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Posted By Topic: Electrically Unsafe Hire Caravan - Worksafe

ShaneR
Jan 13 2016 14:54

Hi all

I'm helping with a caravan park and would like to know at what point you get work safe involved?

It is a 1970,s hire caravan with a current WoEF

It has many faults, same major and some minor

Faults

-Supply lead had a water leak in the inlet plug, plug full of water, corrosion so it has been like this for some time. Tripped Pillar RCD. Supply cable failed insulation test.

-Supply lead has no Tag and Test

Replaced lead with a new one and still tripped RCD

Pulled cover off the Switchboard and the main Active supply wire was floating/not connected to anything.

-Disconnected active to main switch

-No 16Amp RCBO but the MEN link has been removed

-no double insulated supply from inlet to main switch/Neutral/Earth

-The main switch uses the cover screw to disable switching with the cover removed. The screw was replaced with one that didn't fit properly.

-GPO power point switch does not switch

-Isolating switch I think for the fridge has tape covering it so can't be used?

I believe if the supply pillar didn't have an RCD the would have been serious risk of shock or fire.

How should I proceed with this case?

I've replaced the supply lead and reconnected the main active cable.

I've done basic safety tests and signed a safety certificate for the work that I have done.

I think the caravan needs a full retest by and Electrical inspector.

I've talked to the inspector who signed the WoEF and he claimed that the caravan was fine at the time of inspection. He did concede that the supply cable did need to tag and tested but this this was not common practice in NZ ...................

Thoughts?

   

pluto
Jan 13 2016 16:02

A valid WoEF for the caravan as a whole is the ONLY certification required by ESR 2010.

There is NO provisions in AS/NZS 3001 Appendix C which details inspection and testing for a WoEF for a separate tag and test of the supply lead only.

It you find faults that have developed since the valid WoEF was issued, the faults are repaired in the same manner if the fault occurred in an normal electrical installation, remember the ESR 2010 "electrically unsafe" provisions still apply.
   

ShaneR
Jan 13 2016 17:52

The supply lead is detachable

I would have thought regulation 26 b applies

But appears that see that 26.3.b the cable would be safe if supplied through an RCD?

The hirer had no way of knowing if the supply pillar had an RCD?


   

ShaneR
Jan 13 2016 17:56

also as per other post

How can an inspector issue an WoEF with MEN link removed but have not RCD or RCBO?

   

Sarmajor
Jan 13 2016 18:24

The link was probably removed by some moron when they took it to a caravan park that had RCD protected pillars.

I generally refuse to issue a WOEF for a caravan if the RCD upgrade has not been done or is not done at the time the WOEF inspection is done because of this issue.
   

pluto
Jan 13 2016 19:41

ShaneR Jan 13 2016 17:52

your comment 1
The supply lead is detachable

I would have thought regulation 26 b applies

But appears that see that 26.3.b the cable would be safe if supplied through an RCD?

My comment 1

Would suggest you read ESR 2010 regulations 76, 77, 78 and AS/NZS 3001 Appendix C in particular, an these control the issue and use of the WoEF system for caravans and the like and also the obligations of a hirer of a caravan.

your comment 2
The hirer had no way of knowing if the supply pillar had an RCD?

My comment 2

The use of a valid WoEF for caravans and the like is the method used for Hire caravans, etc. ESR 2010 Regulation 77 refers.

   

ShaneR
Jan 13 2016 21:04

"The link was probably removed by some moron when they took it to a caravan park that had RCD protected pillars.

I generally refuse to issue a WOEF for a caravan if the RCD upgrade has not been done or is not done at the time the WOEF inspection is done because of this issue."

Unless im mistaken the electrical inspector who issued the WoEF told me today that there was a time when the link could be removed and an RCD/RCBO was not necessary? I was starting to believe this was correct.

"Would suggest you read ESR 2010 regulations 76, 77, 78 and AS/NZS 3001 Appendix C in particular, an these control the issue and use of the WoEF system for caravans and the like and also the obligations of a hirer of a caravan."

I suspect non compliance based on the above sections.






   

Sarmajor
Jan 13 2016 23:53

Reading through your original post I noticed a few things that concerned me that I missed the first time around.

Leaving aside the obvious electromechanical issues that could have developed while the caravan was in transit, wire falling out of terminals etc.

The non functioning gpo switch and taped over switch are fail items for a WOEF.

Your inspector was wrong to concede that the lead headed to be tested and tagged. The caravan supply lead is covered under the WOEF and is part of the testing requirement for the issue thereof.

Your repair work to rectify the faults does not invalidate the WOEF that is current.

I agree that you should get the caravan inspected and a new WOEF issued by another inspector.

As far as I can recall there was never a time when it was ok to remove the men link from a caravan without installing an RCD.

