Coc question Regarding Earth for other services.

[DieterT]

Ok in regards to the EIR why would marking the earthing terminal as N/A be acceptable as reasonably safe?

Reason I am asking this is as it is a requirement from 2006 to have said earthing terminal installed. I can understand if the installation was done prior to the publication of said standard as per 6.11.5 (amdt 6 & 8 , 2006 & 2012) that it's valid to argue that it would not be required as it is the same with old (bobbin) wiring used, but where alterations done the installation should then be treated as to the latest standards.

Also unclear as to why the opening notes of Section 5 SANS10142-1 has anything to do with this, if you could also please explain?

5 Fundamental requirements
All commodities in an electrical installation shall be installed in
accordance with the requirements in this part of SANS 10142 and with
the manufacturer’s instructions, where applicable. Amdt 8
NOTE 1 This clause contains the general safety principles applicable to electrical
installations. Amdt 5; amdt 8
NOTE 2 The manufacturer’s instructions may contain more stringent
requirements. Amdt 8

[Dave A]

Also unclear as to why the opening notes of Section 5 SANS10142-1 has anything to do with this, if you could also please explain?

NOTE 1 This clause contains the general safety principles applicable to electrical
installations. Amdt 5; amdt 8

As additional reference, the brown stuff started heading toward the fan on this issue on TFSA round about here.

Reason I am asking this is as it is a requirement from 2006 to have said earthing terminal installed. I can understand if the installation was done prior to the publication of said standard as per 6.11.5 (amdt 6 & 8 , 2006 & 2012) that it's valid to argue that it would not be required as it is the same with...

I know that this is what has been promoted by some very prominent folk in the electrical contracting industry for the longest time already. The underlying argument has always been that if it was compliant with regs when it was installed, it remains compliant today.

I've listened to a number of folk wax lyrical about this progressive applicability of standards.

But take a close look at the regulations. That is not what the regs are saying.

Progressive applicability of standards is a wonderful, romantic myth.
When it comes to current legislation on the issue of an electrical CoC today, there are two current standards in play. Period.

[DieterT]

As additional reference, the brown stuff started heading toward the fan on this issue on TFSA round about here.

Lol, just briefly viewing that post I do see what you mean about "brown stuff heading toward the fan..."
It is a very sensitive topic and seems the older the electrician the more "harde gat" he would be.
Funny thing thou, lots of them are still stuck on old regs and have completely lost track of amendments made and additional regs added.
This I blame personally on the ECB, not that I had much to do with them, only got my first ever CoCs from them and then started making my own.

if it was compliant with regs when it was installed, it remains compliant today.

Well that all depends if no change have been made since to the characteristics of the circuit.
I am in some ways also still confused about this especially with the most common BOBBIN WIRING

Long ago we (me as qualified electrician with a registered wiremans) did a CoC on a house which had 4 different time periods of wiring in the roof space, obviously as time progressed things where changed and addition things where installed.
Anyways then through knowledge of the wiremans (not proper old school, but more mid school) and through advise from the ECA PTA (Cecil) and JHB (Louis) I was taught you have to rewire everything unto new standards as the old installation was modified.
Ok so we did that, cost the client thousands and more, but it got done and we moved on.

Then not so long ago also doing a CoC on an old installation, then myself being the registered wiremans, we had a situation where one side of the house was twin flat and the other side bobbin. Half of house was rebuilt due to some explosion that happened close by. So then also confused as after doing my unit standards at the inspector and him teaching us that should the old part of the installation comply with the standards used at that time and once I satisfied myself through test and inspection that the installation is reasonably safe I could issue a CoC for such ticking both (a) and (b) under section 4.13

Also because I found 1 or 2 problems with the bobbin wiring as a new geyser was installed in that roof space and so the bobbin wiring was poorly connected and cut + also some of the bobbins where broken. Therefor I phone the inspector and asked him what must I do now. His words then was to asses the installation and to review the extend of modifications to be made. Since it was a small part to be repaired he said that without the installation of additional wiring and without changing the characteristics of the circuit to repair the wiring as to the general safety requirements and so it is reasonably safe.

When it comes to current legislation on the issue of electrical CoCs, there are two current standards in play. Period.

