# Interest group forums > Electrical Contracting Industry Forum >  Issuing electrical COCs - On a hiding to nothing!

## Dave A

Having anything to do with the issue of an Electrical Certificate of Compliance when a property is sold can be an absolute nightmare at times. Here's one case that has me really scratching my head.

We get a written instruction to test the electrical installation of a flat - which we duly do, issue faults report, which is authorised, carry out repairs and issue a COC *on the electrical installation in the flat*. To be specific, the COC sets out the rooms, number of various electrical points, DB, etc. Very specific. Sale goes through - everyone gets their money - purchaser moves in and things start getting exciting.

We get called back because there are a number of problems.

It transpires that we have not tested and issued a COC on all portions of the property that has been sold. There is a garage and flatlet at the bottom that forms part of the sale agreement. At no point was this indicated to us in any way, means or form, and ordinarily this would all be relatively simple to establish where responsibility for this tidy little mess would lie - but not so lucky in this instance.

Now to give a better picture, this "block of flats" is really a house subdivided into residential units - and anyone who has seen such conversions will understand what I'm getting at here; it is quite often far from obvious just what parts make up a unit. With this one I still haven't managed to establish whether there are two or three residential units in the building. I haven't been out to take a look as yet. My partner has been dealing with it.

And here is where things start to get really messy.

All the garages, the flatlet in question, a pool, some of the buildings external lights and all the geysers are fed off a distribution board in one of the garages. This distribution board is fed off the distribution board in the flat we tested and issued a COC on. There is a redundant circuit breaker in the flat's DB marked sub-board - but no feed going off it. For some reason this sub-DB is being fed of a plug circuit breaker - along with a number of plugs in the flat.

So based on this, we are expected to figure out that there was a lot more that should have been tested. But wait - there's more.

Mrs. Purchaser is also the conveyancer for the transaction. Mr. Purchaser is an electrician.

Mrs. Purchaser, as the conveyancor, received all our documentation (well before transfer) which, as pointed out earlier is rather specific about what we've issued a COC on.

Mr. Purchaser is actually quite understanding of the difficulties of testing for COCs - that's why he doesn't do that particular line of business.

The seller, who has not satisfied the sales agreement or the law (essentially sold "electrical machinery" without a COC as required), is not taking calls and is not returning messages.

I'm still waiting on a ruling as to whether we're responsible for the subinstallation we did not issue a COC on. 

Mr. & Mrs. Purchaser just want their COC on the flatlet and garage like yesterday because they're in the middle of alterations and have already technically invalidated the COC we _have_ issued. They've already managed to remove a wall and wreck a light circuit in the process, and the painters have all the plug point covers off.

And I've got to make it happen!?  :Surrender:

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## Yvonne

So many "cases" are decided on a "reasonable expectation" - This seems like an outright case of "deliberate concealment" of information, and any resulting dispute to your company, would surely be upheld by any fair legal process!.

Yvonne

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## Dave A

> So many "cases" are decided on a "reasonable expectation"


Scary, isn't it. This should be clear cut based on contract and regulations.

I've got a clear understanding of where things stand in terms of contract law. At the moment I'm *still* waiting for someone to tell me if we are responsible by virtue of the installation regulations for parts of the electrical installation where we have neither done any work nor have issued the COC.

I've also got every sympathy for the purchaser - they should simply *not* be sitting with this problem. But that doesn't mean it's my duty to resolve the problem merely because it's unfair on them.

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## murdock

this is the reason why i cannot do a COC for R450.00.

if you do the COC correctly you should have opened all the plugs and light switces...not only to trace the wires but also to make sure that the correct size wiring has been used  between the plugs and lights.

but the reality of it is that you would be out of bussiness in a short period of time...you would be the most expensive tester in SA.

the other problem is that there is nobody to enforce the law...i have contacted from the ECA to the department of labour and reported installations which have been tested and i have been told to contact the company responsible for the test and ask them to rectify the problem...what a joke.

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## Dave A

I seem to have resolved whether we are responsible for the untested section by virtue of the regulations. As usual, it is the extreme example that gives the clue.

The catch phrase goes "A COC covers from the point of supply to the point of consumption." I'd propose it should be the other way round - It covers from the point of consumption to the point of supply! And this is why.

Current practice is that when you install a new point of consumption, for example a plug point, you are required to issue a COC for that new portion of the installation. And in so doing you are now responsible for the compliance from that point of consumption all the way back to the point of supply. But you are not responsible for other branches downstream of the installation elements that the power for your point passes through.

