Storage Heaters: LOT20

[SteamyTea]

This one slipped by me, does anyone know what it really means.

 

It also may account for why I got a letter offering me free storage heaters (as long as I was on benefits, which I am not).

 

Here is a link to some 'stuff':

 

https://www.lot20.co.uk/

Edited January 11, 2018 by SteamyTea

[Temp]

Play with the calculator here to see if your electric heater solution meets the new regs...

 

https://www.lot20.co.uk/efficiency-calculator

 

I looked at an electric UFH mat with a programmable 7 day thermostat. It said it...

 

In order to comply with regulations, it needs to increase its efficiency standard by

1%

 

To get it to pass I had to add one of the "additional features" listed below to the stat... 

 

Room temperature control with open window detection

Distance control option (whats this?)

Adaptive start control

 

The other features listed don't result in a pass.

 

I suppose most suppliers will modify their stats to provide Adaptive start control. No doubt that feature will confuse a few elderly people. 

 

 

 

[Jeremy Harris]

And people wonder WHY some of us lost our patience with the way EU regulations have been formulated over the years........................

 

They start out with a laudable aim, to reduce energy use, but by the time the legislation has passed multiple times through the technical committee the original objective gets lost and replaced with a load of restrictive crap that will do little to reduce energy use.

 

It's a bit like the EU regulations on electric bicycles.  They set out, quite sensibly, to restrict the power and performance of these vehicles that did not require a driving licence, insurance, taxation etc.  They then went through a process to develop a test method, and instead of just using the tried and tested UK British Standard that had worked well for years by doing a simple dynamometer test on the motor, they made up their own test.  The result was that you can have a perfectly legal EU electric bicycle that massively exceeds the motor power output in the regulations.  Why?  Because the test is only a timed acceleration test over a set distance, and there is no stipulation on the weight of the test bicycle.  This means you can get a pass with a very heavy person riding the bike, get the required approval, then sell an electric bike that has far more motor power than the regulations allow, and it's all OK.................

 

PS:  Please don't take this as an anti-EU rant - it is solely a rant about the very poor way some regulations are framed, nothing more.

Edited January 11, 2018 by JSHarris

[PeterW]

43 minutes ago, JSHarris said:

PS:  Please don't take this as an anti-EU rant - it is solely a rant about the very poor way some regulations are framed, nothing more.

 

Oh I don’t ...!! As someone who’s been involved in taking regulations into legislation, I’ve seen more than my fair share of these not just from the EU..! 

 

I think its a rather amusing human trait that wherever there is a test or a standard that needs human “involvement” then the human element will try and bend the rules to make things pass ....!!

[PeterW]

1 hour ago, Temp said:

Play with the calculator here to see if your electric heater solution meets the new regs...

 

https://www.lot20.co.uk/efficiency-calculator

 

I looked at an electric UFH mat with a programmable 7 day thermostat. It said it...

 

 

 

 

To get it to pass I had to add one of the "additional features" listed below to the stat... 

 

Room temperature control with open window detection

Distance control option (whats this?)

Adaptive start control

 

The other features listed don't result in a pass.

 

I suppose most suppliers will modify their stats to provide Adaptive start control. No doubt that feature will confuse a few elderly people. 

 

 

 

 

Looking into this they are taking the components as standalone, not part of a system. So in that instance if you have UFH mat as part of a larger "system" then the control element comes into the equation but their efficiency calculator doesn't take this into consideration. 

 

Not that this has affected the 20,000 or so eBay products available currently.... 

 

 

[Jeremy Harris]

I've been involved in both BS and EU regulation, and the approaches were very different.  The BS starting point was a technical compliance process, and didn't usually involve significant input from the manufacturers, other than as consultees, a bit like planning. 

 

The EU process seemed to me to be dominated by commercial interests.  I sat on both the LV Directive and EMC Directive technical committees, and it was blindingly obvious that commercial prerogatives dominated over technical compliance.  As a national technical rep, I had very little input into the process, it was clearly dominated by the most powerful commercial entity present.  The sole exception that I can recall was the BS1363 fused plug and shuttered safety socket.  The BS lobbied hard that the UK should not be forced to degrade it's safety standards just because Germany was pushing for everyone to accept the Schuco plus and socket standard.  Luckily  we won that derogation, thanks to a bit of support from RoI, who use the same standard.

[ProDave]

So reading this, you can no longer make and sell a basic storage heater with an input charge control thermostat and basic heat output control?