I agree that there are two standards at play, one for new installations and the other for existing installations and then also another additional part for existing installations "prior to the publication of this edition of SANS 10142-1"
But that does not mean that the rest of SANS 10142-1 gets ignored. Well at least I can say that is how I have been taught and that is the way I interpret the regulations. The way I understand that statement in the EIR is that special care needs to be taken when it's an existing installation and especially when it's an existing installation "prior to this edition of SANS 10142-1" Thus taking into account the current requirements and also what has been installed and when it was installed.

Just now in the MIE specialized codes they where hammering on the fact that an age for the installation should be obtained as the verify the standards that was used in order to confirm if the installation complies.
The regulations has a lot of loop holes, even the inspector mentioned a few to us, but at the end of the day I am a professional and need to verify that the installation is safe. I sometimes bend the rules, but within limits of safety.

The reason I chose not to go to the guy who was offering the unit standards other side of the mountain from me and rather drove 2hrs every Saturday to train at the AIA, was cause he would be the guy I would face in court should my installation not comply and/or pose a safety risk. He was originally trained as an inspector in UK and I have much respect for most 1st world countries in regards to their code of conduct of their electrical industry (especially NZ) So if something is unclear to me and I am confused as to what the regs are trying to say I would give him a call and ask him. Not so easy sometimes as he is constantly busy.

I personally made a choice not to blindly follow regs and the question everything (yes I am from that generation)
So when confronted with something and the regs aren't clear about it I will contact a few accredited informers and scrutinize their answers and then implement the requirements.
Main priority for me is safety and then from there on I will consider the rest. At the end of the day, I have to put my signature in that certificate and take responsibility. Still can't understand how some sparkies blindly just sign CoCs and thumb suck the test results. I am one of those that does a earth resistance test on every plug point on domestic / light commercial and average on heavy commercial / industrial and yes there are annexes added.

This has probably not much to do with the original question of the earthing terminal for other services on new installations and on existing installations prior to this part of SANS 10142-1, but I will get back on this once I have had a chat with the inspector.

[Dave A]

I agree that there are two standards at play, one for new installations and the other for existing installations and then also another additional part for existing installations "prior to the publication of this edition of SANS 10142-1"
But that does not mean that the rest of SANS 10142-1 gets ignored.

For the sake of clarity, not all of it. You still need to pay attention to other parts of the code referenced out of section 5. It does make vast swathes of the code irrelevant though.

[DieterT]

For the sake of clarity, not all of it. You still need to pay attention to other parts of the code referenced out of section 5. It does make vast swathes of the code irrelevant though.

When reading a certain standard you always have to take into account the rest of the standards around that certain standard. One can never just isolate one standard and then make that the required regulation to be used only for that specific part. Only when it specifically says you have to only use that one standard under said condition then you will be able to do that, which I have only seen with specialized installations as they would say that these special locations takes into the account SANS 10142-1, but is in addition to such (i.e. medical locations and hazardous locations)

I always compare the electrical regulations with the bible. When doing study of the bible you never just pull something out of context and make that your thing to live by. You reference it with different parts of the bible, read all that is before and after that specific piece and if you really want to make sure you know your stuff even look at different translations.
Apart from the different translations, the SANS 10142-1 for electrical installations (non - hazardous/medical locations or specialized earthing) is treated in most cases the same as doing bible study.
If looked at Section 4.13(b) on the CoC it can be seen

13(b) In the case of installations that existed before the publication of this edition of SANS 10142, the installation complies with the general safety requirements in this edition of this part of SANS 10142 and is reasonably safe

and then also (not to sure if it is on all the different types of CoCs offered by ECB / ECA etc.) it says (i.e. Section 5)

Now for me this means that when certifying an installation that existed before this part of SANS 10142-1 that the installation complies with the general safety requirements as set out in Section 5 with taking into reference the rest of SANS 10142-1 also taking into mind the date of the installation and the relevant regulations that was used according to age of installation. Then after satisfying myself that the installation is reasonably safe I then issue a certificate of compliance.

