Just reading through a recent disciplinary hearing, where an inspector got pulled up for failing to test/identify there was no earth connection to the body of a ‘plug in’ Xpelair fan (amongst a couple of other non compliance items), when completing a Woef.
Quote from the hearing as follows ‘…Appliances - (Xpelair fan) Continuity of earthing conductors. An Xpelair connected to the electricity supply via a three pin plug did not exhibit continuity between the metal parts of the fan and the earth pin of the connecting plug. (AS/NZS 3001 clause 6.2)…’
I didn’t think C6.2 applied to plug in appliances, I’m obviously wrong? So all appliances in a CI should be tested? Plug in toasters etc? Or is this more just applying to appliances permanently fitted in place, which I’m guessing the Xpelair fan in question is?
Earthing equipment/appliances in caravans
Re: Earthing equipment/appliances in caravans
When we look at the definitions for "electrical installation" & "connectable installation" in the Act;
one of the key differences is that appliances are specifically excluded from being part of an "electrical installation" but are specifically included for a "connectable installation".
The wording is "... and includes any electrical appliance that is connected, or intended to be connected, to any such installation "
So certainly directly-connected appliances are part of a CI and so must be included in the WoEF checks.
For appliances that are plugged in, the "intended to be connected" bit applies.
If it's there when we carry out the WoEF checks; we are presumably expected to assume that someone intends to "connect" it by plugging it in to use it. However I suspect this testing almost never happens.
For portable appliances, the excuse of "it wasn't there when I did the check" would be hard to disprove.
But an appliance that's fixed in place is clearly there with intent to plug it in.
So from that point of view, yes the appliances are part of a CI; and therefore it might seem that they have to be checked.
However it's not quite that simple.
ESR 78 requires WoEFs to be issued in accordance with the relevant Standard; which for most is "3001".
So we need to look at what requirements are set by the Standard for issuing a WoEF.
Clause 3.10.2 covers "periodic reverification", and points us to App C for the specific requirements.
C3 then narrows that down to the checks & tests listed in C6 for inspection & C7 for testing.
C6.2 covers equipment not earthed that is designed to be earthed. So a Class I appliance fitted with a 2-pin plug would be a fail.
C 7.5 requires specific checks for earth continuity - but only appliances that are permanently connected are included.
So as far as I can see, there's a requirement to inspect earthing of plug-in appliances; but no requirement to test it.
For imported CIs, the Part 1 assessment also has to include the appliances.
And clearly some common sense has to be used.
C6.1 would pick up exposed live parts (and again specifically includes "damaged equipment or appliances").
But every toaster has exposed live parts - and I wouldn't fail the CI for that unless the exposure was due to damage.
one of the key differences is that appliances are specifically excluded from being part of an "electrical installation" but are specifically included for a "connectable installation".
The wording is "... and includes any electrical appliance that is connected, or intended to be connected, to any such installation "
So certainly directly-connected appliances are part of a CI and so must be included in the WoEF checks.
For appliances that are plugged in, the "intended to be connected" bit applies.
If it's there when we carry out the WoEF checks; we are presumably expected to assume that someone intends to "connect" it by plugging it in to use it. However I suspect this testing almost never happens.
For portable appliances, the excuse of "it wasn't there when I did the check" would be hard to disprove.
But an appliance that's fixed in place is clearly there with intent to plug it in.
So from that point of view, yes the appliances are part of a CI; and therefore it might seem that they have to be checked.
However it's not quite that simple.
ESR 78 requires WoEFs to be issued in accordance with the relevant Standard; which for most is "3001".
So we need to look at what requirements are set by the Standard for issuing a WoEF.
Clause 3.10.2 covers "periodic reverification", and points us to App C for the specific requirements.
C3 then narrows that down to the checks & tests listed in C6 for inspection & C7 for testing.
C6.2 covers equipment not earthed that is designed to be earthed. So a Class I appliance fitted with a 2-pin plug would be a fail.
C 7.5 requires specific checks for earth continuity - but only appliances that are permanently connected are included.
So as far as I can see, there's a requirement to inspect earthing of plug-in appliances; but no requirement to test it.
For imported CIs, the Part 1 assessment also has to include the appliances.
And clearly some common sense has to be used.
C6.1 would pick up exposed live parts (and again specifically includes "damaged equipment or appliances").
But every toaster has exposed live parts - and I wouldn't fail the CI for that unless the exposure was due to damage.
- Rating: 16.67%
Re: Earthing equipment/appliances in caravans
Have now found the report. I note the Board quotes C6.2
which - as per my prev post - is an 'inspection" item and not a "testing " item.
However it seems the Board interpret it as needing to be tested, not just inspected.
I also note they are relying on the earlier decision that issuing a WoEF is PEW (because they believe it counts as "maintenance").
I strongly believe they are wrong on that; and the only reason that have adopted that position is that they can't take disciplinary action if the person concerned wasn't doing PEW at the time.
If this ever gets to court (by someone appealing their decision) I can't see their position being upheld.
However clearly this person was woefully negligent WRT other aspects;
and wasn't going to get far with any appeal, even if he had the time & money.
which - as per my prev post - is an 'inspection" item and not a "testing " item.
However it seems the Board interpret it as needing to be tested, not just inspected.
I also note they are relying on the earlier decision that issuing a WoEF is PEW (because they believe it counts as "maintenance").
I strongly believe they are wrong on that; and the only reason that have adopted that position is that they can't take disciplinary action if the person concerned wasn't doing PEW at the time.
If this ever gets to court (by someone appealing their decision) I can't see their position being upheld.
