We've recently been told by energy safety portable containors that previously were issued ewofs are not compliant under 3001 C6 C7 due to daisy chain plug configuration breaking main overcurrent rule.
But they can be compliant under 3012 as these containors/TS are always used on building sites.
After a read over peridic verification section seems clear on what verification is required at table 7 shows intervals.
What I'm not about is note 1
"in New Zealand, verification (inspection and testing) intervals for transportable structures do not apply"
Does that mean the entire TS does not need periodically checked?
Or would the rcds and switchboards/ construction wiring still need checked?
Photos attached
Help appreciated
Transportable structure installed to construction demolision standard
Re: Transportable structure installed to construction demolision standard
That Note only affects the intervals, not the requirement for periodic verification.
What the table is doing - or trying to do - is reducing the 4 years set by ESR 78 to 6 months;
and the Note simply points out that this 6-month interval set by the Table does NOT over-ride the interval set by ESR 78.
No Standard can over-ride a regulation.
And that means that EVERY connectable installation must have a current woEF before being connected
- and these types with cascade feature are, quite simply never going to pass the mandated WoEF inspection.
So anyone who issues a WoEF to one is committing an offence.
They don't comply with 3001 in the first place.
And in Oz, that's OK; because they mostly don't need to (this varies a bit, state by state).
But in NZ they do: ESR 60 says every SO must comply with both Part 2 and 3001.
So anyone who has wired one up like this has also committed an offence.
What the table is doing - or trying to do - is reducing the 4 years set by ESR 78 to 6 months;
and the Note simply points out that this 6-month interval set by the Table does NOT over-ride the interval set by ESR 78.
No Standard can over-ride a regulation.
And that means that EVERY connectable installation must have a current woEF before being connected
- and these types with cascade feature are, quite simply never going to pass the mandated WoEF inspection.
So anyone who issues a WoEF to one is committing an offence.
They don't comply with 3001 in the first place.
And in Oz, that's OK; because they mostly don't need to (this varies a bit, state by state).
But in NZ they do: ESR 60 says every SO must comply with both Part 2 and 3001.
So anyone who has wired one up like this has also committed an offence.
Re: Transportable structure installed to construction demolision standard
OK so if I understand correctly the only options are to remove daisy chain outlet to make compliant with 3001
Or
Perm connect to installation to comply with 3012 each time it's moved to a site?
Or
Perm connect to installation to comply with 3012 each time it's moved to a site?
Re: Transportable structure installed to construction demolision standard
OK thanks for clearing that up much appreciated.
Re: Transportable structure installed to construction demolision standard
Hi Alec, I asked a similar question in Nov 2021 about this, it was mentioned if their was overload protection on the "daisy chain outlets" this makes the interconnecting cables like submains so could be ok?
Cheers Peter
Cheers Peter
Re: Transportable structure installed to construction demolision standard
Overload protection is one factor.
Modern CIs must have current limitation such that the current drawn cannot exceed the rating of the supply fittings.
Typically these daisy-chained units do not comply, as the socket intended for plugging in another CI is either teed off at line side of main switch, or directly at the inlet fitting and is unprotected.
That's directly comparable to how an ACS system is set up, and for ACS this pass-through "backbone" is deemed to be a submain, with each unit on the string being a DB teed off the common submain.
There's no requirement for this pass-through submain to be current-limited at each DB it feeds; instead it has overcurrent protection at source, just as a normal fixed-wired submain would.
The ACS backbone is like the 'rising mains" in a high-rise building; except we don't allow those to be set up by plugging units together. ACS is a special case; and CIs don't comply as ACS units. So while it's similar it doesn't mean we can't just call a string of CIs an ACS system.
The ACS system, as specified in App K of "3012"; is fundamentally about an alternative way of providing construction wiring; which would normally be intralled using fixed wiring. So if wanting to adopt this system, you use compliant ACS units, and then plug your CIs into them.
Yes the CI's could be arranged so that the pass-through )backbone" goes through the current-limiting device in each unit.