Now looking at the 15 Visual Inspection points on Section 4 of the CoC I would then thick 13(b) as YES as for the rest of the points I have to ensure that everything comply with the relevant standards and answer YES. Only where an item is not applicable then I would mark it as N/A and where it is marked as NO then you cannot give the certificate of compliance (PS : the test/inspection report can be answered with NO as this can be given to the person requesting an test & inspection report and does not normally mean it is for a compliance certificate)

Take an example, you install a plug point on a already existing circuit. You issue a CoC since the characteristics of the circuit has been changed (which before the change there was already a CoC issued for) and also since a alteration to existing installation have been made and new materials have been installed.
On the Visual Inspection in regards to the plug point having been installed, which will have to be marked as YES (as to comply and to be able to issue certificate of compliance) and which would have to be marked as N/A (obviously nothing will be marked as NO since this will in-able you to issue a compliance certificate, so for argument sake the circuit from point of supply to point of consumption is compliant)

Once you can answer this question then it would be easy to answer the question when you are doing a CoC (Test & Inspection only) on a property under Section4.13(b) as indicated on the CoC.

Also take into mind the tests that needs to be carried out when an addition or alteration has been done what needs to filled in and what needs to be answered N/A and same with existing installation.
That is why I agree that the CoC is issued differently as a new installation compared with an existing installation and also compared with an alteration/modification to a existing installation and that what needs to be answered as YES and that what can be answered as N/A

[Dave A]

I always compare the electrical regulations with the bible. When doing study of the bible you never just pull something out of context and make that your thing to live by. You reference it with different parts of the bible, read all that is before and after that specific piece and if you really want to make sure you know your stuff even look at different translations.
Apart from the different translations, the SANS 10142-1 for electrical installations (non - hazardous/medical locations or specialized earthing) is treated in most cases the same as doing bible study.

I gently suggest it is this type of analogy approach that has got the industry into such a regulatory tangle in the first place. It really is much simpler, and certainly way more appropriate, to consistently apply the principles of law to the understanding of law (and regulations) in my opinion. It is bound to produce a far better quality product that requires less divine intervention to decipher and understand.

Let me try to restore your faith in the principles of law a little.

In my own quest for clarity, I have now gone hunting for references to section 6.11 in section 5, and found 5.1.3.1 which reads

A new electrical installation shall not be connected to the supply unless the supply includes a protective conductor. (See also 6.11 and 8.7.3.)

This plainly applies to a new electrical installation only, otherwise why include the word "new". If it had been the intent that it applies to all electrical installations (and all supplies for that matter), it should have read -

"An electrical installation shall not be connected to a supply unless the supply includes a protective conductor. (See also 6.11 and 8.7.3.)"

So in the instance where we are dealing with an existing installation, we are effectively directed to look elsewhere. If this was not the intent, those with input into these codes need to ensure the words match their intent.

Fortunately the balance of 5.1.3 does go on to deal further with earthing, bonding etc. issues, so happily it's not like that's the end of the matter.

[DieterT]

I had the opportunity to talk to the AIA and the ECA in regards to this matter.

Will try and answer this in more detailed answer over the weekend when I have more time.

Need to go back on call recordings to get the exact points of reference.

Basically it comes down to that you have to implement the whole SANS 10142-1 when conducting a section4.13(b) Test and inspection with intent to issue a certicate of compliance. And for that matter you will always implement the whole SANS 10142-1 and any other additional regulations as required for given situation except where clearly indicated otherwise.

Also the installatio of an earthing terminal for other services is a safety aspect and is required to be installed even if on a test and inspection CoC. Will also get more into detail on the reason why this would be seen as a safety concern.

Wish our industry as with ECSA would post case studies to help people get a better insight into the regulations and implementation there of.

The conversations with the AIA is always insightfull as he shares some of his cases he doesn't have a non desclosure agreement with.


"I used to have a lot of anger issues, now I just have a passion for justice"

[Dave A]

I'm really looking forward to reading this one

Just a thought on relying on voice recordings - why not just ask them to reply in writing?

[DieterT]

Hope not to dissapoint...

I am sure you can email them and ask them. I have not considered this as I am just glad to be able to get them to advise me which does not happen often as people tend to be busy.

Well then again I was to guy who got to talk to Pieter Laubscher. Wish I asked him to put lots of things in writing...ow wait I was blown away that he answered my call...

