Are all EV charge point installers this bad?

[Mike Johnson]

What's the difference between a Hazard analysis and a risk assessment when dealing with this scenario.

They are two entirely different things in the scheme of Health and Safety, a Hazard analysis is always done first and then a risk assessment if necessary, it not always the case that the hazard has to be managed, the difference between the two are often miss-understood.

 

[mainline]

They are two entirely different things in the scheme of Health and Safety, a Hazard analysis is always done first and then a risk assessment if necessary, it not always the case that the hazard has to be managed, the difference between the two are often miss-understood.

An electrical hazard analysis identifies dangers that are present in an electrical system.

Mike Johnson said:
If, as should be done, a Hazard Analysis is carried out first and concludes that the Hazard does not exist or is of a very low consequence, then a Risk Assessment does not have to be carried out.


Are you saying that if there are no electrical hazards, then a risk assessment for fitting an SPD is not required ?

 

[Mike Johnson]

The first order of business in any H&S protocol is to eliminate the Hazard, If there is no hazards then a risk assessment is not required.

 

[DPG]

The first order of business in any H&S protocol is to eliminate the Hazard, If there is no hazards then a risk assessment is not required.

But you can't eliminate the chance of voltage surges, so a risk assessment is the thing to do.

 

[loz2754]

But you can't eliminate the chance of voltage surges, so a risk assessment is the thing to do.

There is no allowance for a risk assessment for the installation of SPDs anymore.

 

[DPG]

There is no allowance for a risk assessment for the installation of SPDs anymore.

True, but I think most of this discussion has been around the previous guidelines/regs.

 

[mainline]

There is no allowance for a risk assessment for the installation of SPDs anymore.

The AQ criteria (conditions of external influence for lightning) for determining if protection against transient overvoltages is needed are no longer included in BS 7671. Instead, protection against transient overvoltages has to be provided where the consequence caused by overvoltage (see Regulation 443.4)

(a) results in serious injury to, or loss of, human life, or
(b) results in interruption of public services/or damage to and cultural heritage, or
(c) results in interruption of commercial or industrial activity, or
(d) affects a large number of co-located individuals.

For all other cases, a risk assessment has to be performed in order to determine if protection against transient overvoltage is required.

 

[loz2754]

The AQ criteria (conditions of external influence for lightning) for determining if protection against transient overvoltages is needed are no longer included in BS 7671. Instead, protection against transient overvoltages has to be provided where the consequence caused by overvoltage (see Regulation 443.4)

(a) results in serious injury to, or loss of, human life, or
(b) results in interruption of public services/or damage to and cultural heritage, or
(c) results in interruption of commercial or industrial activity, or
(d) affects a large number of co-located individuals.

For all other cases, a risk assessment has to be performed in order to determine if protection against transient overvoltage is required.

You appear to be quoting the previous version of BS7671 here.

This is an extract from Amendment 2:

443.4 Overvoltage control

443.4.1 Transient overvoitages due to the effects of indirect lightning strokes

Protection against transient overvoltages shall be provided where the consequence
caused by the overvoltage could result in:

(i) serious injury to, or loss of, human life
(ii) failure of a safety service, as defined in Part 2
(iii) significant financial or data loss.

For all other cases, protection against transient overvoltages shall be provided unless the owner of the installation declares it is not required due to any loss or damage being tolerable and they accept the risk of damage to equipment and any consequential loss.

 

[mainline]

You appear to be quoting the previous version of BS7671 here.

This is an extract from Amendment 2:

443.4 Overvoltage control

443.4.1 Transient overvoitages due to the effects of indirect lightning strokes

Protection against transient overvoltages shall be provided where the consequence
caused by the overvoltage could result in:

(i) serious injury to, or loss of, human life
(ii) failure of a safety service, as defined in Part 2
(iii) significant financial or data loss.

For all other cases, protection against transient overvoltages shall be provided unless the owner of the installation declares it is not required due to any loss or damage being tolerable and they accept the risk of damage to equipment and any consequential loss.

Try chapter 44 Protection against voltage disturbances and electromagnetic disturbances.

 

[loz2754]

True, but I think most of this discussion has been around the previous guidelines/regs.

