In this article, produced for PE before his recent passing, the late Paul Skyrme looks at the relationship between the Electricity at Work Regulations and BS 7671.
This article intends to explain the inter-relationship between standards and legislation, using BS 7671 and the Electricity at Work Regulations as the reference point. Firstly, it should remembered that standards are not compulsory. They may be considered best or good practice, or even the bare minimum (BS 7671, I’m looking at you), but they’re not mandatory for compliance with the law.
For work being undertaken by electricians in the UK, one of the most important pieces of law is the Electricity At Work Regulations 1989 (as amended), referred to from here forward as EAWR.
EAWR applies to all electricians or anyone undertaking electrical works, regardless of where those works are being undertaken – a private home, a shop, a hospital, a railway, or the Houses of Parliament.
If we look at EAWR in a little more detail, we’ll see that some of the requirements will fall under the remit of the designer of the installation, some under the remit of the installer, and some under the remit of the person undertaking the inspection and testing.
Even with this quick glance, we can see that the legislation is far-reaching but, hopefully, if we follow BS 7671, we should meet the requirements of EAWR. But, how is this so?
We have the legal requirement, EAWR (Legislation), and our means to comply with this when at work in whatever capacity we work with the installation in BS 7671 (Non-mandatory standard).
BS 7671 even has an introductory note written by His Majesty’s Health and Safety Executive (HSE) suggesting and endorsing the use of BS 7671 to meet the requirements of EAWR.
In a nutshell, this gives us a piece of legislation – EAWR – and the means to meet it – BS 7671.
If we now consider BS 7671, we will find Appendices in there labelled ‘Normative’ and ‘Informative’. Only one Normative Appendix – Appendix 1 – lists the standards referenced in BS7671.
Why are they in there and why is this important?
They are there to illustrate that these standards relate to the products we purchase to complete our electrical installations under BS 7671. This ensures that the products are safe to use and that a product made to these standards should be safe to use anywhere in the European Economic Area – not just the EU, but slightly further afield.
What does Normative mean?
In this situation, applied to this Appendix, Normative means that the Appendix itself forms part of the requirements for BS 7; that is, to comply with BS 7671, one must comply with the requirements of Appendix 1.
Much of what is listed in Appendix 1 are product standards, so the designer, constructor, inspector and tester have little or no control over them. Is that important? Perhaps, perhaps not.
If the designer is also specifying equipment, then to comply with BS 7671, the equipment specified must meet the requirements of the product standard listed in Appendix 1.
Before you ask, this doesn’t mean the designer needs to start by buying the product standard and then getting their hands dirty to check that the selected product meets the requirements. The person selecting the product to be used should instead satisfy themselves that the product is compliant by using the tools outlined in the legislation which facilitate this. This is often known as ‘undertaking due diligence’.
What tools are available and how do we use them?
The tools are the CE/UKCA (I will use CE from this point forward to mean both CE & UKCA) marking and the Declarations of Conformity (DoC). Electrical products must be safe to be placed on the market or otherwise made available in the marketplace.
This requirement extends not only to items for sale to paying clients but also to any equipment made internally to meet the needs of the business. So, a test adaptor made internally within the company should be CE-marked.
For now, we’ll ignore internally designed and manufactured products and will only consider products selected and purchased on the open market to construct an electrical installation, such as isolators, light fittings, switches etc.
How would we check these?
Firstly, we need to get hold of the DoC for the product. The structure and content of the DoC are defined in the law. This law is the Low Voltage Directive (LVD), as amended, and is transcribed into UK law, mirroring the safety requirements of the LVD, as the Electrical Equipment Safety Regulations (EESR). On the DoC, a requirement is to list the standards used for compliance with the legislation.
So, in this case the due diligence called for would be to verify that the product standards listed on the DoC meet those required by the legislation and that this standard is also listed in BS 7671.
The product manufacturer is responsible for compliance, following the product standard and completing the DoC. There is, therefore, the possibility of the information being incorrect or misleading on the DoC or that the product will not meet the requirements of the product standard.
There’s nothing that the specifier can do concerning this except, perhaps, selecting products from reputable and reliable manufacturers with a good reputation in the supply chain and procuring these items from reliable and reputable sources.
The aim of this article has been to provide a brief overview of how a standard (BS 7671) can be used to meet a piece of legislation (EAWR), what a Normative reference in the standard is, and how this Normative reference can be used to assist in ensuring that products selected for use under BS 7671 meet the relevant product legislation (EER) and assist in compliance with the EAWR.
Further information and background can be found at the following links:
● Health and Safety at Work etc. Act 1974 (legislation.gov.uk)
● The Electricity at Work Regulations 1989 (legislation.gov.uk)
● The Electrical Equipment (Safety) Regulations 2016 (legislation.gov.uk)
● Directive 2014/35/EU of the European Parliament and of the Council on the harmonisation of the laws of the Member States relating to the making available on the market of electrical equipment designed for use within certain voltage limits (europa.eu)
● The Electricity at Work Regulations 1989. Guidance on Regulations (hse.gov.uk)
PAUL SKYRME – 1966 – 2023
It is with great sadness that PE has to report the death of this article’s author, Paul Skyrme, following a long battle with illness.
Paul’s career began with an apprenticeship in Industrial Maintenance with Austin Rover, followed by various factory maintenance roles with global industrial manufacturing organisations.
He self-funded his HNC in Engineering and undergraduate studies with the Open University whilst employed as an Installation & Service Engineer for a global high-precision machine tool manufacturer. Paul completed his BSc. with 1st class honours, followed by his Master of Engineering with the Open Univeristy.
Paul went on to hold several roles in manufacturing engineering and, in the early 2000s, was heavily involved in developing what has since become Industry 4.0. Through his company, Abertawe Engineering Services, his later work involved electrical product and machinery safety consultancy for CE marking to the LVD & MD for equipment manufacturers as well as CE audits and PUWER compliance assessment works for end-users.
He became an IET fellow, registered with the Engineering Council at the IEng level, and was a TUV Nord Certified Machinery Safety Expert. He was also an IET volunteer, Professional Registration Advisor (PRA), and EngTech Assessor.
After being taken ill with stage 4 cancer in November 2020, Paul kept himself busy with voluntary work with the Electrical Safety Roundtable and the IET, including participating in the EngTech Elec programme & BS 7671 Technical Regulations publications.
As someone who gave up so much of his time and knowledge to support and encourage others, and was widely regarded by his peers as one of the ‘real’ industry gurus, Paul’s loss to an industry that he loved is enormous.
We’d like to express our sincere condolences and best wishes to Paul’s family, friends and colleagues.