Misinterpretation:
The reason for "Out-of-Scope" stoppages
Out-of-Scope stoppages and demurrage are the main irritations to product importers. They lead to extensive wasted expenditure; all incurred as a result of the NRCS’s questionable regulatory model.
The (mis)-interpretation by NRCS inspectors, of the scope of the most comprehensive compulsory specification VC8055 is the main cause of frustration in suppliers.
While VC8055 is based on IEC 60335 for domestic appliances, the wording is often not applicable to other products. The ambiguity and misinterpretation of the scope of VC8055:2009 was essentially the reason for an industry request to NRCS to extract product types other than domestic appliances from VC8055 into different compulsory specifications.
It should be noted that VC8055:2009 has been extended from domestic appliances to a wide range of other electrical/electronic apparatus, unfortunately without conducting Impact Assessments to evaluate the effect that the specification and regulatory requirements has on consumers (the ordinary person) and product suppliers.
Product categories that are affected are:
• Luminaires,
• Measuring instruments, and
• Transformers.
The extraction of Electric motor-operated tools from VC8055 with the publication of VC9105:2016
In 2012, the project to develop a new specification (VC9012: Electrical Luminaires) was approved. It has been active for the past 12 years.
A NRCS developed Risk Assessment (RA) was first conducted in July 2013 on the main categories of luminaires. This Risk Assessment methodology has been questioned by stakeholders as this is not based on probabilities or statistics but purely on personal assumptions. However, the potential risk of electric shock, fire hazard and burns were evaluated, which resulted in the following Risk ratings:
Comment on the risk assessment:
- Risks were based on personal assumptions only, without any evaluation of actual data of burns, fire or electric shock.
- Risks were based on then current luminaire technology which included, tungsten halogen, fluorescent and CFL and HID technology. LED technology, which operates at temperatures < 130°C with a significantly reduced risk of burning and fire, has largely replaced older light source technology.
- Since the banning of old lamp technology which becomes effective in May 2024 with the introduction of VC9109 and VC9110, a new Risk Assessment is needed to determine the present/future situation.
The NRCS’s conclusion and recommendations on the Risk Assessment (Report date 9 September 2013) (which does not take new LED technology into account) were;
“6. Conclusion
There were three major risks associated with all six (6) categories of luminaires, these were electric shock, fire hazard and burns. Fire hazard had the most severe consequences, when compared to the other two risks for all product categories. The need for the proposed compulsory specification has therefore been established.
8. Recommendation
The consensus of the workshop participants, based on the discussion and rating exercise, was that there is significant risk to warrant mandatory compliance and the proposal should be supported. The level of regulation and administrative requirements for different categories of luminaires will be outlined in the compulsory specification.”
Luminaire Groups
There are two distinct sectors in the lighting industry namely: manufacturers and suppliers of decorative/domestic and commercial/industrial luminaires.
Decorative/domestic luminaires
Used predominantly in domestic dwellings can be classified as consumer items, purchased and used by the ordinary person (typically decorative lamps or bedside lamps). The decorative designs are the most important features. Such products are seldom tested for light distribution and photometric characteristics and are seldom used in public buildings, shops, hospitals, factories, etc.
Commercial/industrial luminaires
The commercial/industrial product groups (including streetlights, floodlights etc are generally used in lighting projects where the lighting installations are covered by regulations such as the OHS Act, Building Regulations SANS 10400, Lighting codes and standards e.g. SANS 10114-1, SANS 10114-2 and SANS 10098 are applicable.
For lighting projects, luminaire photometric performance data is a key element. Installations and maintenance of commercial/industrial luminaires are mandated to be done by skilled persons and such installations are maintained under supervision of an appointed resident engineer. Such luminaires are not general consumer products and are often custom-made for specific lighting projects and therefore fall outside the scope of VC8055 and should be excluded from VC9012.
Impact Assessment
No formal Impact Assessment (IA) has been conducted on the proposed VC9012 drafts that have been under discussion by the NRCS Stakeholder Meetings. Despite requests from stakeholders, the NRCS has not made provision for IA as required by Regulation R924 and NRCS procedures.
It is evident that this extraction would negatively impact the LOA approval and levy income of NRCS as some luminaire types based on their safety risk assessment outcomes, would in future fall outside the scope of the new VC9012.
This specification development project resulted in NRCS’s questionable delays against principles of openness and transparency. The NRCS website states the following for its specification development process:
The development of a new scope for VC9012 has been the cause of endless debate and disagreements during stakeholder meetings. Stakeholders are adamant to only include luminaire types that are presently covered in VC8055and which pose a justifiable safety risk.
It is crucial that luminaire types that are to be included in VC9012 and also those excluded are clearly identified so as to prevent future misinterpretation and out of-scope stoppages.
A thorough analysis of the VC8055 scope must be applied to retain the intent of the specification to protect the general public (ordinary person) and environment against unsafe products, also taking cognisance of the NRCS’s inefficiency and incapacity in approval of LOAs and the dwindling product testing capacity in South Africa.
VC8055 - section 1. SCOPE
1.1 This specification covers safety and energy saving requirements for the specified types of mains-powered electrical and electronic apparatus listed below, rated at voltages not exceeding 500 V a.c. or d.c. and intended for use by ordinary persons in household, light industrial and general office applications. Such apparatus is generally available through normal retail distribution channels.
“Mains-powered”
Luminaires such as battery-operated lanterns, torches, head lamps for campers, illuminated key rings etc, are not covered by the referenced specification SANS/IEC 60598 series. This is also the case with solar-powered luminaires. These should therefore be excluded from the VC9012 scope.
“Use”
In the case of luminaires, the term “use” would typically apply to luminaires connected to the supply by means of a plug and includes portable luminaires, such as hand lamps, portable luminaires for children, portable garden luminaires, decorative lighting chains, luminaires for standby lighting etc. It could possibly apply to luminaires that are mounted within reach of the ordinary person or user such as fixed luminaires for decorative domestic applications, including pendant luminaires and luminaires specifically designed for wall mounting at low mounting heights, aquarium luminaires, luminaires designed for regular adjustment.
Commercial and industrial luminaires for recessed ceiling mounting or high mounted luminaires are not “used” and therefore are outside the scope of VC 8055 “generally available through normal retail distribution channels.”
Conclusion and Recommendation
The VC9012 project which was virtually “shelved” by the NRCS has been taken up by Safehouse and IESSA to ensure completion of the project.
Luminaire suppliers and manufacturers are again advised to familiarise themselves with specification requirements and apply self-regulation principles within the constraints of the regulatory process.
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