I just skimmed the whole thread again, and you're correct, it dates back to before Amendment 2.
However, in the context of whether an SPD should have been fitted to an EV charge point, the previous version states that if a risk assessment is not carried out (and documented), then an SPD shall be fitted.

So the installer had no real reason not to fit one, unless they produced a documented risk assessment.

 

[loz2754]

Try chapter 44 Protection against voltage disturbances and electromagnetic disturbances.

What do you think I just copied and pasted from?

 

[mainline]

What do you think I just copied and pasted from?

Page 5

Chapter 44 Protection against voltage disturbances and electromagnetic disturbances

Section 443, which deals with protection against overvoltages of atmospheric origin or due to switching, has been redrafted.

The AQ criteria (conditions of external influence for lightning) for determining if protection against transient overvoltages is needed are no longer included in BS 7671. Instead, protection against transient overvoltages has to be provided where the consequence caused by overvoltage (see Regulation 443.4)

(a) results in serious injury to, or loss of, human life, or
(b) results in interruption of public services/or damage to and cultural heritage, or
(c) results in interruption of commercial or industrial activity, or
(d) affects a large number of co-located individuals.

For all other cases, a risk assessment has to be performed in order to determine if protection against transient overvoltage is required.

There is an exception not to provide protection for single dwelling units in certain situations.

 

[loz2754]

Page 5

Chapter 44 Protection against voltage disturbances and electromagnetic disturbances

Section 443, which deals with protection against overvoltages of atmospheric origin or due to switching, has been redrafted.

The AQ criteria (conditions of external influence for lightning) for determining if protection against transient overvoltages is needed are no longer included in BS 7671. Instead, protection against transient overvoltages has to be provided where the consequence caused by overvoltage (see Regulation 443.4)

(a) results in serious injury to, or loss of, human life, or
(b) results in interruption of public services/or damage to and cultural heritage, or
(c) results in interruption of commercial or industrial activity, or
(d) affects a large number of co-located individuals.

For all other cases, a risk assessment has to be performed in order to determine if protection against transient overvoltage is required.

There is an exception not to provide protection for single dwelling units in certain situations.

Ah, I see where you're coming from.
I believe that section of page 5 is actually an error and should have been removed or reworded, as it is exactly the same as it is in the blue book. It contradicts what is actually said in section 443. It's only an introduction to BS7671:2018, and you'll notice the whole introduction is exactly the same as it is in the blue book, and makes no reference to the changes brought in with Amendment 2.

Also the On Site Guide pages 43 and 44 are in error.

 

[Mike Johnson]

But you can't eliminate the chance of voltage surges, so a risk assessment is the thing to do.

If the hazard analysis identifies a voltage surge as being possible? (with the main input isolated?) Then the next stage is the risk assessment.

 

[loz2754]

If the hazard analysis identifies a voltage surge as being possible? (with the main input isolated?) Then the next stage is the risk assessment.

You seem to have a thing about this Mike!
I'm afraid I have to disagree with your treating the hazard analysis as a precursor to a risk assessment.
According to the steps outlined in many guides to risk assessment, the hazard analysis is the first step of the risk assessment process and it's therefore a part of the risk assessment, not a separate process.
May be just semantics, as the end result is the same.
An example downloaded from HSE:

 

[Mike Johnson]

The reason the hazard analysis is a precursor to the risk assessment is if the analysis is able to eliminate the hazard the risk assessment is not needed.

 

[catdog1121]

As this has been dragged back up I will give an update..

Pod point eventually agreed to fit an SPD, I provided a 40A mcb in consumer unit, to a small 4way consumer unit with a double pole 32A RCBO with an SPD next to it, during install I was present and had to point out that the electrician had wired the SPD the wrong way round, I needed to then provide him with 6mm WAGO connectors as he cut the cables to short..

All good, but then no certificate, I chased and was sent the EIC, when I asked for the building regs certificate they said they would resend it, nothing came so I chased again and was told nothing to do with them and I needed to go to my local authority... I contacted NICEIC who were really good and checked, they had raised two building regs certificates so they deleted one and sent me a copy of the other...

