Basic Compliance requirements

[ACEsterhuizen]

The EIR 2009 refers:

There is a lot of different interpretations of the standards but the ECA or any "Inspection Authority" has no legal mandate to decide on that interpretation, only the Chief Inspector has. (Something the IA's tried to change some time in order to become judge jury and executioner)


....Appeals

12 (1) Should a dispute arise over the interpretation of a health and safety standard referred to in regulation 7 between the user, the registered person, the approved inspection authority for electrical installations, or the supplier, as the case may be, the affected person may appeal against that interpretation to the chief inspector.

(2) The person who appeals under sub-regulation (1) shall serve a notice of appeal, setting out fully the grounds of the appeal, on both the chief inspector and the person against whose interpretation he or she is appealing, by personally delivering the notice of appeal or sending it by registered post.

(3) The person against whose interpretation is being appealed shall, within 14 working days of the date of on which he or she received the notice of appeal, forward a notice setting out the reasons for his or her interpretation, to the chief inspector.

(4) The chief inspector shall, after having considered the grounds of the appeal and the cause of the dispute, confirm, set aside or vary the interpretation of the safety standard referred to in sub-regulation (1) or substitute it for such interpretation, which in the opinion of the chief inspector ought to have been taken.

They do respond very quickly, and I have have had numerous favourable "rulings" (which is a short letter sent back to the affected parties telling them what is going where and when and how deep) regarding disputes (against incompetent IA's, vindictive contractors and clever lawyers with their customers) So what I am saying is, interpret the standards to the best of your ability, and if you are challenged, follow the above procedure. It is fairly quick, and also the only legal way, and it's final.

Also, if you have such papers and ruling on appeals from the chief inspector a small claims court order becomes so much more successful. (I successfully claimed against a customer for not paying an invoice for wasteful time spent because of his incompetence and his contractor's vindictiveness)

Merry Christmas everyone and have a prosperous new year!

[Stef-Lec]

Thanks for the advice AC,

I read that as well and that's also why I'm questioning the ECA interpretation Dave quoted, I could not figure out what rule it is based on. To me the the more direct & explicit rules are the ones that would carry more weight as they are clearer, and the more rules you can apply to one interpretation as opposed to another, then the that would be the logical way to implement. And as someone mentioned in one of the threads, never say " I was told to..." as that would imply insufficient knowledge on your part.

I'd much rather just interpret as best I can based on what I can read in the rules and note the rules used on the COC in the comments section; chances are that your interpretation would not even be challenged.

[markthespark]

I think that, although it may cost you an extra hour on your inspection, make a note of any fixed appliances that are faulty and notify your client and have them sign acknowledgement of the faulty appliances. If there are issues with the new owners of the home you can always refer them back to the agent or the ex home owners. Sometimes the original home owners are not entirely aware of the faulty appliances.

I know its a pain but through experience I have found that this route has helped me out on numerous occasions. I have also benefited from the extra work for the repair work to some of the appliances.

[Dave A]

I was at a DoL safety forum in Durban a few weeks ago, and one of the points on "interpretation" is that too many people are trying to justify their installation's compliance via interpretation of the rules, rather than letting the code define what compliance is. This discussion illustrates the point.

Our hero is seeking to exclude the swimming pool supply because of a concern about the way it is supplied (specifically buried surfex not in conduit). So he tries to hang his hat on the fact that it's supplied via a socket outlet.

What does the code say?

I could not figure out what rule it is based on.

You raised it yourself in your conundrum - SANS 10142-1 has specific requirements for these fixed appliances regardless of whether it is supplied via a socket outlet or not. If you are to say that the installation complies with SANS 10142-1 and there's a swimming pool pump fixed appliance present, does the supply to the swimming pool motor comply?

I suggest if there's a "conundrum", a likely reason is there has been a wrong turn taken in the logic path.

[Stef-Lec]

I was at a DoL safety forum in Durban a few weeks ago, and one of the points on "interpretation" is that too many people are trying to justify their installation's compliance via interpretation of the rules, rather than letting the code define what compliance is. This discussion illustrates the point.

I most certainly agree with that; the discussion just illustrates that the rules are not always clear cut.

You raised it yourself in your conundrum - SANS 10142-1 has specific requirements for these fixed appliances regardless of whether it is supplied via a socket outlet or not

True.. and this is the bit I'm not too clear on.

These points are clear according to code:

1. Fixed appliances are not part of the installation
2. COC covers point of control to point of consumption
3. Point of consumption is the terminal of of fixed appliance except if powered from a socket
4. Cables must be buried deeper than 0.5m and in a conduit if unarmored
5. Non submersible pumps must be earthed, bonded and protected by E/L (specific requirements)

The supply to the pump does not comply, no argument.
The pump itself however is compliant with the specific rules.
Based on the code my logic says pool pumps, gate motors etc are not part of any installation and the the supply cable is only regarded as part of the installation when it is wired to the DB or any (mixed) circuit i.e NOT from a socket, fairly simple.

In this case then the supply to the pump is not covered by the COC, so is it then up to the owner to decide what he wants to do with the non-compliant cable? I see what you're getting at Dave, but can I reasonably refuse to issue the COC based on the rules above?

