Richard Hayes writes: Whenever I deliver the ICEL course on Emergency Lighting Legislation and standards for the LIA, I keep getting told that consultants and specifiers are using BS 5266 part 1 as a specification. I have written the article attached to point out why this is annoying and wrong.
So: when is a standard not a Standard?
This sounds like a riddle but it’s a serious point. We are all familiar with standards, we use them in our daily practice within the lighting industry; they are used by end-users and consultants when issuing tenders and documents; they can form a part of contractual terms. But some of the standards we use are not entirely what they seem.
Because some standards are Standards and some standards are Codes of Practice. Confused?
Most of the documents that we regard as standards are specifications standards. They are highly prescriptive documents setting out detailed absolute requirements. BSI describes them as ‘commonly used for product safety purposes or for other applications where a high degree of certainty and assurance is required by its user community.’
Codes of Practice on the other hand “recommend sound good practice as currently undertaken by competent and conscientious practitioners. They are drafted to incorporate a degree of flexibility in application, whilst offering reliable indicative benchmarks.”
All well and good but what difference does this make? If you read the foreword for a BS Code of Practice you will find the following wording.
“As a code of practice, this part of BS???? takes the form of guidance and recommendations. It should not be quoted as if it were a specification and particular care should be taken to ensure claims of compliance are not misleading.”
This is very relevant to some areas in the lighting industry; consider, for example, Emergency Lighting. The specification standards that are relevant to Emergency Lighting design are BS EN 1838 and BS EN 50172. These documents contain specifications that can be used as the minimum requirements for an emergency lighting installation. Those requirements can be verified at the design stage and then measured and inspected to comply with the specification when the installation is completed.
BS 5266 Part 1 is a Code of Practice. It does not contain specifications that can be verified and inspected, but we often see it quoted as if it was a Standard. BS 5266 Part 1 should not be used as a standard, according to its own foreword.
Whilst we are on the subject can we also be clear about the legal status of Standards. As professionals we have duties imposed on us by various parts of UK legislation. In law we must comply with Health and Safety at Work Act, Electricity at Work Regulations, Regulatory Reform (Fire Safety) Order 2005 to name but a few. Using Standards does not in any way guarantee that you are complying with the duties placed on you under any of the parts of the legislation, nor that you are immune from prosecution. For instance, the Health and Safety Executive says
“Installations which conform to the standards laid down in BS 7671 (the Wiring Regulations) are regarded by HSE as likely to achieve conformity with the relevant parts of the Electricity at Work Regulations 1989”.
To reiterate, complying to the Standard is no guarantee that you have complied with the law. This is true of all Standards. They are just an industry’s way of giving you a good place to start.
Can we also place the requirements of standards into some context. There seems to be a general consensus that complying to a Standard infers some sort gold medal. No, you can and should look at the requirements of Standards in a different way. Let me propose to you that this wonderful product I am trying to sell you just conforms to the minimum requirements for mechanical, electrical and thermal safety to enable it to be legally placed into the market. But Standards represent a minimum set of requirements; they are not the ultimate measure of the safety of any particular product or process.
A good product will be designed and manufactured to be as safe as it can possibly be, it will not be designed to just scrape through minimum requirements for product safety.
A luminaire tested to comply with the requirements of BS EN 60598 won’t fall on your head, electrocute you or burst into flames…………..but that’s about as far as it goes. To quote Dame Judith Hackitt’s interim report on the Independent Review of Building Regulations and Fire Safety, commissioned following the Grenfell Tower disaster, she identified the need to “………..change the culture away from one of doing the minimum required for compliance, to one of taking ownership and responsibility for delivering a safe system throughout the life cycle of a building.”