Several months on I contact WPD to ask if they have sent paperwork for unlooping, nothing sent, I chase and ask them to send, after months of checking with WPD last month I finally got annoyed escalated it to pod point and they admitted they had not sent it as some MPAN number was wrong, I guess they were just going to do nothing with this even though they had a duty to inform WPD of the looped supply... Eventually that was sorted and I got a call from WPD within a week and they are going to extend the cable in the street and dig up my garden to run a new 3 phase supply to just outside the front door where they hope to intercept the loop cable, splicing the new cable on to that and terminating the other end coming from the neighbour so they dont need to be disturbed..

As for SPD's, well I went to many seminars and got told from the horses mouth by the guy involved in writing the regs from the IET, if you install a new circuit you must fit an SPD unless customer refuses, they cannot refuse on certain circuits... Move on to my NAPIT assessment and I get told an SPD is only needed if you change a consumer unit, if you are adding a new circuit to an existing consumer unit then its not needed, this was completely contradictory to what NAPIT confirmed with me when dealing with the EV charger..

So it seems like the powers that be can't decide, from a personal note with everyone doing their own electrics or getting dodgy electricians coming in I am putting electrical work on the back burner and going back into IT as a contractor for a bit as the work has dried up well unless you want to sign off some DIY'rs bodge job, I want to do a decent job but nobody wants to pay for it or appreciate it, I think ill still keep my insurance but will be dropping NAPIT as the cost just keeps going up and I don't get enough work that requires certification to warrant keeping it especially as ill mainly be doing IT contracting.. I guess the cost of living is hitting everyone so house building has stopped, nobody is getting extensions etc..

 

[nicebutdim]

True, but I think most of this discussion has been around the previous guidelines/regs.

That's what I'd been trying to ascertain as the thread has been resurrected long since introduction of AM2, with statements being made that no longer apply.

I believe it's important that this distinction is made clear as, from other threads, it sould seem as though the member who resurrected the thread is (at the very least) keen to advise the electrician rewiring their property. It would be remiss of us to allow someone to labour under the misapprehension that a previous version of BS7671 is still relevant on this subject and to press their electrician toward a non-compliant installation.

 

[nicebutdim]

Try chapter 44 Protection against voltage disturbances and electromagnetic disturbances.

@loz2754 just quoted 443.4.1 from Chapter 44.

Oddly enough 3.7.2.1 of the new OSG quotes the very same regulation verbatim and then goes on to expand upon it with further advice that I can not find within the BB(rown)B.

Advice from OSG appears to deviate slightly from BBB, but the distinction is quite significant.

 

[nicebutdim]

The reason the hazard analysis is a precursor to the risk assessment is if the analysis is able to eliminate the hazard the risk assessment is not needed.

In the case of transient voltages due to the effects of indirect lightning strikes, how would one go about arguing that no hazard exists or eliminating the hazard entirely, without installing surge protection?

 

[Midwest]

I suppose like all proof reading of publications, errors don't always get picked up. Seem to recall, has happened previously with BS7671.

 

[nicebutdim]

I suppose like all proof reading of publications, errors don't always get picked up. Seem to recall, has happened previously with BS7671.

The additional information is lengthier than the regulation quoted before it. Worth looking at if you have both books to hand.

I'd quote it, but it's a lot to type.

 

[loz2754]

@loz2754 just quoted 443.4.1 from Chapter 44.

Oddly enough 3.7.2.1 of the new OSG quotes the very same regulation verbatim and then goes on to expand upon it with further advice that I can not find within the BB(rown)B.

Advice from OSG appears to deviate slightly from BBB, but the distinction is quite significant.

It's an error, which I pointed out to the NICEIC instructor on my Amendment 2 course. He wasn't aware of it, but agreed that the OSG had retained a whole section that should have been deleted.

 

[mainline]

@loz2754 just quoted 443.4.1 from Chapter 44.

Post #62

 

[Mike Johnson]

The reason the hazard analysis is a precursor to the risk assessment is if the analysis is able to eliminate the hazard the risk assessment is not needed.

In the case of transient voltages due to the effects of indirect lightning strikes, how would one go about arguing that no hazard exists or eliminating the hazard entirely, without installing surge protection?

