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Posted By Topic: EWOF on motorhome

north1
Sep 26 2018 17:40

Have just knocked back a renewal EWOF on a European motor home with un switched sockets.
Owner was upset with the news since the motor home had a EWOF from new with another inspector when it was imported by NZ firm.
He then did a shop around and found a inspector that said all o/k with having un switched sockets and issued a new EWOF.
WHAT the h\'\'\' is going on or am I missing some thing with my views on un switched sockets in motor homes.

   

AlecK
Sep 26 2018 18:25

Maybe you are.
What was your basis for knocking it back?
What rule did it breach (of the rules for issue of WoEF)?
   

north1
Sep 26 2018 19:10

My reasons to not issue a EWOF for un switched sockets are.
The requirements in AS/NZS 3001 calls up compliance with AS/NZS 3000 in section 3, “3.1 Scope” and therefore I have been advised that AS/NZS 3000 Clause 4.4.4.1 applies.

Also have using guidance from the Worksafe Guide Electrical and gas safety requirements for caravan, motorhome and boating. See para 5 in clause 2.4 of that guide.

If I have it wrong in not issuing EWOF for un switched sockets can it be shown what regs allow the use of un switched sockets in a motorhome.
I am o/k with sockets rated at 10 amp and have not used for general use e.g behind micro wave in cabinet.
Also with the use of sockets that have built in isolating switch.

   

north1
Sep 26 2018 19:39

Have added copy of Worksafe Guide Electrical and gas safety requirements for caravan, motorhome and boating. See para 5 in clause 2.4 of that guide.
Was also referred to in the non issue of EWOF on imported German motorhome

Clause 2.4 para 5 is
Importing recreational vehicles with electrical installations.
Recreational vehicles imported from foreign countries must comply with the
New Zealand electricity legislation and applicable standards. A licensed and
registered electrical inspector will need to assess any imported installation
against Part 1 of AS/NZS 3000 before carrying out the usual inspection for a
warrant of electrical fitness WoEF.
The WoEF must be issued in accordance with AS/NZS 3001 for caravans and
other recreational vehicles. A WoEF using the above standards is verification
that an installation is suitable for continued use. It makes an assumption that
the installation was installed in accordance with the regulations in force at the
time of installation.
It is not possible to issue a WoEF for an imported recreational vehicle that uses
any non-Standard NZ socket outlets, such as a UK plug type. This is because
the assessment against Part 1 of AS/NZS 3000 for an imported caravan would
contravene 1.7.3 of the standard.
The replacement of the foreign configured socket outlets must comply with
a NZ type, AS/NZS 3112 socket outlet configuration.
Any replacement work must comply with AS/NZS 3000 parts 1 or 2, which
would require each outlet to be controlled by a separate switch.

   

AlecK
Sep 27 2018 09:35

The bit in that guide about \"foreign\" socket types not being allowed is just plain wrong; being based on an incorrect interpretation of clause 1.73 of \"3000\".
But since that doesn\'t relate to the immediate question about sockets without switches; put that to one side.

The requirements for issue of a WoEF are set in ESR 78; and - as the guide says - include (for imported units) an assessment for compliance with Part 1 of \"3000\"; and (for all units) a WoEF check in accordance with \"3001\". The words that matter here are \"issued in accordance with AS/NZS 3001\".

That does NOT mean the units must fully comply with \"3001\". It means the inspector must follow what \"3001\" says about issuing a WoEF. There\'s a BIG difference.

In 3001, clause 3.10 covers verification of what ESRs call a \"connectable installation\"
3.10.1 is for initial verification; ie when the unit is built. Clause 3.10.2 says \"the reverification requirements for the issue of a NZ Warrant of electrical fitness are detailed in Appendix C\".

In other words, if it\'s not in AppC, it doesn\'t get considered as part of the WoEF inspection.

Secondary point: note the official term is \"Warrant of Electrical Fitness\", same as in ESRs; so the abbreviation must be WoEF, not EWoF. Not hugely important perhaps, but careful reading is the ONLY way to get to correct interpretation. And corect interpretation is what Inspectors are supposed to be able to arrive at.

So the requirement you quote, clause 3.1, pointing in this case to (presumably) clause 4.4.4 of \"3000\", has NO bearing on issuing a WoEF. And since you won\'t find any reference in either Part 1 or App C to sockets needing to have a functional switch; it follows that lack of a switch is not grounds for declining to issue a WoEF.

