combi in a cupboard

[Coherers]

The liability aspect is also one of the reasons why no manufacturer will use weaker standards than those specified by the BSI. Installation in an unventilated compartment must have been approved by a relevant standard.

Yes, I have read them. Both parts, about a year ago. Can't say I recall all the detail though. Despite having a copy "in the office", have you read them? But what has that to do with the fact that manufacturers always detail the British Standards that must be complied with when installing? (Besides, the relevant issues governing compartment installation here are covered by 6798 as much as 5440 Pt 2. )

The alternative for these appliances when the additional clearance is not available (i.e. top/bottom vents) is to allow for ventilation. But I would agree that this is not ventilation in the same way that 5440.2 deals, in the main, with ventilation to ensure adequate air supply for combustion.

Manuals sometimes contain misprints, typos and worse (Saunier Duval during the early 1990's were a particularly bad example of this). Therefore, in the event of an apparent discrepancy between the manufacturer's instructions and the standards they are supposed to be compliant with, the responsible thing to do is to attempt to reconcile the two. E.g. by getting the manufacturer to explain how their advice complies with the relevant standards. In the event of an apparent contradiction, to assume that the manual is correct and the standards have been "superceded" is not sensible.

Having said that, I have not yet seen **any** installation manual that on investigation cannot be reconciled with the appropriate BS - as appears to be the case here (I would want to check BS 6798:2000, as opposed to

6798:1987)

I will continue to operate based on the Standards **and** Manufacturer literature as:

1) I have never (yet) found a reason to be forced to choose between them. 2) It is clear to me that this is what the manufacturers expect you to use the standards from the frequent references to BS this and BS that in their documents and, in some cases (W-B, SD), a lists of standards that need to be followed.

[stuart noble]

Thanks for the info everyone. So it seems we're bound by 2 BS standards, neither of which the public has reasonable access to, and at least one of which is apparently being misinterpreted by a major manufacturer. As far as I'm concerned they can shove their regulations.

[Coherers]

"stuart noble" reasonable access to, and at least one of which is apparently being

I think that the manufacturers are probably correct on the standards, although I want to check them sometime because I have never read the sections on RS appliances in unventilated compartments.

What I think is likely is that boilers made after 2000 can be designed to go in unventilated compartments with increased clearances due to the new versions of the standards from that year. However, there is no obligation on the manufacturer to get their products certified to run in such an environment, so not all modern boilers can necessarily be fitted like that.

Totally agree with you on the lack of reasonable access to the standards. It is worse than just having to pay £70 quid for a twenty page document. Several libraries that I know used to subscribe to the standards but have stopped because of the exorbitant costs. My local library was one of those, and it also had to send back all the copies it had paid thousands to get over the years, because technically they were only rented.

[Andy Hall]

On Thu, 9 Dec 2004 10:03:23 -0000, "stuart noble" reasonable access to, and at least one of which is apparently being

You can order any of the British Standards from BSI, Stuart, and they'll sell to anybody.

They're not free because a) Some have ISO material and AIUI, there is a royalty, and b) it costs a fair bit to research, test, discuss, agree and publish them. Somebody has to pay, which boils down to governments or users.

[Andy Hall]

But you're not paying £70 for a 20 page document. The production cost is pence. You are paying for use of the intellectual property. In the case of a standard this implies the research, investigation, discussion, testing, paying over 5000 staff etc. etc. It's not cheap to do and there are only really two ways - subsidise from some governmental source or the interested users pay.

But it didn't "get" them. It bought a right to use or license for a specific purpose and has now chosen not to continue to pay for that license.

Given that almost all standards are highly specialised in their fields, the reading audience for most is relatively small, so it would not seem to me to be a good use of public funds to buy licenses for a small number of likely interested people to see them for free.

Access is reasonable. If you want to read the standard you buy it, just the same as if you want to listen to a piece of music from a CD when you like, then you buy the right to do that.

[stuart noble]

How very British to impose legislation and then charge those affected by it for the privilege of seeing it :-) Safety standards are to be applauded but when the whole thing is a muddle and self interest groups see it as a way to line their pockets, the end result has to be less safety.

