Mains lead (flex) replacement. Legal implications.

['LIVEWIRE?']

Am I correct that if, when performing a chargeable repair, the item(s) being serviced are fitted with the old-style (Red, Black, & Green) mains cable, and/or the old type 13 Amp Plugs with uninsulated L & N Pins, it is a Legal Requirement to replace these with modern type approved equivalents. Items for own use, I know, can be left with the original mains leads & plugs, provided of course that they are in good, safe working order.

[Station X]

It would be helpful if anyone replying to this thread quoted the act of parliament or regulation concerned. Hearsay is not good enough.

[paulsherwin]

I believe there is a distinction in law between repairing something and modifying it, but I'm not aware of any relevant court cases. The gist is that a repaired item only has to comply with the electrical regs in force when the item was manufactured, while a modified item becomes subject to current regs. This is why, for example, fitting a capacitive dropper to an AC/DC radio can be a bit iffy legally.

As Graham suggests, anybody seriously concerned about this issue should obtain specialist legal advice from a suitably qualified person.

[Nuvistor]

FYI. Not sure if this covers the subject.
http://www.legislation.gov.uk/uksi/1.../contents/made

[David Simpson]

Best thing is to contact the IET. They have a large website including enquiries & info. They are also responsible for providing the "Wiring Regulations", currently the 17th Edition,(Also known as the IEE Regulations).
Thinking back to the thread(in this sub-section - sticky) containing a discussion on "The Repair Shop" on BBC2 back in March - mention was made regarding PAT testing - which is also a mandatory "Must".

Regards, David (MIET)

['LIVEWIRE?']

I should add that, when carrying out a chargeable repair, I always ensure that mains leads and plugs are of the modern types.

[kalee20]

Originally Posted by paulsherwin

I believe there is a distinction in law between repairing something and modifying it, but I'm not aware of any relevant court cases. The gist is that a repaired item only has to comply with the electrical regs in force when the item was manufactured, while a modified item becomes subject to current regs. This is why, for example, fitting a capacitive dropper to an AC/DC radio can be a bit iffy legally.

Very iffy I'd suggest! On the one hand, you could argue that a burned-out dropper is obsolete and on the basis that a replacement can't be sourced, the 'repair' used a near-equivalent, ie a capacitor. On the other hand, you can also argue that replacing with a capacitor doesn't even meet the original equipment spec - you can't operate on DC mains any more.

I do recall a friend who ran an antique/junk shop in the 1980's being visited by Trading Standards over selling stuff with red/black/green mains leads - the requirement was to put a wrap of labelled adhesive tape around the lead identifying the conductors.

But repairing and selling are two different activities. When an authoritative answer is found, whether IET forum or otherwise, it might be helpful to share it with us

[David Simpson]

I guess that we are talking about the bog standard 3182Y & 3183Y Cable Industry codes. They were for many years under BS6500, but BS7671 is more applicable these days, I understand. Then there is the CENELEC & BASEC regulations which defer to EU regulations.

All very confusing it would seem. I'm sure that booklets &/or information leaflets can be downloaded from the IEE, or Government websites. Your local electrical goods shop, or council trading standards office might also provide info.

Legally the onus is on the trader to keep up with current regulations & standards.

Regards, David

PS. Aren't all self-employed electricians/traders supposed to register with the local council building dept., and provide certification such as NICIEC Registration ? I seem to remember that the NICEIC used to provide leaflets & booklets, etc. on wiring.

[cmjones01]

With regard to three-phase, many countries never used different colours for the three phases at all. They were all the same colour, but with labels where necessary. I understand that pressure from the UK was one of the things which led to the current brown/grey/black colour scheme, in which the three phases are identifiably different. In this instance, the harmonised standard is actually closer to historic British practice than to that of other countries.

Chris

[turretslug]

Surely the appliance lead harmonisation would have been done by an organisation with wider international remit than the (as-was) EEC- more likely the IEC? I thought that the old red-black-green British colouring was stupid anyway, as it introduced dangerous ambiguity for the red-green colour-blind (the most common colour-blindness). Having a stripey wire for the crucial safety earth was welcome common sense. Similarly in the course of work over the years, I encountered a few cases of installations where single-phase blue (neutral) was confused with three-phase blue (live) with destructive results. In one case, a night watchman had plugged his BS4343 16A mobile home lead into a shiny new distribution panel with a large number of "red" three-phase outlets and a single single-phase "blue" outlet. He came up to me saying that his lights had blown, smoke had come out of his VCR and his fridge wasn't working..... Opening the panel showed that (you guessed it) blue neutral for the 240V outlet was connected to blue phase. I never got an answer as to who was responsible for wiring and signing off. The introduction of brown/slate/black (i.e. no blue) was something of a relief.

[Station X]

Gentlemen.

This thread had nothing to do with mains CABLING. It's about mains LEADS or flexes. Let's stay on topic please.

Similarly can we avoid comments about the EU. This is a very divisive issue in the UK.

[G6Tanuki]

On anything I'm doing for someone-else I'll happily replace a mains-lead of unknown age/condition (anything that's visibly damaged, anything rubber-insulated or if it's only single-insulated and/or unpolarised) with a modern double-insulated lead using current colour-codes and a moulded-on plug.

Other power-related modifications can get into interesting discussional lacunae: a single-pole mains switch in the neutral-lead, for example, is OK with me if that's how the manufacturer designed the thing to be.

[G4_Pete]

I do not often do sets for others and very rarly sell anything but when I do I just approach this from the point of view of, if this gets independantly inspected after an incident can I defend the quality of the work and parts used? Was the owner made aware that this is vintage equipment and covers etc must not be removed?

