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Thread: Basic Compliance requirements

  1. #11
    Diamond Member AndyD's Avatar
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    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.
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    Gold Member Sparks's Avatar
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    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.

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    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.

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    Site Caretaker Dave A's Avatar
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    Quote Originally Posted by Stef-Lec View Post
    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.

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    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.

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    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!

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    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.

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    Full Member markthespark's Avatar
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    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.
    " I'd always rather be on the golf course!! "

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    Site Caretaker Dave A's Avatar
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    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?

    Quote Originally Posted by Stef-Lec View Post
    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.
    Last edited by Dave A; 24-Dec-16 at 07:22 PM. Reason: tried to soften my unintended BA

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    Quote Originally Posted by Dave A View Post
    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.

    Quote Originally Posted by Dave A View Post
    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?

  12. Thanks given for this post:

    ACEsterhuizen (25-Dec-16)

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