[Andy Hall]

Of course. Mind you, this is not a new phenomenon. Before it was handled by not encouraging the masses to read and write or to obfuscate using Latin. Nowadays we use comprehensive education and jargon to achieve the same thing.

[Coherers]

You are paying £70 for the document. There may be a small profit element in it, but the production cost is the cost of production, which includes all the costs involved up to the point where it is delivered to the consumer.

Exactly the same sort of arguments can be made about government produced legislation or much other state or quasi-state documentation. However, on balance it is considered to be in the public interest for these documents to be available online and generally free for non-commercial use.

I do believe that commercial organisations that benefit significantly from the BSI's output should pay. But where a private individual can end up breaking the law as a result of not being able to access what he/she is expected to do then, or where matters of public safety are at stake, there is a strong argument for low cost or free access.

Having spoken to him about this, I am not sure the head librarian for my borough libraries would agree with you. They held printed standards going back over 40 years some of which they believe were acquired under a very different regime to that operating today. But as a local authority, they would not have had the budget to challenge the BSI, nor the incentive, as an non-current set of standards is of limited use anyway.

See above

The IPR issues around music/books/software are a lot clearer than those around those produced by an organisation which was for a long-time sponsored by the government, whose current output has been at least in part paid for by the taxpayer, and which has a clear public interest role.

On access, my understanding is that local libraries have had to stop taking the standards as the BSI's status changed, and the costs increased significantly. If the public library system is not able to afford the standards, I would say access is NOT reasonable. After all, they can afford many extremely expensive subscriptions of other commercially produced material.

The BSI is a defacto monopoly with the status of a company. However, it also functions as a quasi-governmental organisation. As something of an evangelist for the free-market, I also recognise the limits and that there are real problems that have to be addressed when public interest functions are put into the market. And, in my opinion, recent charter changes to the BSI did not address the public interest side.

Without wanting to get into the argument about standards approaches generally (e.g. W3C vs.ISO ), this issue is not a simple one.

[Coherers]

"stuart noble"

[Andy Hall]

You are paying for the right to use the information. That is not the same thing.

Standards are not of themselves legislation and are only referenced by it.

For things like Statutory Instruments, it is arguably part of democracy.

The trouble with that idea is how do you control it and where do you draw the line? An argument could be made for almost any standard that ultimately safety or something related to it or in the public interest is involved. If you have low cost or free access for the private individual, how would you prevent individuals in commercial organisations simply pulling information on a personal basis because it was easier to do that than get a purchase order organised?

So they should perhaps have written off the cost from before.

That's certainly true......

[Coherers]

If you have a subscription yes, if I buy it on the BSI web-site then unless I agree to the contrary I imagine I "own" it as with any other reference book (copyright remains with the publishers etc. etc.)

Technically true. But BS 7671 for instance is effectively part of the more general regulatory enviroment and could be used against you in court if you don't follow them. I think of them as "tertiary legislation" -another step removed.

Yes! Only I'd say the same is true to a lesser extent for 7671, 6798,

5546, 5540 and related friends.

Agreed, there is a balancing to be done here and common sense is needed in deciding what is really about safety and what is really peripheral (Prescott, please note).

Personally, I think an simple solution and sensible compomise would be to impose a condition on the BSI to provide public libraries with subscription at a reasonable price point like they used to. Satisfies access, and largely protects the IP. Sure, you couldn't prevent commercial abuse, but on the whole I think companies would mostly buy the standards for the same reasons that they generally license their software rather than pirate it. If you are involved in commercial activity, then £150 for a document is often chicken-feed. Sure some would abuse the system, but they can find other ways to avoid paying anyway - e.g via the few libraries that still take it / photocopying etc. Besides, the time the firm spends avoiding doing a PO will often cost them more than £150 in wages.

The way I see it, one can borrow a music CD from my library and rip it (I wouldn't). However, do we say that libraries shouldn't lend CDs ( and books) because of this ?

I hate the idea of government intervention, but then I don't like the idea of price regulation of gas/water etc. Life's a compromise. Sigh!

[Tony Bryer]

But that's a very recent development and a rare but welcome example of HMG calling it right: in my BCO days most of us had a week's wages worth of Acts and SI's in our desk drawers - there was an office copy of course but to do the job properly you needed your own.

