Information sheet swimming pools Page 1 of 8 Introduction INFORMATION SHEET LVD ADCO PUMPS AND OTHER ELECTRICAL APPLIANCES FOR MOBILE SWIMMING POOLS For a longer time the configuration and construction of the applicable requirements for pumps and other electrical appliances for mobile swimming pools are discussed and were still not clear to economic operators. Specific standards for pumps and other electrical appliances for mobile swimming pools are not available. This information sheet aims to provide more clarity for all. This document is in detail prepared by some directly involved member states 1. The content of the draft was in general discussed on the principles during the LVD AdCo meeting in December 2011. The information sheet provide detailed information for all member states, economic operators and all other relevant stakeholders. It is published to make it available to all and be as transparent as possible as LVD AdCo. This information sheet is a non binding document and intended to provide guidance to help Member States and all stakeholders to facilitate the decision-making process. Part of that process must be a risk assessment in order to draw the correct conclusions. Based on Union legislation one must proceed on a case-by-case basis, taking account of all the characteristics of the product and all accessories. If you have any questions you can contact the Market Surveillance Authority in your member state or address the chairman of LVD AdCo. April 2012 Chairman LVD AdCo 1 This information sheet is designed in cooperation between the member state MSA of Belgium, Denmark, Germany and the Netherlands. - 1 -
Information sheet swimming pools Page 2 of 8 INFORMATION SHEET LVD ADCO PUMPS AND OTHER ELECTRICAL APPLIANCES FOR MOBILE SWIMMING POOLS 1. Introduction The objective of this document is to made information available for stakeholders over the common understanding amongst market surveillance authorities of the applicable requirements for pumps and other electrical appliances for mobile swimming pools, that are subjected to the Low Voltage Directive 2006/95/EC and sold on the European market. This initiative is undertaken for the reason that specific standards for the described situation are not available and the selection of relevant requirements is complex. This document is informative and written in a way that it is considered suitable to make it available to all interested stakeholders. This information sheet concerns filter pumps for mobile swimming pools as well as other electrical appliances in connection with such swimming pools, e.g. equipment for water treatment and heaters. By mobile swimming pools, one understands swimming pools which are inflatable or mobile or which can be dismantled and put back together again elsewhere. Similarly, when it is possible to add, move, replace once or several times one of its electrical accessories during life, the swimming pool installation is considered to be mobile. Indeed, the fact that a single part might be moved makes the configuration of the swimming pool installation likely to be changed, which means that the installation can no longer be considered to be a fixed one. It is clear that swimming pools which has to be dismantled for the winter and for situations were it is not ensured that all parts will be placed exactly on the same location as required for a fixed installation, will be considered mobile swimming pools. The information given hereafter was already passed on to the sector in the past, either under the form of a circular sheet, or by talking to manufacturers, importers or dealers on-site in the framework of market surveillance. It is applicable as long as no harmonized document is established at European level, among others in the field of standardization. In order to protect consumers in a responsible way and knowing that establishing such a harmonizing document takes time, it is necessary that meanwhile necessary measures are taken on the national markets of the Member States. Every time when summer approaches, electrical appliances, such as water filtering pumps or all kind of accessories for water treatment, do systematically appear on the market for use in connection with swimming pools in private gardens. These appliances are often sold under the form of a kit combining them with an inflatable or an above ground swimming pool, which can more or less easily be dismantled. In other occasions, they are sold separately but with an advertisement or documents showing their use for general purposes or promoted combined with swimming pools in gardens. - 2 -
Information sheet swimming pools Page 3 of 8 Because these electrical appliances are often equipped with a direct connection to the mains at 230 V, it is necessary to specify the conditions of placing them on the market, in such a way that full safety can be guaranteed to the consumer when those appliances are intended to be used in the context of swimming pools. Indeed, the fact that the concerned swimming pool installation is mobile makes it likely that an electrical appliance directly supplied with 230 V be put in proximity of the swimming pool and might get into contact with water from it (projections, splashes, puddles, flows, etc.). This increases the risk of jeopardizing the user s safety in case of a first defect in the appliance. Especially when taking into account that the conditions for risk of electrical shock are deemed extreme unfavourable because of the wet conditions of the environment, the low electrical resistance of the human body and possible contact with grounding. 