[SteamyTea]

1 hour ago, ProDave said:

So reading this, you can no longer make and sell a basic storage heater with an input charge control thermostat and basic heat output control?

That is the way I understood it too.

All pretty basic stuff really and probably no bad thing.

 

 

[Temp]

3 hours ago, JSHarris said:

I sat on both the LV Directive and EMC Directive technical committees,

 

If you had anything to do with EN55022 I can blame you for all the hours I spent in draughty barns and down salt mines pointing aerials at computers and set top boxes :-) 

[le-cerveau]

So basically, a good idea initiated by Politicians (fine), but then implemented by Politicians (not fine) who have no idea how to do it but need to ensure they don't impact their electoral base!

[nod]

14 hours ago, SteamyTea said:

This one slipped by me, does anyone know what it really means.

 

It also may account for why I got a letter offering me free storage heaters (as long as I was on benefits, which I am not).

 

Here is a link to some 'stuff':

 

https://www.lot20.co.uk/

We could all do to be on benefits 

Apparently we would qualify for a free boiler 

Now wouldn’t that be a thing

Yhough I suspect none of us are ☹️

[Jeremy Harris]

8 hours ago, Temp said:

 

If you had anything to do with EN55022 I can blame you for all the hours I spent in draughty barns and down salt mines pointing aerials at computers and set top boxes :-) 

 

 

Possibly...............

 

For a time I was a Notified Body under the EMC Directive, and ran some EMC measurement labs in Portsmouth in the late 1990's.  I sat on the EMC Directive TC as the UK head of Type Approval for Maritime Radar, Radio and Nav Aids.

Edited January 12, 2018 by JSHarris

[Jeremy Harris]

1 hour ago, le-cerveau said:

So basically, a good idea initiated by Politicians (fine), but then implemented by Politicians (not fine) who have no idea how to do it but need to ensure they don't impact their electoral base!

 

 

Not quite.  There were/are two different approaches.

 

1.  The process in the UK used to be that politicians would come up with a policy, most usually having been advised by the Chief Scientific Advisors (CSA) in each relevant department and coordinated through the Government's one CSA.  Frequently there were external political drivers forcing this, like climate change, oil prices, coal prices etc.

 

The policy would then be handed to the relevant body within the responsible department to be turned into legislation.  Within the UK (pre-EU harmonisation) most often the technical aspects would be put together on the basis of a mix of sound scientific data plus the art of the possible, in terms of cost impact, to government, the general public and industry (this was done via a number of impact statements that were collated from the initial proposals). 

 

The draft regulation would then be handed back to government to go through the process of being turned into a Statutory Instrument, that could be enacted.  This process inevitably involved lobbying of MP and Ministers by pressure groups and industry, and there would always be amendments made during the two reading stages, for the technical people to check and comment on before the SI became law.  In general, the process was policy-led, and that policy was usually from the relevant CSA, although inevitably it would be watered down a bit if there was strong opposition.

 

2.  The process in the EU is different.  It starts in a similar way, in that a policy is created on the basis of some political, scientific or technical driver, but most often because there was a strong political driver to change something, more often than not associated with harmonisation and protection of the EU closed internal market.  Instead of the technical committees being dominated by relatively impartial government technical staff, they were dominated by members from industry, so every single EU Directive is very largely driven by the negotiated wishes of industry in terms of how best to come close to meeting the political policy they've been asked to address. 

 

The result is legislation that is often designed to create or maintain jobs within the EU, and make it harder for any non-EU state to trade with the EU without complying with EU standards.  At first things were worse than this, in that the EU required that only EU-based Notified Bodies could perform the required test and accreditation work, but that was relaxed under international pressure, so we now have the situation where the majority of some marked goods are in fact fake, having never been tested or assessed at all.  The CE mark is arguably the most faked compliance mark in the world.

 

The UK has very little control over EU technical standards, as it is just one of 28 states that contribute to them.  In some areas we can put our foot down, for example  the debacle over BS1363, where we were allowed a derogation on the basis that the BS1363 plug and socket is demonstrably safer than the proposed alternative, the Schuko, as it provides fused protection for the appliance cord and has a demonstrably good safety record.  Our argument was that forcing the UK to adopt the Shuko plug and socket system would degrade electrical safety in the UK, as well as incur an unacceptably high cost to consumers to change tens of millions of connectors across the country.