In the latest version of 3001 removal of the link is one of the specific actions that triggers a ,mandated installation of an RCD. 3.3.5 3001 Ammendment 1 May 2009

The removal of men links by caravan owners is more common than we might think because when they drag their old van into a new park they cannot get a supply from an RCD pillar. There is always someone around who knows how to "fix" that problem.

   

Steve
Jan 14 2016 08:56

I would also apply a common sense test to this, looking at the caravan, do you think there is a likelihood it could electrocute somebody? In the case of a hire caravan you have to consider that somebody could be an occupants child. Or otherwise an unsuspecting member of the public who does not have the knowledge to determine what is safe or unsafe, but just puts their trust in 'the system' to make sure it is. Then I would ask myself "Why is the caravan in this condition". And the answer to that might be lack of awareness, or it might simply be because the owner has been able to get away with it. The main objective here of course seems to be to get the caravan to a safe condition. Personally if I find something that I think is a real danger to life, in the past I have always cut the plug off it / rendered it inoperable, then started talking to the owners about it. And that might get you ticked off as you are of course damaging someone elses property when you do that, but you might also save a child's life. Always good to get a second opinion though.
   

AlecK
Jan 14 2016 10:03

ESR 26 does NOT impose ANY requirements.
Whereas having a valid WoEF IS a requirement.
So even though this is a hired-out caravan. there is NO requirement for the lead to be T&Td.

The range of problems you found would certainly make me suspicious as to the state of the caravan when the WoEF as issued; but there is no evidence as to when these defects originated so must give the inspector benefit of doubt; can't say he got it wrong.

What I can say is that this inspector clearly isn't fully aware of the "Rules", else he wouldn't have agreed about T&T for the lead.
Also that in one day's WoEF testing just before Christmas, 10 of 14 caravans looked at had basic non-compliance issues that must have been there when last WoEF issued, yet all had current WoEFs.
That was worse that I expected; generally around 30 % of connectable installations I check are wrongly set up. Which indicates that inspectors issuing WoEF without doing a full check as per Appendix C of 3001 is quite common.



As for a time when it was officially OK to remove the N-E link without upgrading (by installing RCD and current limitation); there was a short time, when the WoEF criteria cited by ESRs was ASNZS 3000 + Amendment A.
Amendment A - which was NZ-only - had an error in it that unfortunately wasn't picked up until after publication & citation in ESRs.
The error was corrected when Amendment A was incorporated into Amendment 1.
I can't be bothered looking up the dates, nor quoting the details of the error. Those details don't matter. But yes, for a sort time it was actually valid to issue a WoEF in these circumstances.

The removal of N-E links to avoid tripping RCDs - whether on new-style caravan park pillars or at other premises - is especially dangerous because the older caravans with links generally have the supply E connected to the N-bar o the E-bar. So when the link is removed there is NO connection from the caravan's "earthing" system and the supply earth. All it takes is an earth fault on an appliance, and the whole caravan becomes live.
Which is why Amendment A, and the later Amendment 1, both require ANY alteration work on a connectable installation - including the removal of a link - to be followed a COMPLETE test of the ENTIRE earthing system.
Problem is, this mandatory testing often doesn't happen. It's failure to test, rather than the lack of upgrade, that causes the biggest safety issue.
Why do electricians not tst? Because they never make mistakes.
How do they know they don't make mistakes? Because they haven't killed anyone yet(that they know of), and because they don't test so they don't find their mistakes (any other way than killing someone).

So yes, there is definitely a chance that a link-less caravan without RCD could electrocute somebody. especially if supplied from an older, non-RCD pillar.
   

ShaneR
Jan 14 2016 11:10

Thanks guys

I was a bit upset by this caravan

I can accept 1 fault but 2 major faults plus a few other no compliant issues combined...................................When the ducks start to line up bad things can happen

Just to add to the story, from my understanding when the caravan was dropped of the the supplier was having trouble getting the power to work. I understand he swapped the main supply lead and wriggled the inlet plug and it began to work(or something to that effect).

Then is rained and bad things happened

When I rang the supplier he told me to wriggle the inlet plug or something to that effect to get it to work..............Go figure

re:MEN link
Everybody will lie and say it was done in the allowed time period?

Do inspectors issue a WoEF knowing that the there is no MEN link and no RCD if the supplier says it was done in the allowed period?

   

pluto
Jan 14 2016 12:10

ShaneR Jan 14 2016 11:10

Your question 1 (part only of post)

re:MEN link
Everybody will lie and say it was done in the allowed time period?

Do inspectors issue a WoEF knowing that the there is no MEN link and no RCD if the supplier says it was done in the allowed period?


My comment 1
ESR 2010 regulation 78 covers the issue of WoEF and cites that AS/NZS 3001 is to be used.