Essentially, this means that any COC is a collection of points of consumption sharing a common point of supply, and covers all the elements of the electrical installation between those points of consumption and the point of supply. 

Any other interpretation means we are being inconsistent.

In this instance then - no COC issued on the sub-board and its point of supply.
Seller has failed to provide a COC on portions of the installation.
If DoL should be acting against anybody - it should be the seller!

Of course, the responsible person (wireman) is responsible for any non-compliance issues in the portions where a COC *has* been issued.

I have to agree with murdock's post. There seems to be little doubt that when it comes to interpretation and application of the regulations, the powers that be seem to be unduly influenced by who is involved. And it was shown up in this case. At this point I'll just say there were conflicting opinions from the powers that be.

So our position is defendable if taken to DoL, but given the low cost of the repairs involved and the hassle of the defence, we have resolved to carry out the repairs required on the sub-installation anyway.

As I said - On a hiding to nothing!

The seller is still not taking calls or returning messages BTW.

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## murdock

we have a whole lot of new problems with regards to COCs...the STANDBY GENERATOR...the so called experts suppling and installing them from lawn mover sales man to computor data cable installers...i am yet to find someone who understands all the legislation with regards to generators and installations ...i have found some documantation but it is vague.

i wont even go into detail with regards to the other specialists who do electrical installations:

gate installers...pool pump specialists...aircon specialists...builders...the list just goes on.

what gets me are the customers who get unskilled or unqualified people to carry out electrical work...why because they are cheap...then when you have to repair the work dont understand why now after it has worked for 100 years you have to now replace and or repair it   :Yawn:

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## murdock

dave 
what you should have done...what everyone else is doing is just fitted a plug top to the cable feeding the outbuiding and you are no longer responsible...it no longer forms part of the installation...time and money saved.

what i find so amazing about this COC is the fact that anyone can do electrical work and get away with it until a licensed electrician comes along then suddenly all the blame lands on his shoulders...an example... a person can fit a tv aerial nobody puts an earth wire... its not a problem until the house is sold then the wireman must fit an earth and if he doesnt then he is responsible for not fitting the earth why is the aerial installer not bought to book.

i did a COC a little while ago and the DB wasnt just covered by the kitchen cupboards there was no access i had to remove a shelf and cut just to get the cover off...the kitchen was revamped less than 2 years ago...the aircons were fitted with isolators outside which were not weather proof...the aerial had no earth...outside lights connected with cabtyre...geyser had been replaced and there was no bonding between hot and cold and no earth etc etc...the old exsisting installation was the only part legal and wired correctly...all the replacement and new parts of the installation were illegal...problem is there is no recourse on the people who created all the faults listed...because it is just to much of a hassle to track them down and prove they actually did it...so they get away with it...and just make it that much more difficult for people like myself to make an honest days living...having to pay all the levies...taxes...uif...workmans comp...etc...etc....etc.

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## Dave A

> problem is there is no recourse on the people who created all the faults listed...because it is just to much of a hassle to track them down and prove they actually did it...so they get away with it...and just make it that much more difficult for people like myself to make an honest days living...


Now that is a rather astute observation. This sounds like something that the authorities should be *really* focusing on!

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## murdock

surely your COC only cover the part of the installation which you fill in on in section 3 "description of installation covered by the this certificate" and not the entire installation and all additions done by other people...if you clearly state eg 5 plugs 2 light and 1 sub db what more could they ask for otherwise it becomes open book for all installation electricians to get NAILED... not that it will ever happen but rather be safe than sorry.

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## Dave A

Thank you Murdock  :Clap: 
My understanding of this exactly!

However, when the correct definition of the extent of responsibility doesn't suit, it's amazing how creative people can be to try to find alternative definitions.

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## murdock

a typical example...i have just finished a complete rewire of an old house i do all the tests and hand over the coc i go back to remove the masking tape label and  stick the permanent label on the DB i see new tv aerial and of course no earthing...well try sue me for this...i wish somebody would try...the person who installed the aerial and the copmany should be held responsible for his action and i would say a R20000.00 fine would make him think the next time he installs one...but unfortunately in the real world some installation electrician will be held responsible when the house gets sold...i am just getting soooooooo tired of this kind of cr*p.

