to the mini DB in the pump house. The mini DB then has a plug socket again where the pump motor is plugged into. I'm inclined to just exclude it from the COC and note the same on the exclusion section of the COC.

I'm of the opinion that the user/lessor/lessee is using it as an appliance due to the fact that it is connected to a point of outlet, as per the definition for "point of consumption" the supply terminals of the pump DB would only be regarded as the point of consumption when it is NOT connected to a point of outlet, i.e a plug socket....which then means I could exclude it?

Considering 6.16.1.11 of SANS 10142-1, it talks about the PARTS of a fixed appliance, not the wiring between the installation and the appliance....the fixed appliance is the pump inclusive of the mini DB (ie the different parts), then the wiring between the mini DB & the pump are regarded as fixed, unless <3m in length which it is, so then it is not fixed, and not part of the installation?

Looking at 7.2.4.4 & 7.2.4.6 the only requirement if the pump is in Zone 2, is that it must be be EL protected & earthed obviously & have visible bonding, so whether part of the installation or not it still satisfies the so-called specific provisions for pumps.

[Stef-Lec]

If I read 6.16.1 in it's entirety, point 1 clearly says fixed appliances are not part of the electrical installation, other than positioning in relation to the supply & wiring between the parts of the appliance(referred to again in point 11)
Point 3 states that the supply must be through a double pole disconnector (not a double pole switch) OR socket outlet that is directly accessible, and according to point 5, either 1.5m from the appliance OR in a DB(if able to be locked in open pos)

6.16.10 talks about connnections between circuit conductors and appliance conductors, then it logically follows that 6.16.11 is not referring to the supply to the appliance, but rather aimed at appliances like split a unit AC's where the wiring between external & internal units (parts of the fixed appliance) are >3m. This part of wiring is then regarded as part of the installation ( and must then have it's own overcurrent protection) even if the AC unit in its entirety is fed from a scoket, but the AC itself is not part of the installation.

Thus my conclusion is that in short, swimming pool pumps, garage door motors, gate motors AC units,geysers, stoves etc are fixed appliances and not part if the installation, and could be fed from a plug (unless specific regs apply such as for geysers/stoves) or a switch disconnector, in the case of the latter the point of consumption will be at the supply terminals of the appliance and thus the wiring up to these terminals is included in the COC whilst in the case of the former the COC covers up to the socket outlet.

[AndyD]

I would suggest the socket in the house would be considered the point of consumption. I don't think you can consider a pool control box as a 'Sub-DB', if I remember correctly it should be solely for the supply of pool equipment and an integral part of the fixed appliance. From waht you've mentioned above it sounds like you've got a fixed appliance supplied from the socket in the house via what's effectively an extension lead.

[Sparks]

I agree with Andy that the room plug is the point of consumption. Being a fixed appliance with the isolating point in a room inside the house it is not acceptable. The distance from the plug also exceeds recommendations. The pool db cannot be considered a sub db by virtue of it being plugged in as Andy mentioned. The cheapest and quickest way to rectify would be to call it a mixed circuit and connect the db directly to the socket outlet supply.

[Stef-Lec]

Tx Andy/Sparks,

pretty much my reasoning as well; only reason for calling it a"mini-db" was for the sake of description, it is used as a control box solely for pool equipment.

WRT the isolating point being in a room in the house and the distance, I can agree it is not acceptable to us, but legally it is actually OK. The purpose of the 3m recommendation is for proper functioning of the overload protection, but there is a breaker in the control box, and Amdt 3 of 6.16.1.3 states that if the appliance is remotely installed, the position of the disconnecting device must be indicated by a notice close to the appliance.

The conundrum however is that I could exclude the pool pump from the COC owing to the point of consumption being the plug in the house, yet there are rules still in play for the pump. Does it mean then that the user/lessor is now accountable for the pump and it's associated rules? I feel it is my duty to at least inform them of the fact, but is that where my obligation ends?

I'm a bit weary of going the mixed circuit route as they are using surfix that is buried; if it was buried inside a conduit I'd be comfortable, but there have been issues before with the gardener damaging the cable so I'd rather just exclude it to protect myself as well.

[Dave A]

The conundrum however is that I could exclude the pool pump from the COC owing to the point of consumption being the plug in the house, yet there are rules still in play for the pump. Does it mean then that the user/lessor is now accountable for the pump and it's associated rules? I feel it is my duty to at least inform them of the fact, but is that where my obligation ends?

From one of my posts in this thread here, the ECA (SA) view on this is: -

Can fixtures, lights, fans, electrical gates, swimming pool pump etc. be exluded from an Electrical Compliance Certificate?

In terms of the Electrical Installation Regulations 2009 (which are a Schedule to the Occupational health and Safety Act), an “electrical installation” is defined as any machinery, in or on any premises, used for the transmission of electricity from the point of control to the point of consumption anywhere on the premises. The point of control is defined as the point at which an electrical installation on or in any premises may be switched off by the user from the electricity supplied from the point of supply; and the point of consumption means any point of outlet or the supply terminals of machinery which is not connected to a point a point of outlet. A point of outlet is defined as any termination of an electrical installation which has been provided for connecting any electrical machinery without the use of a tool. In other words, a socket outlet is a point of outlet, and anything plugged into that socket is not deemed to be a part of the electrical installation.

The only situations in which something that is “plugged in” becomes a part of the installation is a swimming pool, spa bath etc for which specific provisions are included in the Wiring Code (SANS 10142-1), and extra low voltage lighting. Such Code lays down the minimum safety standards for any electrical installation in South Africa. Insofar as fixtures such as lights, electric gates, cookers and fans are concerned, the installation terminates at their connections. So, for example, if the fan motor is not functioning but the earthing and connections to the fan are safe, it is not a requirement for the electrical contractor to ensure that the fan is working. This would be an issue between the seller and the buyer because the expectation of the buyer is that all he sees is in proper working order.

[Stef-Lec]

Tx Dave, I saw that, hence my posts; I find that view a bit strange because point of consumption specifically excludes any machinery fed from a point of outlet and fixed appliances are also excluded specifically in 16.6.1.


So which takes precedence? The fixed appliance rules or the swimming pool rules? The pool equipment is complies with specific provision for pools and non submersible pumps; my problem is with the supply cable that's not buried deeper that 0.5m and is not in a conduit.