 

The main difference between the old UK way of doing things and the newer EU way of doing them, is that the UK system used to be very much evidence-based.  If the technical and scientific evidence supported a policy, then that evidence was used to formulate regulations designed to ensure compliance with it

 

In the EU it is significantly different.  It starts out with the technical and scientific evidence to support a policy, but industry then shapes the regulation so that it can reduce its costs of compliance, and perhaps not even achieve the required policy outcome.  We are starting to see examples of this now in several areas, including building materials, where the UK approvals process has slipped very much into the way the EU works; self-assessment by the manufacturer with no independent verification of compliance unless there is a challenge by another manufacturer.  This is not something that could have happened in the UK, back when the BSI controlled standards and compliance testing.

 

 

Edited January 12, 2018 by JSHarris

[le-cerveau]

Mine was an oversimplification, but the results being that the outcome is not necessarily the best result but skewed (sometimes significantly) in favour of an interested party, rather than general improvement.

[Jeremy Harris]

Just now, le-cerveau said:

Mine was an oversimplification, but the results being that the outcome is not necessarily the best result but skewed (sometimes significantly) in favour of an interested party, rather than general improvement.

 

I wholeheartedly agree!

[SteamyTea]

Totally moving away from storage heaters (not that I mind as I was just highlighting some change).

 

If, for whatever reason you change something and the cost becomes prohibitive, you don't achieve your aim either.  So regardless of who a product or service 'safety' or 'best practice' body is, and it probably does not matter if it is local, national, trading block or global, they have to keep the cost of implantation down.

 

The BS1363 plug is now rather outdated as be also protect out mains voltage circuits with other devices.  But there is a good reason to keep it in the UK as the cost, and in some cases there will be danger in changing outlets (a cack-handed DIYer), far outweigh any advantage.

Having worked in two industries that have loads of legislation attached to them (catering, and health and leisure), it is really not hard to comply.

I do wish that all legislation, and an easy to understand guide i.e. IEE17th Edition, was freely available.  There would be no excuse for non compliance apart from laziness.

I also think that anything that has to be administered by a local body i.e. the local council, needs to be to the same standard.  It s no good having one LA saying you can do something while another cannot.

[Jeremy Harris]

17 minutes ago, SteamyTea said:

The BS1363 plug is now rather outdated as be also protect out mains voltage circuits with other devices.  But there is a good reason to keep it in the UK as the cost, and in some cases there will be danger in changing outlets (a cack-handed DIYer), far outweigh any advantage.

 

The primary criticism of the BS1363 plug is size.  It's arguably too big and an awkward shape, and that's the primary reason manufacturers don't  like it.  It isn't as easy to integrate into small devices as some other designs, plus it's a "one size fits all" design, we no longer have a range of different connector sizes, in terms of sockets in our houses, so any appliance has to be able to accommodate the bulk of a BS1363 plug, or be provided with a bulky (fused) adapter.  For double insulated low power appliances this is a particular issue.

 

However, against that, having an internal fuse to protect the appliance lead is an exceptionally good feature, as is having a longer earth pin that not only ensure that the PE is the last connection to break when the cable is tugged hard, but also operates the safety shutters in the socket that close off easy access to the line and neutral connectors. 

 

The proposed EU alternative, the Shuko, has few of these features.  There is no fuse to protect the appliance lead, but worst of all, the plug can be inserted either way around in the socket, swapping the line and neutral connections over.  To add to the problem there are also a lot of "nearly Schuko" plugs that will fit into a Shuko socket and offer far less protection, including some that don't connect to the PE at all and some whereby the PE is connected after the line and neutral (and hence disconnected before the line and neutral when partially removed).  There are also no protective shutters on the Shuko, and often outlets are not switched, either, so overall it's a significantly less safe system, IMHO.

[SteamyTea]

That is only comparing one plug which we are familiar with, against another one, which we are not familiar with.

 

what is really needed is for the world to agree on one type that has primary and secondary features built in, and is small.  it is really not hard to do.

But that would take cooperation and the putting aside of national prejudices.

In 2013 in the UK, there were 3 domestic deaths from electrocution.

 

 

[TerryE]

The major flaw with the lot20 approach is confusing a sub-component with a system. My house uses a 3kW heating coil to heat the house. It takes 3kW electricity and turns it into heat. Yet my house as a whole is well within the top 1% of UK housing stock, in terms of its overall efficiency. 

[SteamyTea]

52 minutes ago, TerryE said:

confusing a sub-component with a system

Yes, and I think that I read somewhere that the control system has to be 'non propriety', whatever they mean by that.