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## 1reniernel

Hi,

Pay special attention to the identification and demarcation of the DBs and the circuits, during the preparation to enable you to issue a CoC.
Do NOT use the labels that you can buy over the counter (i.e "PLUGS", "LIGHTS", etc)for larger installations, but rather "connect-by-notation",
all of the DBs and circuits.

By doing so, the electricity itself will become naked to you, which mean that not even a single circuit can hide from you. Sounds like a lot of
extra work, but the client are obliged to pay for it. How?      

SECTION 3 of the Inspection and Test Report, give you as a registered person, the right to describe the installation in detail. Your issued CoC
can only be as complete as your description of the installation. Basically a CoC is the placing of an electrical installation on PAPER.

Because of the incapable, corrupt authorities, we need to cover for ourselves in a professional manner, leaving no loopholes at all.
If this highly potent system of "connecting-by-notation" is crab, then I wouldn't be able to simultaneously do the CoCs of six
large factories. Not a single circuit can escape this method. (The inspection is done at the same time when doing the identification
and demarcation, and the obvious short comings recorded.)

Another thing: DO NOT include machinery into the CoC. Cut-off the CoC right there by the isolator of the machine. Why?
Machines are "appliances" (hie-hie), and fall under the Machinery Regulations. You are only expected from, to make sure that the
machine indeed have an isolator on or nearby it, and that it is earthed and have the required bonding conductors, where applicable.
Naturally I also connect between machine and DB by notation.

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## Sparks

> Hi,
> 
> Machines are "appliances" (hie-hie), and fall under the Machinery Regulations.


Not quite. The integral wiring of appliances, depending on the length thereof, just may form part of the COC. :Yes:

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## bergie

slightly off topic,section 4 of the new cocs inspection and tests page 5  line 15 : reticulation installations . whats that about?

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## Sparks

Exactly that, reticulation. You would find reticulation at a complex or large factory premises where there is a "network" of cables.

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## 1reniernel

> Not quite. The integral wiring of appliances, depending on the length thereof, just may form part of the COC.


Can you perhaps give me an example of an appliance of which integral wiring must be included in the CoC?

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## Sparks

An eyelevel oven with a hob connected to it more than 1m away, the interconnecting cables form part of the COC. The COC does not end at the first point of termination. The actual oven and hob however are still not part of the COC.

The connecting cables of a split unit aircon unless mounted back to back will also qualify.

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## Leecatt

> dave 
> what you should have done...what everyone else is doing is just fitted a plug top to the cable feeding the outbuiding and you are no longer responsible...it no longer forms part of the installation...time and money saved..


Ive heard of this before and actually seen it about 8 years ago. However I read in an electrical Magazine, could have been Sparks, that it would be contested and the electrician would be found responsible for the alienated circuitry. I can no longer find the relevant article but the following portion of the Electrical Regulations seem to back this up, unless I am reading it wrong. Comments more than welcome to clear this up.


"electrical installation" means any machinery, in or on any premises, used for the transmission of electricity from a point of control to a point of consumption anywhere on the premises, including any article forming part of such an electrical installation irrespective of whether or not it is part of the electrical circuit, but excluding..........(not relevant)

Full regulations here
http://www.labour.gov.za/downloads/l...egulations.doc

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## Sparks

Spot on Leecatt

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## murdock

so tell me how a ready board works...in low cost housing...1 db...3 plugs and you know the rest...

please show me typical cases where the AIA or DOL have enforced this ruling.

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## Dave A

> An eyelevel oven with a hob connected to it more than 1m away, the interconnecting cables form part of the COC. The COC does not end at the first point of termination. The actual oven and hob however are still not part of the COC.
> 
> The connecting cables of a split unit aircon unless mounted back to back will also qualify.


Does this mean it can't be done in cabtyre exceeding a certain length?
(3 metres)?

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## Sparks

It means that where integral wiring exceeds 1m in length, that integral wiring also forms part of the certifiable installation and must comply with the applicable regs.

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## murdock

aircons are a good example...they use to only use cabtyre...but inoticed on the project we are busy with they are using 2.5 x 4 core surfix

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## Dave A

> It means that where integral wiring exceeds 1m in length, that integral wiring also forms part of the certifiable installation and must comply with the applicable regs.


 :Hmmm:  I've just raised this with my wireman and he's scratching his head - there's nothing about this in the airconditioning section of fixed appliances.
What is the applicable reg?