But that set-up isn't comparable to a submain. The cabling feeding the daisy-chain socket is a final subcircuit, and has to be treated accordingly.
So for daisy-chained CIs, this means the total load of the string of CIs is limited to the rating of the supply fittings of the first unit in the chain.
Which rather limits the usefulness of daisy-chaining ; pretty much to CIs that only have lights. Beyond that you'd need a much heavier 'backbone" cabling, including all the supply leads, plugs, and pass-in sockets. Which is exactly what ACS units have, using different firm & rating of fittings for the submain backbone than for everything else, so that - for example - a CI with a compliant supply lead plug can't be plugged into the backbone outlet of the ACS unit (refer K 5.4).
The other rule these daisy-chained CIs break is that the "pass-through" socket doesn't have RCD protection; and EVERY socket of a CI must have RCD protection (unlike the submain "backbone" of an ACS system).
Older caravans, constructed before "3001" required current limitation & RCD protection - and still having their original N-E links - could potentially be daisy-chained; except that as soon as you make any changes to an older unit you have to bring it up to current requirements, including removing the link, and adding current limitation & RCD protection for all subcircuits.
Further; the opening para of clause 2.9 states that "transportable structures and their site supplies" shall comply with 3001 and with the rest of the clause. That means nothing in the clause relaxes any requirement of "3001" they only add to them. If wanting to modify / amend the underlying requirements (which certainly seems to have been the intention); this opening para would have to instead say "except as permitted by this clause"
So it's just not possible to claim "compliance" by following 2.9(d) (v), & Exception A to 2.9 (d)(i), of "3012".
Certainly not in NZ, and not even in Oz (where in some States wiring a CI isn't even equivalent to our PEW, but can be done by anyone and may not even have to follow "3001").
The only regulatory status "3012" has in NZ is that ESR 25 cites it as means of achieving 'electrically safe' for "electrical installations" on C&D sites - ie for (fixed) construction wiring. It has NO official status at all for the plug-&-play side of things.
It can be used as guidance; but not if that leads to non-compliance with requirements set by Regulation.
By contrast, in NZ anything meeting the definition of 'connectable installation" is required to comply fully with "3001". That's not the case in some States of Oz.
And in NZ all CIs must have a current WoEF before being plugged into supply. Again , not the case in any State of Oz.
The checks & tests specified for issue of WoEF include confirming both current limitation & RCD protection (except for caravans that still have their original N-E link). Anyone who issues a woEF for a daisy-chain CI hasn't followed the requirements; and the WoEF is not valid.
One wonders how such a person ever became an Inspector, since the WoEF checklist in App C is very clear.
Modern CIs must have current limitation such that the current drawn cannot exceed the rating of the supply fittings.
Typically these daisy-chained units do not comply, as the socket intended for plugging in another CI is either teed off at line side of main switch, or directly at the inlet fitting and is unprotected.
That's directly comparable to how an ACS system is set up, and for ACS this pass-through "backbone" is deemed to be a submain, with each unit on the string being a DB teed off the common submain.
There's no requirement for this pass-through submain to be current-limited at each DB it feeds; instead it has overcurrent protection at source, just as a normal fixed-wired submain would.
The ACS backbone is like the 'rising mains" in a high-rise building; except we don't allow those to be set up by plugging units together. ACS is a special case; and CIs don't comply as ACS units. So while it's similar it doesn't mean we can't just call a string of CIs an ACS system.
The ACS system, as specified in App K of "3012"; is fundamentally about an alternative way of providing construction wiring; which would normally be intralled using fixed wiring. So if wanting to adopt this system, you use compliant ACS units, and then plug your CIs into them.
Yes the CI's could be arranged so that the pass-through )backbone" goes through the current-limiting device in each unit.
But that set-up isn't comparable to a submain. The cabling feeding the daisy-chain socket is a final subcircuit, and has to be treated accordingly.