This exact point came up at a recent meeting of inspectors, and the conclusion we reached was that while we may not like it, it\'s not our preferences that count but what\'s in the Rules. If the Rules need to be amended, there\'s a process for that.

There are plenty of other requirements of both \"3001\" and \"3000\" that must be followed when wiring a connectable installation, but don\'t count for WoEF.

So to answer you original question, yes you were missing \"something\". A very important and basic \"something\"; which is knowing what rules are applicable to the job we are doing.

---------------
Coming back to the foreign sockets issue, because it probably seems big-headed of me to say ES\'s guideline is flat-out wrong. It\'s certainly a statement that shouldn\'t be made without providing evidence. But it\'s important to realise that just because ES publishes something, doesn\'t automatically make it so. advisory documents don\'t count, and won\'t protect us. The only documents that matter legally are the Act, the ESRs, and the Standards & ECPs cited by ESRs.

The full \"reason\" for the guidelines statement is the author\'s belief that a socket must comply with the relevant AS/NZS (eg \"3112\")

It starts with 1.7.2 which sets three \"essential requirements\" for selection and installation of electrical equipment.

Then 1.7.3 says equipment is \"deemed to satisfy that requirement if meets either of 2 conditions. The first of these is the essential safety requirements of AS/NZS 3820.
The second is a two-parter; (i) the relevant AS/NZS; and (ii) where a relevant AS/NZS does not exist, a recognised international or national Standard.

The guideline\'s author believes this means that because there\'s an AS/NZS for sockets (in fact several of them); then compliance with an international or national Standard isn\'t an available option. Which is perfectly correct interpretation of para (b), but ignores the option of para (a). If the \"foreign type socket satisfies AS/NZS 3820, it satisfies 173 and therefore 1.7.1. And there\'s absolutely NO suggestion that, for example, a typical UK socket does not comply with AS/NZS 3820.

While ESRs cite \"3000\" parts 1 & 2 as alternatives, , in fact the structure of \'3000\" is that compliance with Part 2 automatically gives compliance with Part 1.
Clause 4.4.1 sets the socket types that are permitted, with 4.4.4.1 listing 4 Standards - not including the one for UK sockets (BS 1363-2). But as alwats need to read carefully. the opening sentence, the one that sets up the list, also says \"or Standards equivalent thereto\". Which lets in UK sockets.

Further, if you look at latest edition of \"3000\" you\'ll find specific rules for installing UK & other \"foreign\" type sockets in NZ. In TWO places. One is for clause 7.9 EV charging; UK sockets are specifically allowed (though un-switched ones are excluded). The other is 4.4.4; where the new 4.4.1.1.2 covers alternative pin configurations.

Point being, if Part 2 allows them, then it\'s simply NOT true that Part 1 forbids them.

So the statement in the Worksafe guide that \"it is not possible to issue a WoEF for an imported recreational vehicle that uses any non-Standard NZ socket outlets, such as a UK plug type\"; is utterly and completely wrong.

If they don\'t want UK plug types to be allowed; then - like us - they must use the Standards amendment process. Or alternatively, issue a prohibition notice under ESR 87. But since the words in clause 7.9 came directly from Energy Safety; the chances of either of these things happening is remote.

-----------------

But while it\'s legal for UK and other foreign socket types to remain in service, and a WoEF can be validly issued; that\'s not very practical unless the associated plug-in equipment has UK type plugs to match. Which may be OK for the microwave, but isn\'t much good for a general purpose socket.

People will generally want to use normal NZ appliances with normal NZ plugs - generally \"3112\" type. Use of travel adaptors is NOT a good idea. Many of them are very unsafe. So while sockets don\'t have to be changed, some should be.

Changing a socket is PEW. It\'s maintenance of an installation, so ESR 59 applies. one of the options is \"in such way as to comply with AS/NZS 3000\"; which would bring in 4.4.4 and require a switching device. But another option is maintaining in original condition; and under this one if the existing sockets don\'t have switches the replacements don\'t have to either.

Again, we might not like it much, and it\'s certainly not \"best practice\"; but the rules are not about \"best practice; they\'re about \"minimum acceptable practice\".


   

toyoto
Sep 27 2018 10:27

If the UK or euro sockets are swapped out after it has arrived in NZ, then would it have to be done according to 3001, and need a switch?
   

AlecK
Sep 27 2018 15:26

No.
swapping is replacement, and that doesn\'t have to comply with 3001.