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## Leecatt

> I've just raised this with my wireman and he's scratching his head - there's nothing about this in the airconditioning section of fixed appliances.
> What is the applicable reg?


1./ I understand the following to mean that the wiring between different parts of the same appliance that exceed 1,5 meters are to be considered as part of the electrical installation and subject to SANS requirements:

_6.16.1.1 Fixed appliances do not form part of the electrical installation other than their positioning in relation to the supply and the wiring carried out between different parts of the appliances.

6.16.1.11 The wiring between different parts of a fixed appliance that are installed separately is part of the fixed installation, even where it is supplied from a socket-outlet, unless such wiring is less than 1,5 m in length.
_

2./ I understand the following to mean that 2.5mm and 1.5 mm cables should be solid copper type. Ie Surfix or Norsk cable.

_6.3.2 Construction
6.3.2.1 Conductors of nominal cross-sectional area exceeding 2,5 mm2 shall be stranded, except in the following cases, where solid conductors may be used:
a) conductors of mineral-insulated metal-sheathed cables;
b) internal connections of distribution boards, switchgear and industrial
controlgear;
c) busbars;
d) aerial conductors;
e) aluminium conductors of nominal cross-sectional area 16 mm2 or
more; and
f) copper conductors of nominal cross_

3./ I understand the following to exclude the use of Cabtyre cables entirely

_6.3.1 Materials
All conductors of nominal cross-sectional area less than 16 mm2 shall be of annealed copper. In the following cases alternative material may also be used:
a) earth continuity conductors (see 6.12.1.9);
b) bonding conductors (see 6.13.1); and
c) aerial conductors (see 6.3.4).
_

4./ I hope that I have understood the above quotes correctly.
The reason I am here is to learn and not to teach, please criticize if necessary.

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Dave A (13-Feb-12)

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## Dave A

Thanks Leecatt. At least I can now point to the relevant section that drives the point raised.

While I was looking at the section myself, it struck me how easy it is to take stuff out of context. As example:

6.16.1.6: _A socket-outlet shall supply only one fixed appliance. The use of flexible cords of length exceeding 3 m is not recommended._

It's clearly pretty important to pay attention to the whole section to get the right interpretation (in this case 6.16.1.1 to 6.16.1.13 in full by the looks of things).

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## murdock

and you need to understand the different between cabtyre flexible cords and and flexible cables...i went to a site where the cabling between the floors...where wired with flexible cables...which was not illegal because unless you understand the definition of cords and cable you could make a noise for nothing.

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Dave A (13-Feb-12)

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## Leecatt

> Thanks Leecatt. At least I can now point to the relevant section that drives the point raised.
> 
> While I was looking at the section myself, it struck me how easy it is to take stuff out of context. As example:
> 
> 6.16.1.6: _A socket-outlet shall supply only one fixed appliance. The use of flexible cords of length exceeding 3 m is not recommended._
> 
> It's clearly pretty important to pay attention to the whole section to get the right interpretation (in this case 6.16.1.1 to 6.16.1.13 in full by the looks of things).


Thats right, you literally have to know the whole book - in context as well. 
I must be honest and say that I enjoy the rules and regs, quirky but that's me.
I find that the older I get the more slips away and its not that easy any more so this forum is something of great value to me.
If I go on too much about SANS feel free to shit me out :Shutup2: 

By the way, the name is Lee (i dont know how to change the LEECATT?)

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## AndyD

> 3./ I understand the following to exclude the use of Cabtyre cables entirely
> 
> _6.3.1 Materials
> All conductors of nominal cross-sectional area less than 16 mm2 shall be of annealed copper. In the following cases alternative material may also be used:
> a) earth continuity conductors (see 6.12.1.9);
> b) bonding conductors (see 6.13.1); and
> c) aerial conductors (see 6.3.4).
> _


I don't think that 6.3.1 excludes the use of cabtyre. Cabtyre has stranded annealed copper conductors. I think section 'a' allows earthing continuity conductors to be galvanised steel conduit for example. Section 'b' allows bonding conductors to be hard-drawn copper bar (not annealed) or aluminium. 

I completely agree that interconnecting cables for an oven/hob or an airconditioner may fall under the COC and simple running these appliances from a plug wouldn't exclude them.

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## Dave A

Yet another opportunity to be slagged off as money-grubbing rip-off artists by the the looks of things.

But as I keep saying to clients in our defence - we don't make the rules, we just apply them.




> By the way, the name is Lee (i dont know how to change the LEECATT?)