Here are the contact details of people who would be able to bring more clarity to your questions or for that matter maybe even more confusion (meant by this that ECA said one thing and AIA another as I will post later)

AIA - Nico van den Berg
Faebook page :

https://m.facebook.com/profile.php?id=141716502506464

Email : info@independent-inspectors.co.za

ECA - Cecil Lancester
Facebook page : https://m.facebook.com/profile.php?id=166807173424789
Email : pta@ecasa.co.za

ECB - Tony Mcdonald
Email : info@ecbsa.co.za

DoL - Pieter Laubscher
Email : pieter.laubscher@labour.gov.za

"I used to have a lot of anger issues, now I just have a passion for justice"

[Dave A]

...or for that matter maybe even more confusion (meant by this that ECA said one thing and AIA another as I will post later)

I regret that's no surprise

Unfortunately there is a gaping hole in the regulations, and each seems to have their own theory on how it should be plastered over.

[DieterT]

I regret that's no surprise

Unfortunately there is a gaping hole in the regulations, and each seems to have their own theory on how it should be plastered over.

You know, I had the same opinion when I started with the SANS 10142-1 during my apprenticeship days and this also in the early days of being a wiremans. As also did most other electricians I communicated with. Today after much exposure and also taking the effort to revise and reread the regulations and communication with different sources I can say that yes there is some holes (or loop holes), but nothing major or gaping. This just depends on the knowledge of the person applying the regulations.

How long have you been involved with the regulations Dave, how long have you been issuing CoCs and inspection reports? And during that time, how many times have you been confronted with a regulation you did not understand or where unsure about and contacted someone who could advise and confirm the regulations? Most electricians who where issuing CoCs and those I worked with back in the day where issuing CoCs without even considering what they where filling in and signing on. Almost like it was considered normal not to question. They never in their life even considered to phone the ECA or ECB or "try to phone" the DoL or an AIA. I am sure they who answered their calls would have been glad to assist.

To just complicate things more for sparkies out there, there is a law that says "if it can be proven that an registered person did not have sufficient knowledge on the regulations (obviously in regards to the matter where to he will be judged on) his registration can be permanently removed by the chief inspector" having said this, also be careful when the day comes and you are questioned about the application of regulation in question and you say "they taught me so" and that "they" would be willing to stand up and say that it true.

My report on what the AIA and ECA said on regulations 6.11.5 SANS 10142-1 and also on the matter of an Section 9.2(b) of the Electrical Installations Regulations 2009 certificate compliance for an existing installation will follow in next post.

[DieterT]

As a foot note to the answers from both the AIA and the ECA, the Section 9.2(b) (EIR 2009) CoC it must be understood that this CoC is meant (in the perfect world) to be issued only for the test and inspection of a property which has a CoC for the existing (initial) installation and all the alterations which was done. As we all know, most properties (if you are lucky) there is a CoC for the initial installation and 99% of the time no CoC for any modifications that where made after initial installation. So in most situations fundamental requirements have not been met and any changes to regulations have not been implemented.

Also to understand the reason for such CoC. There is supposed to be every year new/old regulations or amended regulations added / changed / or removed to/from the SANS 10142-1 and if not issued that year it would be compiled over a few years and then issued (ideally every year) This is to avoid any new installations not having regulations to comply with and therefor not being covered by the CoC ,as what is currently happening with inverter and solar installations apart from the fact that it needs to comply with the "alternative supply" section, but does not cover the installation itself. Apart from new installations also with existing installations to keep up to date with new safety standards and changes made to initial regulations. Thus reason why section 9.2(b) CoC reads "In the case of installations that existed before the publication of this edition of SANS 10142, the installation complies with the general safety requirements in this edition of this part of SANS 10142 and is reasonably safe"

ECA - Cecil Lancester

-Existing installation, basic safety principles must comply of the code and is reasonably safe as long as it is used in the correct manner. Section 5 shall be the main part to be considered in conjunction with the rest of the regulations. Never will any regulation be used out of context and all regulations shall be considered when issuing any form of certificate of compliance
-In his opinion when doing a Section 9.2(b) CoC when no earthing terminal installed, this will not make any difference to the safety of the installation. Waste of time because nobody uses it. On an technical point he says yes install it. Agrees for the reason they implemented it. Was actually initially brought up for the earthing of telkom services, but they never even climbed into a ceiling. Reason for implementation is to keep non electricians out of DB boards and fiddling around, making loose connections and to stop other services from strapping their earth wires around geyser pipes or building steel structures.
-As a final point he adds that, should you appear in court or in the tribunal due to a regulation matter on your installation / CoC that will that specific point be in question. Then if yes, they will look at the reason why it was answer as "N/A" and why it was never installed. If then found to be the cause of reason say someone got shocked/killed or the property burnt down, then the person who issued the CoC could be found guilty on that grounds.