WoEFs for on caravans & motorhomes have to follow the WoEF rules of \"3001\" (plus, for imported, Part 1) because of ESR 78.

Installation work on caravans & motorhomes has to follow \"3000\" & \"3001\" because of ESR 60, which covers \"installed, tested, inspected and connected\" but not maintenance.

Maintenance is ESR 59; and as I said, ESR 59 allows 3 methods; none of which refer to \"3001\".

   

toyoto
Sep 27 2018 19:41

if only all inspectors followed the same rules. . .
   

Kingswell
Sep 27 2018 21:24

Have a look at this product: https://www.affordablecaravans.co.nz/Caravan-parts-store/Electrical/Switches,-plugs-,-cables-etc/NZ-Socket-Converter , from Affordable Caravans Christchurch.
   

AlecK
Sep 28 2018 06:59

looks ideal
Hope they have an SDoC.

While un-switched is technically compliant, I much prefer switched.
   

pluto
Sep 28 2018 08:14

HPM also has a simular product, but your local wholsaler is unlikely to have them on the self, but they can get them from the HPM NZ warehouse.
   

toyoto
Sep 28 2018 08:55

Another question regarding swapping over overseas sockets.

If the UK or euro socket is an auto-switching type then would the replacement also have to be auto switching/regular switched socket?
   

pluto
Sep 28 2018 10:04

toyoto Sep 28 2018 08:55

Your comment 1

Another question regarding swapping over overseas sockets.

If the UK or euro socket is an auto-switching type then would the replacement also have to be auto switching/regular switched socket?

My comment 1
If the caravan has evidence that it was built in the UK or Europe to IEC 60364-7-721 or BS 7671 (UK wiring rules) has no requirement for a function or control switch on socket outlets, so the likelihood that a functional or control switch being provided is very low, or will never be provided.

My comment 2
If AS/NZS 3001 Appendix C is being used as the checks and testing required for the issue of a WoEF, the linkage to AS/NZS 3000 requires that a functional or control switch is to be provided.

AS/NZS 3000:2007 +A1 +A2 clause 4.4.4.1 requires the use of a functional or control switch adjacent to the socket outlet.

Exception 3 of that clause permits the use of an auto-switching type socket outlets.
   

toyoto
Sep 28 2018 10:47

So Aleck is saying switches not required, and Pluto is saying switches are required?
   

pluto
Sep 28 2018 12:00

Note very carefully that my comment 2 above if you was using AS/NZS 3001:2008 Appendix C as the check list for the issue of a WoEF, the use of control switches or functional switches is required.

Confirmed by the WorkSafe NZ information sheet re overseas built caravans and motorhomes.

The use of a Part 1 solution, say using the IEC 60364 and IEC 60364-7-721 is prevented or blocked by ESR 2010 regulation 60 (1).

AS/NZS 3001 is currently being amended to make some major changes, but they will NOT be applicable until at least late 2019 as they require an amendment to ESR 2010 at apply.

The amendment will address some of current operational problems concerning connectable installations, of which the need for a control switch on a socket outlet is just one issue of approx 6 other major issues.
   

AlecK
Sep 28 2018 12:33

As I stated in an earlier post, there is NO reference in the relevant parts of AppC of 3001 (ie clause CC6 & C7) to switches for sockets. Nor to type of socket. And there\'s NO linkage to \"3000\".

There\'s not even a reference to Type A RCDs, so upgrading imported units has to be done using Part 1 [specifically 1.5.6.3(e)]
   

AlecK
Sep 28 2018 12:47

For toyoto\'s specific question about replacing an auto-switched socket ; no the replacement doesn\'t have to be an auto-switching type.

Currently ESRs don\'t specify the limits of what counts as replacement. Previously they did, by referring to \"the replacement of any fitting with a fitting of appropriate size, type, and rating for the electrical circuit\" as not requiring to be certified [ESR 66, up until the 2012 Amendment that brought in the classifications of PEW as low risk, high risk, and general].

There has never been anything to suggest that the re-writing of the ESRs in 2012 intended to alter that underlying principle. But it would be nice to have that clear wording back to cover the point of what \"replacement\" can be and when it stops being replacement and starts being an alteration - which of course requires a CoC.

So, for example, you can replace a socket with a PCU, or vice versa - provided it fits under one of the 3 options of ESR 59(3).

An auto-switched socket is a form of switched socket. so the replacement clearly doesn\'t have to be another auto-switched socket. And in fact could be replaced with an un-switched socket; though I don\'t see that as good practice.

