Hi Pete,
Thanks for your view! Firstly I dare to say it is not a new
issue since I have read some reviews with this concern in the
past plus a quick search of products available on the market
showing some models in exist. I do believe the standard
committee and manufacturers are well aware of it. It must have a
reason to be tolerated or in a lower priority. This forum has
lots of expert and senior and looking for their enlightenment or
common alignment.
Regards,
Scott
On Tue, 17 Jul 2018 at 01:26, Pete Perkins <[email protected]
<mailto:[email protected]>> wrote:
Scott,
In watching this thread it is clear that the
technical assessment and the regulatory certification are two
separate issues but linked by local law so we need to be
cognizant of the regulatory environment.
The technical assessment (per the standard)
is organized by an ongoing group of (fallible) folks who work
very hard to cover all of the risks (usually) from the
product manufacturers point of view (since they seem to
dominate the technical committees). Since the requirements
are usually written in retrospect from experience and,
usually, not organized in a top down approach (using the
usual risk assessment tools – FMEA, etc) it is incomplete is
some (usually) unexpected ways – as you have discovered.
When exposed, the standards committee then scrambles to fill
the hole identified. This is a never ending process,
approaching perfection asymptotically.
All this ignores the clever manufacturer who seeks out these
holes and makes use of them to gain advantage in some way.
The regulatory certification reflects the
level of development of the National bureaucracy responsible
for setting requirements. Additionally, the lobbying of
legislators and bureaucrats by special interest groups
affects the final rules applied. So it ends up being a
patchwork of requirements that need to be applied by the
manufacturer.
John Woodgate assures us that the world is happy with the UK
approvals; check it out carefully. Oh yes, a question – does
Hong Kong or Singapore still use the British plug design?
What residual of this usage is still left in the world?
All of this is the reason that you and I (and
most of the others on this net) have a meaningful job – once
we get a little experience and are willing to put up with the
uncertainty regarding the roles of requirements along with
the varied level of enforcement by the legal jurisdictions.
You are uncomfortable with this hole in the
requirements. When we feel that the requirements or the
application of requirements is either too strict or too slack
our only recourse is to get (directly or indirectly) involved
in fixing things (in which managers and technical folks
excel) by joining a technical committee or lobbying the
political process that needs fixing.
My advice is: pick your fights carefully and
pursue them with all you have – personal and corporate. You
may even be successful in some of the efforts.
So much philosophizing; good luck in fixing
the world.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201
IEEE Life Fellow
[email protected] <mailto:[email protected]>
*From:* Scott Xe <[email protected]
<mailto:[email protected]>>
*Sent:* Monday, July 16, 2018 9:48 AM
*To:* [email protected]
<mailto:[email protected]>
*Subject:* Re: [PSES] Safety design of shutter opening
Dear Johns,
Thanks for advice abt other countries using 13A plugs &
sockets! Do they require specific approved bodies for
issuing certification like UK?
Regards,
Scott
*From: *John Allen <[email protected]
<mailto:[email protected]>>
*Reply-To: *John Allen <[email protected]
<mailto:[email protected]>>
*Date: *Monday, 16 July 2018 at 3:45 PM
*To: *<[email protected]
<mailto:[email protected]>>
*Subject: *Re: [PSES] Safety design of shutter opening
Also used in Malta and Cyprus (even in “Turkish” Northern
Cyprus IIRC!) – and then there is Gibraltar.
John E Allen
W. London, UK
*From:*John Mcauley [mailto:[email protected]]
*Sent:* 16 July 2018 01:03
*To:* [email protected]
<mailto:[email protected]>
*Subject:* Re: [PSES] Safety design of shutter opening
Hi Scott
Ireland uses the same plug as the UK as per I.S. 401:1997 -
Safety Requirements For Rewireable And Non-rewireable 13A
Fused Plugs.
IS 401 is the equivalent of BS 1363.
Interesting issue about plugs being able to be inserted
upside down in some extension sockets.
John McAuley
*From:*Scott Xe <[email protected] <mailto:[email protected]>>
*Sent:* 15 July 2018 23:32
*To:* [email protected]
<mailto:[email protected]>
*Subject:* Re: [PSES] Safety design of shutter opening
Thank you for the clarification.
On Mon, 16 Jul 2018, 12:47 am John Woodgate, <[email protected]
<mailto:[email protected]>> wrote:
GPS applies to anything; that's why is called
'General...'. Anything can fall within more than one
Directive, in fact all electrical products fall within
both LVD and EMCD, as well as GPSD.
BS 136X connectors are used outside the UK; the EU is not
relevant to that.
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
<http://www.woodjohn.uk>
Rayleigh, Essex UK
On 2018-07-15 17:33, Scott Xe wrote:
The product is for UK market only since 13A
rectangular pins. I believe only UK uses this type
of plug within EU. As far as I remember, a couple of
such product reviews raised this concern in the past
but I did not know the BS standard does not prohibit
it. I am uncomfortable with such design if it meets
the standard.
According to LVD guidance, this type of product falls
into LVD, not GPS. John, how does this product
relate to GPS?
Thanks and regards,
Scott
*From: *John Woodgate <[email protected]>
<mailto:[email protected]>
*Date: *Sunday, 15 July 2018 at 10:53 PM
*To: *Scott Xe <[email protected]>
<mailto:[email protected]>,
<[email protected]>
<mailto:[email protected]>
*Subject: *Re: [PSES] Safety design of shutter opening
I believe that no-one thought of the possibility of a
design that allowed that incorrect insertion. It is
known to the responsible BSI committee, but of course
it takes time for the standard to be amended. Until
it is, conformity to the existing standard cannot be
denied. However, the marketing of such a device might
violate the GPS Directive in Europe, although that is
not certain because unshuttered sockets are legal in
some EU/EFTA countries. Since it only affects those
countries that use the BS136X system, the
appropriate regulatory action may be problematical.
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
<http://www.woodjohn.uk>
Rayleigh, Essex UK
On 2018-07-15 14:52, Scott Xe wrote:
I received a sample of portable extension
sockets with a compliance certificate of BS
1363-2. It is noted the slim enclosure
design allows the mains plugs to be inserted
into the sockets up-side-down by mistake. In
such circumstance, only the earth pin is
inserted and the plug opens the shutter of L
and N terminals posting the risk to access
the L and N terminals with a test pin. It is
a foreseeable misuse but seems no breach of
the safety standard. Can someone share why
it can be tolerated by the standard?
Thanks and regards,
Scott
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