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Posted By Topic: Status of SAA approvals in NZ

mowgli
Mar 27 2018 14:01

This question directed at Pluto and AlecK

Consider a miniature circuit breaker that was manufactured in China and imported into Australia under SAA certificate of approval. The standard noted in the certificate matches the applicable standard in ESR schedule 4. The SAA certificate number exists in the SAA online database. The non-paywalled details match the certificate provided with the MCB.

As a high risk product this MCB requires approval before it can be offered for sale in NZ. The SAA website claims that they are accredited to certify products for sale in Australia and NZ.

How does SAA approval tie into ESR86? Where do I find \"the Gazette\"? If the product was a DMRA then what status would the SAA approval have?
   

Andrew
Mar 27 2018 14:28

I don\'t know if I can fully answer your question but can give a few pointers...

The Gazette is at https://gazette.govt.nz

I believe SAA is one of the bodies that can issue certification acceptable for EESS, meaning you might be working under ESR86A rather than ESR86, but I can\'t say without checking the Gazette - it might be faster to just ask WorkSafe directly.

The EESS database is searchable at https://equipment.erac.gov.au/Registration

You\'d need to confirm that the supplier is registered as well as the product.

Hope this helps.
   

TheDon
Mar 27 2018 17:26

A useful link for you maybe .

https://worksafe.govt.nz/topic-and-industry/electricity/appliances-and-fittings/high-and-medium-risk-products/
   

mowgli
Mar 27 2018 18:29

Excellent advice. Thanks guys.
   

mowgli
Mar 27 2018 22:40

Hmmm so it gets complicated.

The MCB is one of a number of fittings that may be supplied in an assembled container building. All necessary approvals are in place to import these into Australia.

It looks as though there will be sufficient documentary evidence to show compliance with schefule 4 standards. Examination of the manufacturing process, design and finished product should demonstrate compliance with 3000 with minor changes required to suit NZ. It appears therefore that there may be sufficient grounds to determine electrically safe for the purposes of connection to a supply.

But that doesn\'t meet the importer\'s obligations if they plan to sell or supply the house. Given that the fittings are all EESS listed they could apply for Supplier approval under that system for each fitting.

Alternatively they could issue SDOCs for the DMRAs and apply for approval for the high risk articles while citing SAA approvals as evidence of testing and compliance.

It\'s one big cans of worms. I think the bottom of the can is some way off.
   

AlecK
Mar 28 2018 07:03

for fittings that are both DMRAs & DHRAs, the two requirements are cumulative.
In other words, having an Approval / deemed Approval does not negate the requirement for an SDoC as far as I can see.

As installers, we can rely on an SDoC that meets the requirements set out in ESR 83. But we\'re not required to rely on it, we have to make a call.


   

mowgli
Mar 28 2018 07:25

AlecK,
Is it possible to do an SDOC for the complete assembly? As I understand it they are all stamped out identical. Accepting they\'d need a new SDOC for every design change.
   

AlecK
Mar 28 2018 08:10

I suppose it\'s possible, if the assembly was compliant to a Standard (which seems unlikely other than for eg a switchboard).

But for anything that\'s a DMRA, where an SDoC is required, the SDoC has to not only refer to the relevant Standard(s) but also point to the test report.
   

mowgli
Mar 28 2018 20:16

Are SDOCs required in Australia?
   

AlecK
Mar 28 2018 23:01

No they\'re an NZ thing
   

AlecK
Mar 29 2018 08:08

need to clarify / correct yesterday morning\'s post.

For DMRAs [ESR 83] there are two pathways to \"deemed safe\"; either SDoC [ (2)(a)] or deemed approval [(2)(b) ].
But only the SDoC pathway can be relied on when issuing CoC / ESC [(3A)].


So if there\'s a deemed approval, no SDoC required - and an increasing number of suppliers are likely to adopt this pathway.

Meaning we\'ll need to get used to trawling through the EESS registers (BOTH suppliers & things); but even when we find the item has a deemed approval we won\'t be able to rely on it.

I don\'t believe a deemed approval for DMRA+supplier [ESR 83A] is good enough for a DHRA Approval; the wording of ESRs 84, 85 & 86 is sufficiently different to make me think the DHRA Approval is a different beast. In which case all the things that are both (eg RCDs) will need to qualify under both systems.