[Dave A]

Point of consumption is the terminal of of fixed appliance except if powered from a socket

That's not what the definition says. Read it again -

"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;

In your situation I'd be inclined to say the point of consumption is the supply terminals of the control panel - i.e. your "mini-db" (being the machinery's control panel).

Of course we all recognise the moment that "mini-db" also supplies something else, like outside lighting, a gazebo, the gate motor, etc. it now becomes a sub-db and the whole game moves to a different level.

If you don't consider the pool appliance (normally the pump and the pool light) as a complete unit of machinery installed for a specific purpose, then the "control panel" must actually be a sub-db.

This seems to put me at odds with Andy, which does concern me some. The crux would seem to be what constitutes a "complete unit of machinery", perhaps?

[AndyD]

Lol, I wouldn't worry about being at odds with me, I'm certainly not an expert and am usually at odds with myself from one day to another. I almost never get involved with this area of electrics (domestic and CoC's) so take anything I say with a pinch of salt.

point of outlet
termination of an electrical installation, which has been provided for
connecting any electrical machinery without the use of a tool, provided
that no connection to a busbar is deemed to be a point of outlet. (See
socket-outlet, 3.72)

The point of outlet for the pool installation was a socket in the bedroom therefore the supply terminal of the machinery is connected to a point of outlet therefor by the definition in 3.55 the supply terminal of the machinery or any point within the pool control box can't be the 'point of consumption'.

As you say, whether you class a swimming pool a fixed appliance installation along with its light, possibly a chlorinator etc as 'machinery which has been installed for any specific purpose as a complete unit'. The COC itself classes a pool as a fixed appliance but the contention for me with this definition is the 'complete unit' part. It would suggest all components would be have been supplied together as a complete unit and all would be interlinked via common controls. A pool pump and possibly a chlorinator and even a 24hr/7day timer switch could be a 'complete unit' because they're usually interlocked to operate together so an installation consisting of only those items the panel that supplies them could be a control panel. Problem comes with the light with isolating transformer on its own OCPD and own switch which would be an autonomous/extraneous item from the pool machinery although the luminaire itself is an integral part of the pool so would this make the pool box a subDB? Honestly I don't know.

It would be a similar conundrum with a geyser that has a retrofit energy monitoring gizmo attached to it. Invariably these are supplied from the geyser isolator switch but often they wouldn't pass the 'being installed as a complete unit' requirement so would they be classed as being part of the geyser or would they be a separate fixed appliance meaning the geyser isolator is actually supplying two fixed appliances?

[Lionels]

My thinking is that a pool DB should always be fed directly from a DB, and class it as a SUB DB.
My reasoning is that on the COC it only lists a POOL PUMP, not POOL DB, so in my mind it should be listed as a separate DB.

Maybe I dont need to go that far but the SANS 10142 is deemed as a minimum standard so if it is safer or as deemed by me, better, no one can complain.

[AndyD]

.....but the SANS 10142 is deemed as a minimum standard so if it is safer or as deemed by me, better, no one can complain.

I like the way you think, I agree the code is and should considered be an absolute minimum standard and there's no reason a risk assessment by a competant person shouldn't result in a higher standard being required if necessary.

[Blurock]

What is the compliance standard for manufacturing of LED light fittings.
A friend is manufacturing a really sexy housing from extruded aluminium, but is uncertain about the requirements for the LED lights fitted inside the housing.

Can someone please help?

[AndyD]

Maybe contact SABS and ask what the testing/certification requirements would be https://www.sabs.co.za/Sectors-and-S...tronics_pt.asp

[markthespark]

Hi guys it seems that most of the topics on the forum are items related to compliance. It would really be helpful if the inspectors of the inspection authorities would join the forum and assist us all with these confusing issues.How do we get them to participate?

[ians]

Hi guys it seems that most of the topics on the forum are items related to compliance. It would really be helpful if the inspectors of the inspection authorities would join the forum and assist us all with these confusing issues.How do we get them to participate?

Putting yourself on a public forum and opening up to all these issues would be suicide.

Getting the correct info about the regs is like trying to squeeze water out of a stone.

In the perfect world SABS would have a help line. They make the rules they should have people who are employed and trained to offer 24 hours (or at least during office hours) guidance to inspectors.

The fact that people have to resort to social media platforms like this to get advice is a clear indication of how f&*%&* the system is.

You can always follow the sparks edition of the regs, they dont even get it right.

[Sparks]

What is the compliance standard for manufacturing of LED light fittings.
A friend is manufacturing a really sexy housing from extruded aluminium, but is uncertain about the requirements for the LED lights fitted inside the housing.

Can someone please help?

Have him print "Made in China" on it and he will be good to go.

[AndyD]

I know you guys are talking about interpreting of the regs rather than the regs themselves so on a slight tangent, I've wondered for a while and never got around to asking, does anyone know if the SANS regulations are available to be accessed for free viewing at public libraries? This is the case in the UK, (in theory) you can view all the British Standard regs at any library. In practice they're only available at the main libraries but none the less they're available for public viewing, just wondered if it was the same here.....