Don't think of your individual situation think more global, think hazard first, identify and eliminate if possible, if not then complete a risk assessment.

 

[nicebutdim]

Don't think of your individual situation think more global, think hazard first, identify and eliminate if possible, if not then complete a risk assessment.

I get where you're coming from, but was (not unreasonably) referring specifically to the situation in this thread.

 

[Mike Johnson]

I was just trying to clarify for those that don't know that a Hazard Analysis is separate from the Risk Assessment and is carried out first with the main aim to eliminate the Hazard.

 

[nicebutdim]

I was just trying to clarify for those that don't know that a Hazard Analysis is separate from the Risk Assessment and is carried out first with the main aim to eliminate the Hazard.

Which is the ideal (if infrequent) situation.

 

[mainline]

 

[DPG]

Process:
Step 1. Stop dicking about
Step 2. Spend £25 extra for an SPD

 

[Mike Johnson]

Which is the ideal (if infrequent) situation.

Can't agree with that, it is either carried out correctly to leave a paper trail that can be followed, or just ignored or carried out incorrectly, in most industries where Hazard Analysis and Risk Assessments are carried out on a regular basis that trail is essential to comply with Health and Safety legislation.

It is often quoted on this forum about standing in the dock answering the questions from the judge, how do you prove you carried out your obligations in accordance with the regulations, the same applies to Health and Safety, can't have it that way for one piece of legislation and not for others.

 

[nicebutdim]

Can't agree with that, it is either carried out correctly to leave a paper trail that can be followed, or just ignored or carried out incorrectly, in most industries where Hazard Analysis and Risk Assessments are carried out on a regular basis that trial is essential to comply with Health and Safety legislation.

It is often quoted on this forum about standing in the dock answering the questions from the judge, how do you prove you carried out your obligations in accordance with the regulations, the same applies to Health and Safety, can't have it the one way for one piece of legislation and not for others.

Not sure if I worded the last post badly, but I was expressing the opinion that (in my experience) it is rare that hazards can be eliminated. I work extensively in a particularly 'risk averse' industry and have yet to see a permit issued on the basis that all hazards have been eliminated. The simplest job requires a risk assessment and without that no permit will be issued for work to be carried out.

 

[Mike Johnson]

This is were it all gets a bit confusing for most people, if the Hazard has been eliminated a permit is not needed and therefore the trail would not be visible, the simplest job requires a Hazard analysis first.

 

[mainline]

This is were it all gets a bit confusing for most people, if the Hazard has been eliminated a permit is not needed and therefore the trail would not be visible, the simplest job requires a Hazard analysis first.

Yes you're right, this is getting a bit confusing because on the one hand you say if no Hazard then no risk assessment is required and would leave no paper trail.

Then you say Risk assessments are essential to comply with HSL, and go on to say

“It is either carried out correctly to leave a paper trail that can be followed, or just ignored or carried out incorrectly”

“That trail is essential to comply with Health and Safety legislation.”

It is often quoted on this forum about standing in the dock answering the questions from the judge, how do you prove you carried out your obligations in accordance with the regulations, the same applies to Health and Safety, can't have it that way for one piece of legislation and not for others.”




I can't think of any scenario that wouldn't have some sort of hazard.

Risk assessments are a legal requirement. At least, they are a legal requirement at work. In fact, risk assessment is so important it has its own section under the Management of Health and Safety at Work Regulations.

 

[Mike Johnson]

It is quite a simple process, if you believe a Hazard exists then an Analysis should be done, if at the conclusion of this Analysis this conclusion is the Hazard has been eliminated then no further measures are required, if however the conclusion is the second measure of "Control at source" then a Risk Assessment should be carried out to specify that "Control" can't remember the order of the third and forth measures order, but PPE is one of the lower ones and if I remember correctly the last is "Prepare a Method Statement" the Hazard Analysis process is judged by Likelihood/Risk with a High/Medium/Low probability under each section, if you don't understand this process perhaps some training is required.

Since the introduction of the Health and Safety Regulations in 1974 there have been numerous additions and refinements to the process including the "Construction Design and Management" regulations, updated twice since their introduction, these CDM regulations put the onus on designers to eliminate risk.