When Are Regulatory Certificates of Compliance (RCC) Required?
Introduction
The implementation of the standard SANS 10142: “The Wiring of Premises Part 1: Low-Voltage Installations” has generated widespread controversy and uncertainty regarding the need for Regulatory Certificates of Compliance (RCC). This blog aims to provide clarity on this subject and explain the historical context and current requirements for RCCs.
Background
The SANS 10142 series was developed by SABS technical committees, including specialists from the Department of Employment and Labour (DoEL), manufacturers, SABS Electrical Test Facility experts, and various industry experts. The objective was to ensure the safety of electrical installations and comply with legislation like the OHS Act and the Electrical Installation Regulations.RCC Introduction and Objectives
Initially, there were no national or international standards for certain products beneficial for fixed installations. To address this, an Authorisation Committee was formed to evaluate these products, conduct tests, and issue RCCs through the SABS Regulatory Department.
Procedure for RCC Issuance
- Evaluate the Product: Assess the product’s suitability.
- Compile a Test Program: Conduct tests by an independent laboratory such as SABS NETFA.
- Issue RCC: If the product complies, issue a Regulatory Compliance Certificate.
Historical Context and Evolution of RCCs
The RCC program initially did not apply to products that complied with applicable national standards or compulsory specifications. A significant amendment in January 2003 included RCCs and specially tested assemblies as proof of compliance. When the NRCS was established in 2008, the Authorisation Committee was dissolved, but NRCS continued issuing RCCs without reference to RCCs in the NRCS Act subsequent regulation, creating an opportunistic administrative scheme. RCCs were then expanded by NRCS to products with available Type Test reports against national standards or Type 5 product certification.
Changes and Current Practice
- NRCS Establishment in 2008: The Authorisation Committee was dissolved, but NRCS continued issuing RCCs without subsequent regulation.
- Current Requirements: For products listed in SANS 10142-1 Section 4.1, compliance is regulated through the Electrical Installation Regulations. and may be shown by one of the following:
- Identifiable proof of compliance (e.g., Type Test report)
- Certification from a recognised body (e.g., SABS Mark)
- Letter of Authority (LOA) for regulated products under compulsory specifications (VC).
Standards and Specifications
- Mandatory Specifications: Standards are considered mandatory when referenced in other regulations or standards. These are not regulated by NRCS.
- Compulsory Specifications: Standards become compulsory when published and regulated by entities such as NRCS under acts like VC8036. These require strict adherence and compliance.
Proofs of Compliance
Components used within electrical installations must have mandatory proof of compliance in one of the following formats:
- Identifiable proof of compliance (i.e. Type Test report) from the manufacturer or supplier, or
- Certification confirmation (e.g., SABS Mark) from the manufacturer or supplier, or
- LOA issued by NRCS under the NRCS Act 5: 2014 for regulated products within the scope of compulsory specifications.
We advise all suppliers of electrical products to ensure that products within the scope of compulsory specifications receive an LOA. Products outside this scope do not require RCCs; proof of compliance can be shown through a test report or product certification.
For advice, please reach out to us:
- Connie: Connie.Jonker@safehousesa.co.za