So for daisy-chained CIs, this means the total load of the string of CIs is limited to the rating of the supply fittings of the first unit in the chain.
Which rather limits the usefulness of daisy-chaining ; pretty much to CIs that only have lights. Beyond that you'd need a much heavier 'backbone" cabling, including all the supply leads, plugs, and pass-in sockets. Which is exactly what ACS units have, using different firm & rating of fittings for the submain backbone than for everything else, so that - for example - a CI with a compliant supply lead plug can't be plugged into the backbone outlet of the ACS unit (refer K 5.4).
The other rule these daisy-chained CIs break is that the "pass-through" socket doesn't have RCD protection; and EVERY socket of a CI must have RCD protection (unlike the submain "backbone" of an ACS system).
Older caravans, constructed before "3001" required current limitation & RCD protection - and still having their original N-E links - could potentially be daisy-chained; except that as soon as you make any changes to an older unit you have to bring it up to current requirements, including removing the link, and adding current limitation & RCD protection for all subcircuits.
Further; the opening para of clause 2.9 states that "transportable structures and their site supplies" shall comply with 3001 and with the rest of the clause. That means nothing in the clause relaxes any requirement of "3001" they only add to them. If wanting to modify / amend the underlying requirements (which certainly seems to have been the intention); this opening para would have to instead say "except as permitted by this clause"
So it's just not possible to claim "compliance" by following 2.9(d) (v), & Exception A to 2.9 (d)(i), of "3012".
Certainly not in NZ, and not even in Oz (where in some States wiring a CI isn't even equivalent to our PEW, but can be done by anyone and may not even have to follow "3001").
The only regulatory status "3012" has in NZ is that ESR 25 cites it as means of achieving 'electrically safe' for "electrical installations" on C&D sites - ie for (fixed) construction wiring. It has NO official status at all for the plug-&-play side of things.
It can be used as guidance; but not if that leads to non-compliance with requirements set by Regulation.
By contrast, in NZ anything meeting the definition of 'connectable installation" is required to comply fully with "3001". That's not the case in some States of Oz.
And in NZ all CIs must have a current WoEF before being plugged into supply. Again , not the case in any State of Oz.
The checks & tests specified for issue of WoEF include confirming both current limitation & RCD protection (except for caravans that still have their original N-E link). Anyone who issues a woEF for a daisy-chain CI hasn't followed the requirements; and the WoEF is not valid.
One wonders how such a person ever became an Inspector, since the WoEF checklist in App C is very clear.
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Re: Transportable structure installed to construction demolision standard
In terms of issuing a Woef, I can see how it fails regarding overcurrent protection (as per C6.4). Is there actually a requirement for RCD protection though? (assuming it’s not a caravan).
Only C6.9(a) applies to non-caravans. (b) - (d) is for caravans only. And C6.11 only applies to caravans. Nothing here seems to indicate an RCD check is required.
I understand that if a (non caravan) CI was being constructed IAW section 3 of 3001, RCD protection would be required, but perhaps it’s not required for a Woef check?
Perhaps there was a time when no RCD Protection and no MEN link was permitted for porta-coms and the like?
Only C6.9(a) applies to non-caravans. (b) - (d) is for caravans only. And C6.11 only applies to caravans. Nothing here seems to indicate an RCD check is required.
I understand that if a (non caravan) CI was being constructed IAW section 3 of 3001, RCD protection would be required, but perhaps it’s not required for a Woef check?
Perhaps there was a time when no RCD Protection and no MEN link was permitted for porta-coms and the like?
Re: Transportable structure installed to construction demolision standard
True; but C 6.9 is not about RCD protection; it's about supply arrangements.
The only reason it mentions RCDs is because the presence / location of RCD protection can affect two aspects of the supply arrangement:
- whether an N-E link is permitted; and
- whether the lead can be detachable.
RCD protection is assumed, simply because all units built to comply with '3001" have always been required to gave it.
Only caravans have ever had N-E links (which was due to the un-reliabilty of earthing using the old scraping-earth plugs / connectors / inlets).