   

north1
Oct 01 2018 12:13

Thanks to Alex re his explanation re un switched sockets in a 1st EoWF renewal on a new motor home that was imported from Europe.
Is it good practise from the first electrical inspector to pass on to owner a dossier on what was checked under Part 1 AS/NZS 3000 with the original EoWF which is issued under AS/NZS 3001.
My understanding from feedback from other inspectors is if you don\'t know what was checked the 1st time round you have to do the Part 1 AS/NZS 3000 again before issuing new EoWF.
This question relates to European motor home imports.
   

AlecK
Oct 01 2018 12:45

The Part 1 assessment is required for EVERY WoEf on an imported unit. So we can\'t rely on a previous Inspector\'s assessment.

But yes I believe it\'s a good idea to have a dossier that includes details of what was found. Eg if an isolating tx was found to have a label indicating compliance with relevant Standard. Or if fixed wiring was found to be marked with a particular voltage rating.
Just that setting that up takes time; although most UK units come with a folder / pouch of relevant info so not too hard to add to it.

I\'ve had a few tries at setting up a checklist-cum-record sheet for a Part 1 assessment; but there are just too many variables

For the App C stuff, I always follow a checklist; and I record record how many sockets I found (and of course tested). Doen\'t cover me if I missed one. I also record what Class I fixed-wired appliances I found & checked earthing of.

Remember also that unlike an \"electrical installation\", a \"connectable installation\" DOES include appliances; so their safety / suitability has to be checked as Part of the Part 1 assessment.
   

Sarmajor
Dec 10 2018 13:20

In the latest caravan magazine the NZMCA electrical technical adviser includes a section about switched sockets in caravans etc and refer to a Worksafe publication that also fails to grasp that WOEF’s are issued in accordance with appendix C of 3001.

New work must of course meet all of the relevant standards.

If they want to mandate switched socket outlets then this is the section they must amend.

And then it will apply going forward.
   

pluto
Dec 11 2018 06:54

Just note what I said on the Sep 28 2018 @ 12:00


AS/NZS 3001 is currently being amended to make some major changes, but they will NOT be applicable until at least late 2019 as they require an amendment to ESR 2010 at apply.

The amendment will address some of current operational problems concerning connectable installations, of which the need for a control switch on a socket outlet is just one issue of approx 6 other major issues.

The use of a PV array, battery and inverter and the need for a RCD in all caravans and motorhomes is also being addressed.


   

Sarmajor
Dec 11 2018 18:26

Pluto,
I have read appendix C several times payin particular attention to Section C6 & C7 and can find no reference to switches for socket outlets installed in caravans.

As this is the checklist for issue of a WOEF the items on this list are the only things that I have to consider (other than Electrically unsafe things).

I agree that for a new build all aspects of 3000 & 3001 have to be followed.

For imported units a Part 1 assessment is required. There is no requirement for switches on socket outlets in Part 1. There is no reason or requirement to include Part 2 in the assessment.

Reg 59 allows repair to original condition. Replacing the socket outlets on an imported British van is simply replacement of fittings and Reg 59 applies.

I appreciate that certain people may want to have things their way but they can’t take rules from all over the place and bandaid them to get the answer they want.

If they want to mandate switched socket outlets in Caravans etc then they have to amend AS/NZS3001, simple reallly.
   

AlecK
Dec 12 2018 10:01

since Pluto has effectively repeated his earlier post; lets look at what that post (Sept 28 2018 @ )1200 included:

1
"using AS/NZS 3001:2008 Appendix C as the check list for the issue of a WoEF, the use of control switches or functional switches is required."

Balderdash, as I pointed out then, and Sarmajor states now; there's NOTHING in either Part 1 or App C that requires a switch

2
"Confirmed by the WorkSafe NZ information sheet re overseas built caravans and motorhomes."

Which is based on a completely incorrect interpretation, and can easily be shown to be wrong on several key points. Worksafe should be ashamed to be publishing such drivel.

3
"The use of a Part 1 solution, say using the IEC 60364 and IEC 60364-7-721 is prevented or blocked by ESR 2010 regulation 60 (1)."

True, but not at all relevant to issue of a WoEF.

As for the amendment, we'll have to wait and see what is and isn't included; but history shows that not all Pluto's announcements actually happen. More importantly; what the rules might be in future has absolutely NO relevance to what they are right now.