AIA - Nico van den Berg

-Chance have been given to contractors to install the "6.11.5" since 2008, with 2009 when the new EIR was released it was decided to start enforcing this regulation and by 2010 it was decided that this is mandatory and sufficient time was given to contractors to install this and confirm with inspection if this was installed and if not, to be installed
-Always have to read regulations in context. With Section 9.2(b) CoC, Regulation 5 of SANS 10142-1 will be as primary and rest of regulations must be implemented as to be reasonably safe.
-The earthing terminal as per regulation 6.11.5 is seen as a safety aspect and also forms part of Section 18 of the GMR 2011
-Reason for implementation of regulation 6.11.5 is for other services not to go mess around in DB board and cause further unsafe conditions
-When the matter is taken to court it will be looked at what lead to the court case and if was found the said regulation to be the cause it will be questioned why it was marked on the CoC as "N/A" and why it was never installed
-Procedure followed when a matter is referred to court is the AIA will first look at the OHSA and then decide if this was a regulation issue.
-Any certificate of compliance where Section 4 number 15 is marked as "NO" or "N/A" will be seen as non compliant
-A word of advice given by AIA is that when a case lands up in court and it was found to have been a regulation issue and then it was found, say for instance in regards to regulation 6.11.5 of SANS 10142-1 that the earthing terminal was never provided. What will be looked at, was it because of a user or contractor or because of the contractor that the user or other contractor got shocked/killed or property damaged. Taking this situation of the installation of an earthing terminal for other services that was not installed, the contractor (plumber,CCTV,DSTV etc.) who had to earth their service gone and fiddled in the DB in order to make such earthing caused then an unsafe situation where to he gets shocked or for that reason causes someone else to get shocked i.e. accidentally disconnects the geyser earth and caused the plumber to get shocked, this would then be looked at that the electrical contractor not having installed the earthing terminal for other services being the cause that the other contractor had to open the DB board to earth his installation and caused someone else to get shocked or himself thus having created an unsafe situation which could have been avoided should the regulation been correctly implemented. This does not void the other contractor from responsibility, but also includes the electrical contractor as responsible.
-Also adding to that, never in a hearing / tribunal / court say that "he said so" or "they taught me so" as this will prove insufficient knowledge of the regulations and thus in the report the AIA needs to tick "insufficient knowledge" which in turn will be given to the chief inspector for the permanent removal of registered person's licence. There was a situation where a contractor said this, that a "not to be named person and institution" taught him so. They brought that person to the court where as he denied ever doing so and then this contractor lost his licence. The situation wasn't even such a serious matter as to where he would have lost his licence.

[Jasond MIE]

Thanks so much for the response guys, will definitely be implementing the advice received, I will be looking into when the ECB is coming to Cape Town again to brainstorm at their meetings, I feel in Cape Town we are quite limited to resource in terms of information that is available to electricians but I see that tge Western Cape Inspection Authority is under new management and I'm looking forward to see if positive changes arise from this, just an example of the challenges involved in keeping current in our industry they are running a 2 day course in April with new amendments for Specialized Installations and I was keen until they told me the price of R6000 (early bird special) I am always willing to pay for knowledge and training but I find this rediculous.

Thx

[DieterT]

Wow that is ridiculous !

This is exactly what I was talking about with the AIA. There is proven a lack of knowledge in the industry, but yet they go and exploit us with prices.
Did you know the SABS just increased the prices of the standards? Has anyone even gone and looked what the total amount is for all the standards for MIE??

Much sadness

[Jasond MIE]

I was lucky enough to work for a great company when I bought my material when studying to become a master, they paid for the standards but it is absolutely crazy what they charge for them and training in general.

To do your unit standards in Cape Town for MIE was over R25k, so I flew to JHB to do it and it cost me half of that for the week course.