The current schedule 2 of the ESR 2010 of referenced standards then cites that Current AS/NZS 3001 + amendment No. 1 is the valid document, it follows that Appendix C of the current issue is the only applicable issue to use, which makes the only provisions; EITHER N to E link fitted; or
an RCD in the supply lead (at the plug end of lead) + permanent connection of the supply lead to the caravan, alternatively, RCDs in the caravan switchboard.

There are NO other alternatives permitted.
   

AlecK
Jan 14 2016 17:59

There was only a short period when Amendment a was in force, so only a limited number of caravans would have come up for WoEF during it.
And most people never even knew about Aamendment A, so not many inspectors would have applied that checklist.
Plus that checklist included full testing of earthing system, so while there may be a few units with no link and no current limitation / RCD; at last they won't be earth-free death traps (as long as the Inspector actually did do all the checks & tests specified).

And now, as Pluto said, we issue woEFs under Amendment 1, which allows EITHER link OR current limiting + RCD, so any that did get through without the upgrade will get caught next WoEF.
   

ShaneR
Jan 14 2016 20:32

I think you guys are fantastic.

The problem is there seams to be a disconnect between requirements and reality.

I had an electrical inspector out today to check on other stuff. He effectively said this caravan doesn't need and RCD even though the link has been removed. That's two electrical inspectors in 2 days saying the same thing?

Do electrical inspectors get bulletin updates of any kind?

Is this a topic we could get in the electron magazine?

By the way I've decided the best thing is to let it go, sounds like it happens all the time?

I always thought Electrical inspectors have reached some level of perfection :)






   

pluto
Jan 14 2016 21:07

There are very few people who have tried and worked hard to get the caravan supply arrangements correct since 1980. I can count them on the figures of one hand many are still in the electrical industry.

Firstly to remove the scrapping earth plug and appliance inlet with a scrapping earth, when the fitting was made from die-cast materials (in stead of the original brass) the earth connections became unreliable and then the plugs and appliance inlet fittings changed to IEC 60309 types.

There was at that time another type of industrial fittings being developed later to become AS/NZS 3123 or the 56 series), that was not used as there was NO standard published so as to be able to identify this new type of fitting, so we ended up with IEC 60309.

The IEC 60309 type of plug and appliance inlet changeover took 4 years to achieve and many caravan park pillars have both the IEC 60309 and the old scrapping earth socket outlet to assist the changeover.

This was the easy part of the changeover process.

The use of RCD's was on the rise in electrical installations.

Since mid to late 1980's several attempts have been made to introduce the use of RCDs in caravans to give increased electrical protection, and the changeover cost had to be nil or very small, many Governments have endorsed this point, so how to introduce total use of RCDs in caravans at no or very little cost.

The first try in-line RCD in the supply lead, water ingress, the drop test when disconnecting from the caravan park service pillar or the run over test by the towing vehicle, so this method fell out of favor.

To be continued
   

pluto
Jan 14 2016 21:59

The caravan story continued

The next major step was the production of AS/NZS 3000:2000 jointly with Australia and was published in August 1999. AS/NZS 3001:2001 followed, Australia required the use of RCD in the service pillar to protect the supply to the socket outlet used to supply caravans and NZ did NOT require an 30 mA on the IEC 60309 socket outlet due to the very large number of caravans where fitted with earth to neutral links (an RCD will trip when a caravan fitted with is connected to an RCD protected socket outlet.

It was not until 2003 that AS/NZS 3000:2000 and AS/NZS 3001:2001 become a “deemed to comply” status.
This also brought in the use of RCD in domestic housing.

Latter in 2007, AS/NZS 3000 was revised and AS/NZS 3001:2008 published this brought the installation of RCD’s in NEW service pillars in Caravan Parks in NZ.

Energy Safety published a method to retro-fit RCDs to caravan switchboards in 2007-2008 (now revoked).

A full changeover of caravans having and RCD (many are using an RCBO to also give current limiting on the supply lead), unfortunely , there are NO facts on how many caravans have been converted to have RCD protection in the caravan.

The position in caravan parks of a 30 mA RCD on socket outlet supplying caravans, the numbers should be increasing as new installation are installed, unfortunely there are NO facts on how many caravan park service pillars have RCD protection for the socket outlets supplying caravans.

Thus the most challenging changeover of all, of caravans to have RCD protection in the supply connection has not been achieved for all caravans without imposing a high cost of fitting an RCD in both the caravan park service pillar and for each caravan.

There are a few who have thought long and hard to find the magic solution, but we are still to find a way to do so. The very few who been with the process from day 1 are getting on in years and it hoped to find the magic solution in the near future, the very few I refer to, are well known in the electrical industry.