2. Position of the administration All economic operators placing an electro technical product on the European market must take account of the requirements of the Low Voltage Directive. More specific one must comply with the national law of the member states that implement that Directive and to which the products are sold. It is of no importance whether these electrical appliances are placed individually on the market or combined with a swimming pool. It has to be emphasized that, depending on the way electrical appliances water filtering pumps or other water treatment appliances are marketed in connection with swimming pools or not, some risks may arise for the safety of the consumer willing to purchase them for use within a private swimming pool installation. Two situations have to be considered: 1) Either the swimming pool installation is fixed and the rules for fixed electrical installations apply; 2) Or the swimming pool installation is mobile and one has to follow the rules for: a. electrical appliances for all parts as far as relevant; b. supplemented by additional requirements necessary to cover aspects not dealt with by the available specific standards; c. and take into account the relevant requirements necessary to come to a configuration that can operate and be connected to the supply in such a way that it cannot result in foreseeable potential risks for the users. Solutions mixing and combining characteristics of fixed installations and requirements for electrical appliances the obligations of 1 and 2 will normally not be fulfilled. It is the responsibility of the producer to provide all the information necessary in order to enable users to use the product in the correct and safe way. It is common knowledge that older private houses are not fitted with sockets -in and outdoorsprotected by a 30 ma RCD. Consumers have to be regarded non experts and it is advised not to just put into the instructions of use of a kit (movable swimming pool and accessories) that the electrical appliance operating under 230 V must be protected by a residual current device (RCD) with a rated tripping current not exceeding 30 ma - 3 -
Information sheet swimming pools Page 4 of 8 (in short 30 ma RCD ). When no socket protected with a 30 ma RCD is available in the user s house in vicinity of the expected location for the swimming pool and its equipment, and/or if the user does not read the instructions for use there is an actual risk. It is in addition important that the defined zones where electrical appliances may be located are respected. In case of a first defect a consequence for users including children can even be a fatal electric shock. Therefore it is important for the producer to decide before placing his product on the market, whether his product in question is foreseen for a fixed or for a mobile swimming pool installation and to inform in advance the potential buyer of this decision. The construction off all parts have to be in compliance and suitable for the intended use. This responsibility may be shared with the other economic stakeholders such as importers, assemblers, dealers and retailers. 3. Rules for fixed installations The safety rules for fixed electrical installations and for equipment relevant to fixed swimming pools are given in the national standards or law regarding wiring rules for household installations based on international standard for Electrical Installation of Buildings HD 60364 series. This means generally e.g. that: - The electrical appliances must be placed at a permanent location. There must be a permanent place specified for each appliance. The appliances must comply with the technical requirements (of voltage, etc.) and the distances as foreseen by the national wiring rules. Where necessary, the class I appliances must be protected by an additional permanently fixed enclosure providing increased resistance to mechanical shocks. The appliances must show an IP protection level as required. The fixed installation must be foreseen with a 30 ma RCD. Any change to these rules makes that the installation does not comply any longer with its technical instructions of a fixed installation and that it is thus a mobile installation and must follow the rules for mobile installations. - In zones 0 and 1 protection should be provided by separated extra-low voltage (SELV) not exceeding 12V a.c. rms that is, only class III appliances are allowed, the safety source being installed outside zones 0, 1 and 2. - If the equipment has to be garaged for the winter, the installation can no longer be considered as a fixed one because if it is not ensured by constructional provisions and it is prone to be changed of place from year to year and ceases therefore to comply with the technical instructions. The installation is then subject to the rules for mobile installations (see hereafter). It is the standard obligation for the producer to clearly inform the user, before any purchase. - 4 -