Pre 1993, the likes of refrigerated trucks were treated as "semi-portable appliances.
Back then, nobody ever used plug-in connection for site huts & similar.
That was first allowed under 1997 Regs, which cited "3001: 2001" from 1/1/2003.
So any site hut ever built as a CI has always had to have RCD protection of all final subcircuits.
C 6.10 requires some aspects of these RCDs to be checked.
Not specifically including that they cover all final subcircuits; because there has never been any other valid option.
And C 7. requires those RCDs to be tested.
Note that the test required is "in accordance with Section 8 of AS/NZS 3000"; and that's not just that the RCD operates, but that it disconnects the circuit(s). So if any circuit doesn't get disconnected, then that's a fail.
-------------------
There has been a series of cases before EWRB, where the Inspector has issued a WoEF but hasn't followed the provisions of App C.
In some cases, they haven't checked the RCD type, and in some they haven't done any testing of the RCD.
So we should perhaps not be surprised that some site huts set up for daisy-chaining have been issued with WoEFs; as clearly there's a worrying number of people who hold an "Inspector" PL - but clearly shouldn't.
The only reason it mentions RCDs is because the presence / location of RCD protection can affect two aspects of the supply arrangement:
- whether an N-E link is permitted; and
- whether the lead can be detachable.
RCD protection is assumed, simply because all units built to comply with '3001" have always been required to gave it.
Only caravans have ever had N-E links (which was due to the un-reliabilty of earthing using the old scraping-earth plugs / connectors / inlets).
Pre 1993, the likes of refrigerated trucks were treated as "semi-portable appliances.
Back then, nobody ever used plug-in connection for site huts & similar.
That was first allowed under 1997 Regs, which cited "3001: 2001" from 1/1/2003.
So any site hut ever built as a CI has always had to have RCD protection of all final subcircuits.
C 6.10 requires some aspects of these RCDs to be checked.
Not specifically including that they cover all final subcircuits; because there has never been any other valid option.
And C 7. requires those RCDs to be tested.
Note that the test required is "in accordance with Section 8 of AS/NZS 3000"; and that's not just that the RCD operates, but that it disconnects the circuit(s). So if any circuit doesn't get disconnected, then that's a fail.
-------------------
There has been a series of cases before EWRB, where the Inspector has issued a WoEF but hasn't followed the provisions of App C.
In some cases, they haven't checked the RCD type, and in some they haven't done any testing of the RCD.
So we should perhaps not be surprised that some site huts set up for daisy-chaining have been issued with WoEFs; as clearly there's a worrying number of people who hold an "Inspector" PL - but clearly shouldn't.
Re: Transportable structure installed to construction demolision standard
Probably where the confusion comes from and how the manufacturers interpret 3012 clause 2.9 (a) "supply shall not be taken from a socket outlet associated with one transportable structure to supply another structure except where item (e) applies". (e) is "all components of an interconnecting supply system ....."
3012: clause 2.9 (d) mentions about "socket outlets installed on the outside of the TS shall be protected by an RCD...." with an exception (A) then referring to clause 2.9 (d) (iv) which then takes you to (e)
So it is confusing I feel
3012: clause 2.9 (d) mentions about "socket outlets installed on the outside of the TS shall be protected by an RCD...." with an exception (A) then referring to clause 2.9 (d) (iv) which then takes you to (e)
So it is confusing I feel
Re: Transportable structure installed to construction demolision standard
Have to agree it's confusing.
Seems to me the writers wanted to allow for cascading, but failed to do a proper job of it.
But even if they'd done it correctly; ESRs would still over-ride any such provision.
Especially while ESRs define any collection of 2 or more sockets intended for CIs as a "caravan park".
Seems to me the writers wanted to allow for cascading, but failed to do a proper job of it.
But even if they'd done it correctly; ESRs would still over-ride any such provision.
Especially while ESRs define any collection of 2 or more sockets intended for CIs as a "caravan park".