I just checked - I regret the username _Lee_ is already taken.

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## Leecatt

> I think section 'a' allows earthing continuity conductors to be galvanised steel conduit for example.


Andy I read the relevant standard quoted here, a) earth continuity conductors (see 6.12.1.9)
I dont see where galvanised steel conduit can be used as an earthing conductor.
I think the following excludes it 
"6.12.1.3 A wireway shall not be used as an earth continuity conductor."

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## murdock

what is important...the fact that people are discussing issues...the more we talk and the more people "get involved" the better it will get...its just to get everyone involved...we need an industry leader...like a union of sorts to stand up for the contractors and the industry as a whole...the eca is an established organisation...but unfortuntely just doesnt have any powers...and the AIA are in it for a buck...so if we could start an organisation which would look after everyone especially the little guys...

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## AndyD

> Andy I read the relevant standard quoted here, a) earth continuity conductors (see 6.12.1.9)
> I dont see where galvanised steel conduit can be used as an earthing conductor.
> I think the following excludes it 
> "6.12.1.3 A wireway shall not be used as an earth continuity conductor."


I can see I'm going to have to blow the dust of my regs with some of the new threads that are now running. I'll double check about steel conduit being allowable as CPC. It may have been a bad example but the point still stands, I don't think those regs you quoted exclude cabtyre as you concluded.

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## Leecatt

> I can see I'm going to have to blow the dust of my regs with some of the new threads that are now running. I'll double check about steel conduit being allowable as CPC. It may have been a bad example but the point still stands, I don't think those regs you quoted exclude cabtyre as you concluded.


I would like to discuss the cabtyre point more, If anyone can add to whether or not it is legal to wire a house in cabtyre add a submission here please

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## bergie

i see we have 2 almost identical threads running now, 6.1.11 excludes it, except for certain conditions. cabtyre up to 4mm is classified as flexible cord.

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## AndyD

It is allowed if stated in the product standard (6.1.11 - C) so this would depend on the manufacturer and what type of cabtyre. I'm assuming in this thread the general discussion is around PVC but we far more commonly use HO7RNF which is neoprene. 

From a common sense point of view, I don't consider it good practise to use it as installation cabling but many types of cabtyre have a far higher specification than FT+e or housewire-in-conduit so I wouldn't necessarily consider it unsafe if terminated with ferrules. Another thing going for cabtyre is that the CSA of the earth wire is the same as the live and neutral conductors whereas FT+e invariably has a reduced CPC CSA, sometimes it's even two wire sizes smaller depending on cable size.

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## BlueArc

Hi Guys 
I am a newly qualified electrician with my wiremans license. I really saddens me to see COC's charged at R450. To me these people are bringing down the reputation and integrity of installation electricians throughout the country.

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## AndyD

I suppose if it's a smal installation and you can complete testing in an hour then R450 might be a viable price. I think some domestic electricians might price the COC as a 'loss leader', knowing it will probably lead to further remedial work which is far more lucrative. Also after the initial failure the customer is semi tied into that electrician because of the reduced re-test fee.

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## murdock

> Hi Guys 
> I am a newly qualified electrician with my wiremans license. I really saddens me to see COC's charged at R450. To me these people are bringing down the reputation and integrity of installation electricians throughout the country.


i agree...but as the saying goes if you cant beat them join them...what i do now is instead of checking the complete installation like you are suppose to i do a spot checks then hammer the customer with a repair bill which covers all the just in case i missed...from experience you can normally see if the installation is "resonably safe" or a dangerous installation...the beuty about COC is there is no policing so its a money making racket...99 % of the installations i have been called out to check after an istallation has been passed and sold...has resulted in me doing the repairs because the customer is just not interested in the hassle of a court case...and the worse part is that they pay the bill for the investigation...

as i have mentioned time and time again...honestly i have no sympathy for a purchaser who doesnt have the electrical installtion checked by his/her own electrician before making one of the biggest investments of his/her life..if you stupid enough to buy a property checked by the seller...then you must suffer the consiqueses of your own stupidity...very sad but unfortunatly a reality.

the project i am busy with right now has this exact issue...we just dont have time to start fighting over whos responsible for what...we have deadline to meet for the customer to move in...by the time i have completed the project it will be safe and signed over with a valid COC.

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## BlueArc

Does anyone know when the e-COC will be available. Good idea to do this as we will be able to have an electronic copy on our files.

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