BS's are horrendously expensive for people who are not really going to get their money's worth out of them - for example BS5268, Structural Timber Design is £178 to non-members, half that to members like us (smallest business membership is £90+VAT p.a.) but for those who use our software virtually all the relevant content can be found in a £20 textbook. That of course won't be true of the more obscure standards.

[Owain]

"Coherers" wrote | > You are paying for the right to use the information. That is not the | > same thing. ... | > Standards are not of themselves legislation and are only referenced by | > it. | Technically true. But BS 7671 for instance is effectively part of the more | general regulatory enviroment and could be used against you in court if you | don't follow them. I think of them as "tertiary legislation" -another step | removed.

In Scotland, BS7671 is more a part of the Building Regulations than the Technical Notes ( = Approved Documents in England). There is no way around, no equivalent, for BS7671 whereas you don't have to follow the Technical Notes but only demonstrate achieving an equivalent conformance with the regs.

| Personally, I think an simple solution and sensible compomise would be to | impose a condition on the BSI to provide public libraries with subscription | at a reasonable price point like they used to. Satisfies access, and largely | protects the IP.

I can see no technical obstacle why the BSI should not release CD-ROMs to public libraries [1], on say a quarterly update cycle for modest subscription, for free on-screen viewing[2], but the software use up credits for every page *printed*. Anyone wanting to *use* the standard would either pay the printing cost for the pages they needed, or just buy the whole standard, but the interested member of the public could use the CD-ROM as an

*in-library* reference free of charge. (It would be up to the library whether it allowed free printing - company or organisation research libraries[3] might well have a quota per user.)

Owain

[1] Apart from they'd probably make them so they only ran on Microsoft. [2] Compatible with accessibility technology, of course. [3] Who could be charged a commercial rate for the CD-ROM subscription.

[stuart noble]

[Coherers]

"stuart noble" Duval have not replied to my e-mail asking them to look up BS6798 and define

I had a trouble getting anything useful out of SD technical support on one of their boilers a few years back. In the end I gave up on them, and worked it out myself. If they had been helpful, I might have bought £100 PCB from them, but it so irritated me that I ended up fixing the board myself - with a 90p NiCd cell, which really chuffed me! (That was before I heard of Geoff.)

Funnily enough, that boiler was a close predecessor of yours. To be honest, with your model, if you want to comply with the letter of the rules, I think you are going to have to bite the bullet and put the vents in the compartment - unless it is a room-sized cupboard or something.

But, I take your point about what does "confined space" really mean. And as John indicated, since you can put their current equivalent model in an unventilated cupboard, one wonders if there is a good reason why this one can't be so configured. Okay, it was designed when an older version of the standards applied and wouldn't have been tested in that configuration, but does that mean it really wouldn't be okay with greatly increased clearances?

But having had a similar sort of conversation with Baxi-Potterton before, I can tell you what the manufacturer's answer will be: No. Because not having been tested, they cannot 100% guarantee that it will be safe. And although I was a bit annoyed at the time, I have come to realise they were right. "Very probably safe" just doesn't cut it.

[John]

Well no that wasn't what I "intended" to say What I meant was, what is taught at most of the pre-assessment courses i.e. its fine to install a room sealed boiler in an unventilated cupboard "as long as the manufacturers say so" in their installation and service instructions. If they dont say (in print) that no additional ventilation is required then compartment ventilation is required. However if they say no additional ventilation is required then it isn't

[Coherers]

You certainly pointed out to me that most manufacturers now produce boilers that can operate in unventilated compartments, something I was unaware of, being used to the fairly odd (to me) older rules. (I know, keep up!)

But that I what I like about this group, you can learn something new all the time. Even in areas you are reasonable familiar with :-)

[stuart noble]

Due to some strange design work by the previous owner of the house, this particular "cupboard" could probably accommodate an erect CORGI and his tools with the door shut, so we're not talking kitchen units or airing cupboards. Larders maybe? Anyway, bugger it. The existing 4" opening to the outside will be converted to a cat flap, with an additional similar opening on the inside. In the event of a survey, they can just take the door off, which won't look any stranger than the current setup. Thanks again. I appreciate the trouble you and others have taken over this.