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Compliance – the difference between Regulation and Guidance, a personal view of G3

Author : Russell Armstrong, managing director of RA Tech UK.

23 December 2020

Having invented a regulatory driven product, I have studied the issue of compliance for a number of years now. Through research and detailed studies, I have come to understand that there is much confusion in the industry and how the regulators “police” the regulations against approved documents.

First off it is important to emphasise that it is vital to diligently follow regulations for the safety of all.

However, to comply with the regulations you don’t actually have to necessarily follow the guidance found in the Approved documents!

Take G3 for example and specifically the situation of PRV discharge, distilled down to G3.(2) and (3) (b).

Did you know that this was the actual regulation that you had to comply with with regards to relief valve discharges (PRV and T/PRV) from unvented water heaters?

To paraphrase, constructed and installed to cope with temperature and pressures (but maybe should say the volume at high temperatures expected?) and discharges visibly and safely.

The Approved Document below the Regulation page is merely guidance, and just that, guidance!

I am not saying you don’t have to follow Regulations, you do. But the religious observance by Regulators to reject an installation because it doesn’t follow the guidance is flawed policy. 

Before anyone shoots me, let me point you to the wording in the introduction of the Approved Document:

Introduction (on page 3 of the document)

What is an Approved Document

“…….The intention of issuing Approved documents is to provide guidance about compliance with specific aspects of the Building Regulations in some of the more common building situations.

“They include examples is what, in ordinary circumstances, may be reasonable provision for compliance with the relevant requirement(s) of the Building Regulations to which they refer.

“If guidance in an Approved Document is followed there will be a presumption of compliance with the requirement(s) covered by the guidance. However this presumption is not conclusive, so simply following guidance does not guarantee compliance in an individual case. It is also important to note that there may well be other ways of achieving compliance with the requirements. There is therefore no obligation to adopt any particular solution contained in this Approved Document if you would prefer to meet the relevant requirement in some other way…….”

There is therefore no obligation to follow guidance!

It is my contention that guidance documentation should include performance parameters. IE stated reasons as to the rational of the guidance EG the “rule” regarding the 300mm drop of straight pipe between the outlet of the tundish and the first bend.

Why is it there, and why 300? Why not 400? What happens if the D2 is 28 or 32 dia as opposed to 22mm?

Wouldn’t it be more useful if the Approved document gave the following performance criterion?

Currently the guidance states G3 3.56 a. “have a vertical section of pipe at least 300mm long below the tundish before any elbows or bends in the pipework (see diagram 1)…..

I would personally want to see the reason why this is important and if I don’t have to follow the exact guidance I need to know what it is trying to achieve so I can safely depart from it, so for me, it would be useful to have ……diagram 1) “the D2 pipework shall be designed and installed to ensure that the water flows completely to drain without any backing up of water into and out of or over the tundish, bearing in mind the maximum volume flow being discharged from the relief valve in each particular installation……..”

And that is the most important aspect of compliance to focus on, to make sure that your installation performs to the level of the requirements of the regulations and without the “why”, compliance, informed compliance is very difficult to achieve.

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