If you can think of the magic solution to fix the problem at very little or no cost, any reasonable and well considered ideas are most welcome. Use this forum to canvas your ideas

   

Steve
Jan 14 2016 22:26

That is a difficult situation having a different view from the two electrical inspectors. I have had two occasions myself where I took the opinions of inspectors as fact only to later find out in both cases the advice given had been perhaps out of date. At the end of the day we can ask for much appreciated advice but the onus is still on us to check the facts for ourselves or face and live with the consequences. Very difficult to know what is the right thing to do, but sometimes the right thing is not the easy thing. Going forwards, it looks like an article in the electron magazine clarifying and raising awareness of what the requirements are for caravans would be a good measure. There is probably quite a lot of aging caravans out there so this risk would only be going to increase if its not swept up. The obvious consequences to me seem to be the potential to liven up the caravan metal work and cause a fatality as someone steps in or out of it.
   

ShaneR
Jan 15 2016 07:28

You guys seem to have inside knowledge

What would be the best way to suggest and article for electron magazine?

Best person/email to contact?




   

ShaneR
Jan 15 2016 07:37

I can only find a link for making a complaint on the EWRB site.

   

pluto
Jan 15 2016 08:40

ShaneR Jan 15 2016 07:28
Your comment
You guys seem to have inside knowledge

What would be the best way to suggest and article for electron magazine?

Best person/email to contact?

My comment
Write a letter to the Editor suggesting this would be a good article for the update of all who work in the electrical industry.

The contract address is Editor, Electrolink
Alpha Publishing Ltd., PO Box 91300 Auckland.
Email magazine@electrolink.co.nz

The editor knows how to contact a suitable person for detailed information.

   

ShaneR
Jan 15 2016 08:56

email sent

Thanks
   

AlecK
Jan 15 2016 09:03

1 "Do electrical inspectors get bulletin updates of any kind?"

We get exactly what you get: notice in the Electron newsletter sent out by EWRB to all PL holders.
There is NO obligation on govt to advertise changes to Acts & Regs, it's legally up to us to know the Rules without being told (ignorance is no excuse).
But EWRB do provide this service for Electricity ct and Electricity (Safety) Regs), as well as their own rules for PL requirements. However they only know what they've been told, so some minor changes slip through with no notification whatsoever (eg 2 minor amendments to ESRs in 2014, basically updating citations of documents.)

We can also be notified when Standards change, by registering with Standards NZ.
Having been told about a change to ESRs, we have to take the time to read it to find out, for instance, that a later edition of a Standard is now cited. Then we have to read the Standard to see what exactly has changed.

Sometimes we get a bit of help from the preface, which outlines what changes have been made. And if it's an Amendment (but generally not for a new edition) there's a margin bar to say: this line / para has changed.
Still need to compare current to new to find out exactly what the change mean.

All that keeping ourselves informed takes time and effort - many just can't be bothered; would sooner believe garbled gossip than do any actual homework.
Or rely on an Inspector who maybe hasn't got it right.


2 "Is this a topic we could get in the electron magazine?"

Probably not, but you could ask. "Electron" is the official mouthpiece of EWRB, and they ae NOT the ones best placed to outline requirements of ESRs & installation Standards. Their job is licencing and competence of electrical workers.

Better to look to an industry magazine such as "Electrolink". If you want an article there about a particular topic, all you have to do is write it as a 'letter to Editor'; and if it looks useful to the trade it may be published as an article.



3 "I always thought Electrical inspectors have reached some level of perfection :)"


Old-time Inspectors got the title because they did that job for an Electrical Supply Authority.
transitional Inspectors got it simply for time served in the industry.
Modern Inspectors pass an exam (which means that if the "pass" point is 75% they got up to 25% wrong).
Holding an "Inspector" PL - regardless of how you got it - is NOT a guarantee that you actually know what you are talking about.

Many do try to keep up, but there's an awful lot to keep up with once you get away from "mains work". And sad to say some Inspectors don't seem to make much effort even on the basics.

WoEF checks being a god example. Leaving aside the Part 1 assessments for imports, issue of a WoEF is simply a matter of following a checklist. Check these items a, b, & c; , do tests x, y, & z. Couldn't be simpler; 'cos every item is either "pass", "fail", or "not applicable".
Yet a large proportion get it wrong.


So yes, there is a disconnect between requirements and reality; which can only be addressed by ongoing training.


As for inside knowledge, yes some contributors here have a bit of that, from being involved in the processes.
But what makes the real difference is spending time keeping up to date, and anyone can do that if they want to - as outlined above.

Best advice I can give anyone is that every time a question comes up, go and look it p. Don't just ask the boss, or a co-worker, or an Inspector. y al means ask all of them but LOOK IT UP FOR YOPURSELF. That's the only way to get properly familiar with Wiring Rules. Remembering not to look at clauses in isolation, but take the context into account.