Obviously not legally water tight but demonstrating good paractice has to be in the right direction and in my opinion this may be the first and only line of defence.

Also if I fit 13 Amp plugs I also use boot lace crimps to avoid strand seperation as I believe it is a better job. Certainly better than the practice of fully tinning leads leading to fluid flow of the metal that guarenteed ultimate failure.

Of course then there are the rarer Line Cord dropper sets where blanket replacement without modification is just not an option !!

So I replace plugs every time to insulated pins high quality types and cables on inspection. New colours on sets done for others all be it with some loss of origionality. But from comments above I will investigate moulded plug options.

[MrBungle]

Everything I touch that moves on gets an IEC socket, is earthed properly (bonded and crimped) and separately fused. Electrical safety must come before originality IMHO. I usually replace everything on the primary side pre 1980ish (some right crimes until relatively recently!)

I would never switch on neutral. If you have PME that’s some bad juju. DPDT or switch on live.

[Hartley118]

Originally Posted by 'LIVEWIRE?'

Am I correct that if, when performing a chargeable repair, the item(s) being serviced are fitted with the old-style (Red, Black, & Green) mains cable, and/or the old type 13 Amp Plugs with uninsulated L & N Pins, it is a Legal Requirement to replace these with modern type approved equivalents. Items for own use, I know, can be left with the original mains leads & plugs, provided of course that they are in good, safe working order.

I'm no lawyer, but, like many members of this forum, I've some experience of EU standards and legal approach. Sorry to raise the potentially sensitive EU topic, but any question of 'Legal Requirement' in this context inevitably means 'EU Legal Requirement' under EU law, also applicable in the UK, because electrical standards are harmonised across all EU countries.

We're all familiar with CE marking, compulsory for all products subject to European Directives, a declaration from the manufacturer that the product complies with all relevant Directives. In the case of mains cables the relevant directive is 2014/35/EU, otherwise known, rather surprisingly as the 'Low Voltage Directive'. For bedtime reading, it's available at http://eur-lex.europa.eu/legal-conte...4L0035&from=EN.
A key sentence in the Directive is

'Electrical equipment which is in conformity with harmonised
standards or parts thereof the references of which have been
published in the Official Journal of the European Union shall be
presumed to be in conformity with the safety objectives.'.

There are numerous harmonised British and internalional standards for different kinds of cables. For example, flexible cables with PVC insulation is covered by BS EN 50525-2-11:2011.

Previous posts have referred to the cable colour changes that have been required over the years for harmonisation: all the nice colours like red had previously been used by member states for different conflicting purposes, so safe standards harmonisation has involved convergence on rather dull brown, blue, etc, the only fun colouring being green/yellow for earth.

The key wording in the Directive is that '‘placing on the market’ means the first making available of electrical equipment on the Union market;. This is interpreted as meaning that the Directive is not applicable to secondhand products, whether refurbished or not. By way of illustration, it would be ridiculous to require that any product sold secondhand should comply with RoHS, meaning that all soldered joints should be purged of lead and remade with lead-free solder!

Safety of something like a mains flex on a secondhand product being offered for sale is of course a rather separate and overriding issue, so if it's dodgy, better to change it. It would then be sensible for the replacement flex and plug to comply with current standards.

Martin

[GrimJosef]

Another important distinction here is who the customer is. As far as I can tell, all of the legislation mentioned so far relates to equipment which is being put on the market with a view to selling it to a new owner. In this case if it has simply been repaired to the original specification then it is regarded as second-hand and does not need to meet any new standards. If, on the other hand, it has been modified then it may need to meet those standards. The government's 'chapter and verse' on this are here https://www.gov.uk/guidance/electric...ical-equipment. They point out that the use of 'different types of components' will require the impact of that to be assessed by the modifier. Presumably a plug with insulated pins is a 'different type of component' from one where the pins are uninsulated, for example.

None of this helps the OP, unfortunately. He didn't ask about equipment which is being brought to market. He asked about chargeable repairs, indicating that the equipment would be returned to its owner, not put on sale. That's an entirely different kettle of fish. I'm not aware that there's any legislation relating to that which is more specific than requiring that the work be done to an appropriate standard. As always 'appropriate' would be judged on a case-by-case basis by the courts. In this case G4_Pete's position would seem to me to be a very sensible one.

Cheers,

GJ

[Refugee]

The whole thing could be taken too far if we are not careful.
What if the appliance was shipped new without a plug?
Would it not be counted as a modification to fit a plug to it?

This is just the sort of stupid thing an uninformed official could come up with.

[Hartley118]

Maybe modifying a product and then selling it is a potential minefield best avoided.

Martin

[Rubberfingers]

In the case of a repair, the customer owns the equipment. Changing plugs and undamaged flex, if not agreed previously by the customer may be seen by the customer as carrying out unnecessary and unasked for work. Furthermore, the old flex and plug are still the customers property, as are other parts that are changed, and the customer is quite entitled to ask for them back.

[GrimJosef]

Originally Posted by Refugee

The whole thing could be taken too far if we are not careful.
What if the appliance was shipped new without a plug?
Would it not be counted as a modification to fit a plug to it?

This is just the sort of stupid thing an uninformed official could come up with.

If it didn't have a plug then I think it wouldn't meet the harmonised standards would it ? So it couldn't be CE marked. So it couldn't legally be sold.

If you're saying "What if it was shipped 50 years ago without a plug, when it was OK to do that, and it's sat on a shelf since then and someone now fits a plug to it ?" then that's a different question of course.

But it's still nothing to do with chargeable repairs.

Cheers,

GJ