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Posted By Topic: Regs Question - 74A Interpretation

zl2aj
Oct 08 2018 09:09

Hi all.

I have been in a discussion regarding the following interpretation of the Regs and am keen to hear the opinion from the learned on here.

ESR74A 1AA c
This regulation relates to any PEW on any fitting that supplies an installation (or part) with electricity

This seems to infer that PEW on fittings in works that supply one (word \"an\") installation requires an ESC.

Example - Changing out a pole fuse carriage as it has burnt out - PEW on fittings that supply an installation (as written).

However the counter to this thinking is that the title of the section \"Part 5 Installations\" and sub part \"Certifying Installations\" means that this is relating to installations, not works.

So the question is - does the headings of the sections impose weight onto the actual words written within the regulation?

Im on the side of the former as the words written are meaningless if they arent referring to the installation (as a and b already cover those scenarios) however I have been told from above that I am reading it wrong. I however am not convinced. Thoughts please?
   

Sarmajor
Oct 08 2018 21:21

I can find no fault in your logic regarding issuing an ESC for the replacement of a pole or pillar fuse base based on the wording of Reg 74A (1AA) (c).

Seems to me that if pole / pillar fuse bases were exempt from Certfication they would not have included section (c) in the regulation.
   

zl2aj
Oct 09 2018 08:43

Yes thats my thoughts too - why have it there otherwise.
   

AlecK
Oct 15 2018 16:31

That bit of the ESR was specifically designed to include supply fuses & similar. Otherwise if the \"final step that will allow electricity to flow\" [refer ESR 73A (5) happens to be the connection of active to fuse outside the boundary (and therefore not being part of \"an installation\") no ESC would be required for (for example) an entire new house; because until that moment, nothing has been connected to a supply of electricity.


   

AlecK
Oct 15 2018 16:32

\"and similar\" includes connection to neutral.
   

zl2aj
Oct 18 2018 13:17

Hi Alek.

For the connection to bit I get (called for by 73A)

But what if the PEW is entirely within works. EG replacing a fuse base that has burnt out, or a repair on a burnt out jumper or connection to an installation (within works).

ESR74A says yes this PEW would require an ESC, but the interperetation I have received has been no - because the section of Regs is dealing with Installations - not Works. The purest in me says so what, but I have been caught out on such things in the past so am keen for your thoughts as to how much weight should be given to the words of a reg by the title of the section / subsection?
   

AlecK
Oct 18 2018 18:11

A good point, and I agree such matters do carry meaning. But I don\'t think the fact that Part 5 is titled \"safety of installations\" and sub-part \"certifying installations\" can be used to exclude any of the regs in that Part / sub-part from applying to works.
Especially when we know that this particular bit of ESR 74A was added specifically to include connections made on works at \"any fitting that supplies an installation. That\'s clearly within the scope of the Part\'s title.
That phrase can ONLY mean fittings of works, because otherwise would be covered by either (a) or (b).

There\'s a lot of things that happen on works that can adversely affect safety of installations. In fact the safety of every installation is dependent on things being OK on the \"works\' side. eg no EPR, and PEN conductors being in good nick, and short circuit & fault protection for mains being in place (as required by ESR 32); all of which a matters relating to works.

However I don\'t believe it goes any further upstream than the supply fuse; because fittings further upstream supply more than \"an\" installation (singular).
Same concept as we have in the Act, where \"point of supply\" depends on \"exclusive fittings\".



   

zl2aj
Oct 18 2018 21:28

Thanks for your interpretation Alek - yes I agree the word \"an\" is important. Fittings that supply more than one installation would not be caught by this.