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Posted By Topic: UK caravans and their sockets

Satobsat
Mar 06 2019 23:37

So I have read numerous times on this forum that UK sockets in caravans can remain in service, yet Worksafe 2.4 at the below link states that this a contravention of AS/NZS 3000:2007 1.7.3 Equipment selection. Anybody got anything to say about this?
https://worksafe.govt.nz/topic-and-industry/energy-safety/electrical-and-gas-safety-requirements-for-caravan-motorhome-and-boating/
   

toyoto
Mar 07 2019 07:53

AlecK has a lot to say about this,

https://www.electricalforum.co.nz/index.php?action=more_details&id=1537940448
   

Satobsat
Mar 07 2019 08:33

Hi Toyota yes he does and I have read all the past threads on this matter. Yet the Worksafe Energy Safety stance on this states the opposite of what Aleck states. Please see section 2.4 of the link I attached above.
   

Satobsat
Mar 07 2019 19:33

Thanks Toyota I thought I had read them all nut must have missed that one and din't have time to have a proper look at it earlier. Do you know if anybody has talked to worksafe about it?
   

gofishing
Mar 08 2019 07:56

Copied from link above to save a bit of scrolling -

2.4 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.

Any Residual Current Device (RCD) protection within the recreational vehicle must also meet NZ requirements (ie if the RCD protection does not trip for residual pulsating direct currents it will be deemed unsafe in NZ).
   

Satobsat
Mar 08 2019 09:26

From toyotas link.

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\".

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.


   

AlecK
Mar 08 2019 10:57

Latest advice from ES (as reported by another Inspector, who rang them, to a recent meeting of inspectors) is that having UK sockets is not a WoEF matter so in fact can pass WoEF without having to change; but they will prosecute anyone who changes them but uses non-switched "3112" sockets - because the work must comply with "3000" and 4.4.4 requires a switching device.

They might prosecute, but winning the case will be hard if the original sockets were non-switched because replacement of fittings is maintenance, and ESR 59(3)(b)allows "original condition" as an alternative to following "3000".

Not that I want to encourage anyone to use un-switched sockets; it's a bad idea. There are perfectly good options avaialable, and they should be used.

ES's stated objection to non-standard sockets is that their presence encourages use of travel adaptors; which ES do NOT want. Fiar enough; far too many travel adaptors are unsafe, and using adaptors is never a good option even if you can find a decent one.

But the way to deal with it is not to twist the rules, or issue "official" interpretations that are not soundly based on ESRs; let alone threaten prosecutions. The answer is to do a bit of public education; especially of caravan importers (shouldn't be difficult - they're all out there advertising the product. Importers are the ones creating the problem; but they're not being made to deal with it. If education doesn't work, and to deal with the cowboy element; could even make it an offence to import the damn things without having them converted. I know getting regs in place is difficult & takes tim; and there's little border control. But with a suitable reg, any found later could be followed back through the registration to whoever imported; and a couple of prosecutions at that level would see 90 % of the problem dealt with.

Also, if necessary - the WoEF requirements could be changed. "3001" is being revised right now; will be interesting to see whether ES suggest a change that would force foreign sockets to be replaced.

Issuing interpretations that are so easily proved wrong, in an attempt to shift responsibility for enforcement from ES to us; just makes them look silly.
   

Satobsat
Mar 08 2019 11:09

Thank you for the update Aleck.