However clearly this person was woefully negligent WRT other aspects;
and wasn't going to get far with any appeal, even if he had the time & money.
- Rating: 16.67%
Re: Earthing equipment/appliances in caravans
Thanks for your response Alec. The definitions in the Act helps clear things up, and I see what you mean regarding the variance between the inspection and testing requirements for plug-in appliances.
Although the wording in the Act is still a little confusing to me “…any electrical appliance that is connected, or intended to be connected…”
I’m probably overthinking it but, the word “connected” to me means an electrical connection that has to be done with tools, rather than a plug/socket arrangement. This would omit plug-in appliances from fitting into the definition of a CI as described in the Act?
I can’t find a specific definition in the Act or ESR for “connected”, so guessing it comes down to interpretation?
Obviously the Board believe plug-in appliances apply, so best to go with that.
Although the wording in the Act is still a little confusing to me “…any electrical appliance that is connected, or intended to be connected…”
I’m probably overthinking it but, the word “connected” to me means an electrical connection that has to be done with tools, rather than a plug/socket arrangement. This would omit plug-in appliances from fitting into the definition of a CI as described in the Act?
I can’t find a specific definition in the Act or ESR for “connected”, so guessing it comes down to interpretation?
Obviously the Board believe plug-in appliances apply, so best to go with that.
Re: Earthing equipment/appliances in caravans
I guess it’s as you say “appliances intended to be connected” infers plug-in appliances apply.
Re: Earthing equipment/appliances in caravans
ESR 73A has a definition (clause (5)of "connection" that restricts it to action that is PEW;
which is similar to what you were thinking; and may be why you were thinking it.
Not that use of tools is required; but definitely an action that involves a conductor and a terminal of a fitting.
This has the effect of excluding actions such as placing a fuse or switching on a circuit breaker; for purposes of determining which particular action counts as 'connection to supply'.
Which matters because whoever does this particular action is required to undertake a whole bunch of checks before making the connection.
And that then carries over to issuing ESC after connection [ESR 74A]
However that definition is tagged "in this regulation"; which means we can't take that definition and apply it more widely.
ESR 4 provides some guidance for terms used in Standards (clause 2), or ESRs (clause 3);
but this time the term is used in the Act so the guidance isn't directly applicable.
In the absence of any specific definition; words take their normal meaning; eg "bring together so as to establish a link" [Oxford Compact Dictionary].
Our installation Standards often use connect / disconnect for switching actions as well as for more permanent methods of connection;
eg fault protection by automatic disconnection of supply is generally the operation of a fuse, circuit breaker or RCD.
This usage comes from IEC; so IEC 60050 also doesn't distinguish between the various forms of connection.
But if we look at Schedule 1 of ESRs, we find that clause 1(1)(c) makes connection / disconnection "other than by means of a plug or pin inserted into a socket" PEW.
Which gives us a clear distinction between 2 forms of "connection" that we can then apply more widely.
I believe that means we have to accept that plugging things in is a form of connection.
From that it's reasonable to interpret "intended to be connected" as meaning plug-in appliances actually present within a CI are part of that CI.
And therefore they are within the scope of a WoEF check - to the extent that the specified checks & tests specified in C6 & C7 of "3001" cover particular aspects.
A CI may also have a battery-powered inverter; and unless the LV output of the inverter is somehow connected to the CI (as defined; ie the LV system that's capable of being supplied from an external LV supply) that separate system isn't subject to WoEF.
But I don't think it would be reasonable to assume that the jug / toaster / hair curler you find in a caravan is only ever going to be plugged into the inverter supply.
which is similar to what you were thinking; and may be why you were thinking it.
Not that use of tools is required; but definitely an action that involves a conductor and a terminal of a fitting.
This has the effect of excluding actions such as placing a fuse or switching on a circuit breaker; for purposes of determining which particular action counts as 'connection to supply'.
Which matters because whoever does this particular action is required to undertake a whole bunch of checks before making the connection.
And that then carries over to issuing ESC after connection [ESR 74A]
However that definition is tagged "in this regulation"; which means we can't take that definition and apply it more widely.
ESR 4 provides some guidance for terms used in Standards (clause 2), or ESRs (clause 3);
but this time the term is used in the Act so the guidance isn't directly applicable.
In the absence of any specific definition; words take their normal meaning; eg "bring together so as to establish a link" [Oxford Compact Dictionary].
Our installation Standards often use connect / disconnect for switching actions as well as for more permanent methods of connection;
eg fault protection by automatic disconnection of supply is generally the operation of a fuse, circuit breaker or RCD.
This usage comes from IEC; so IEC 60050 also doesn't distinguish between the various forms of connection.
But if we look at Schedule 1 of ESRs, we find that clause 1(1)(c) makes connection / disconnection "other than by means of a plug or pin inserted into a socket" PEW.
Which gives us a clear distinction between 2 forms of "connection" that we can then apply more widely.
I believe that means we have to accept that plugging things in is a form of connection.
From that it's reasonable to interpret "intended to be connected" as meaning plug-in appliances actually present within a CI are part of that CI.
And therefore they are within the scope of a WoEF check - to the extent that the specified checks & tests specified in C6 & C7 of "3001" cover particular aspects.
A CI may also have a battery-powered inverter; and unless the LV output of the inverter is somehow connected to the CI (as defined; ie the LV system that's capable of being supplied from an external LV supply) that separate system isn't subject to WoEF.
But I don't think it would be reasonable to assume that the jug / toaster / hair curler you find in a caravan is only ever going to be plugged into the inverter supply.
- Rating: 16.67%