Information sheet swimming pools Page 5 of 8 Especially when the purchaser might be a normal consumer and non expert. Part of the information must be that the swimming pool he wishes to buy and its equipment, including the electrical parts, are intended for a fixed swimming pool installation and that the rules for fixed installations apply. This is also required when the electrical parts are sold separately or at another time, it must be obvious for the purchaser that the electrical appliance he wishes to buy at a given moment is intended to fit a fixed swimming pool installation and that the rules for fixed installations must then be followed. Because buyers can be non experts a simple reference to the rules is not enough, but all relevant information has to be part of the user manual. And in addition for assistance reference can be made to professional installers of electrical wiring, however it is not allowed to make that reference instead of providing all necessary information. Where relevant, the responsibility of the producer may be shared with the other economic stakeholders such as importers, assemblers, dealers and retailers. 4. Rules for mobile installations When the swimming pool and/or one or several of its parts are not intended to stay at a permanent location pursuant to the instructions for a fixed installation (see above), the installation can no longer be considered as a fixed installation and falls under the regime of mobile swimming pools installations. For the present, there are no uniform rules at European level for mobile swimming pool installations for private use. Although harmonised standards might exist for the electrical appliances forming a part of the installation, see e.g. standard EN 60335-2- 41 for pumps, these standards do not generally take account of the use of the appliance together with a swimming pool in the framework of a mobile installation. They do not cover the risks of electrocution which might result from the possible configurations of the mobile installation and must therefore be supplemented by additional safety requirements. Indeed, electrical appliances must firstly comply with the essential safety requirements of the Low Voltage Directive 2006/95/EC 2, as transposed in national law. When, as this is the case for mobile swimming pool installations for private use, the risks resulting from combining an electrical appliance with the swimming pool are not covered by the harmonized standard for the appliance, the compliance with the general obligation of safety is assessed taking account of the available information. When European and national specific standards are missing as well as recommendations from the European Commission and codes of good practice for the safety of products, it is obvious to meet the general safety obligation: - the present state-of-art of knowledge and technique; - the safety level reasonably expected by the consumers. 2 Codified version of directive 73/23/EEC involving the «CE» marking - 5 -
Information sheet swimming pools Page 6 of 8 Regarding the present state-of-art of knowledge and technique, it is in great part reflected - in addition to harmonized standards which of course still apply by the national regulations for fixed electrical installations. The same requirements as for fixed installations therefore apply as a minimum for mobile installations, except the requirement of permanent location. These requirements must be supplemented by other requirements which result from the assessment of the safety level which can reasonably be expected by the consumers. This means that: the average consumer i.e. the one who is not a safety expert, - nor has he the knowledge of the risks related to using electrical appliances together with a swimming pool, - nor does he analyse the instructions for use and systematically keeps them in mind, - the customer who maybe has lost the instructions after a few years and allows his children to play in and around the swimming pool used without steady supervision, etc. has the right to expect that his installation offers a sufficient level of safety such that, provided that the conditions of use are reasonable, there should not be any accident occurring during the whole life of the installation. In 2007, a group of European experts from the Member States administrations in charge of market surveillance judged that the following rules are at least applicable to mobile installations to reach the minimum safety level which may reasonably be expected by the average user: - only class III swimming pool pumps (maximum 12 V, see clause 6.1 of standard EN 60335-2-41) or showing an equivalent level of safety are allowed; - when the manufacturer chooses another solution than the class III pump to reach an equivalent level of safety, he is due to submit his proposal to the market surveillance authority and to justify it by arguments (based on studies, analyses, laboratory tests, etc.) showing that an equivalent level of safety has actually been reached. The same remains valid - mutatis mutandis for the other electrical appliances which are parts or meant to be part of the mobile swimming pool installation. Choosing for a 230 V voltage, provided that the appliances are ensured placed at a distance of more than 3,5 meters from the swimming pool - as allowed by the wiring rules under special conditions of fixing, protection and mechanical resistance of the appliance is not sufficient to reach the equivalent level of safety for mobile installations. In that case the appliances are in general mobile and do not provide the same level of safety as the permanently fixed appliances in the frame of a fixed installation. Incorporating a 30 ma RCD (e.g. in the plug of the appliance) may be a part of a solution to reach the equivalent level of safety, on the condition that the manufacturer of the electrical appliance justifies the adopted technical solution by means of documents, drawings, measurements, test results, etc., allowing to convince the competent authority that the proposed solution actually results in an improvement of the safety and gives a safety level equivalent to class III. - 6 -
Information sheet swimming pools Page 7 of 8 Incorporation of a 30 ma RCD (e.g. in the plug of the appliance) as a substitute for a 30 ma RCD in the fixed installation is not considered sufficient. Certainly not in a way that the applying of the zones can be ignored. In general and whatever the solution of the manufacturer to assure an equivalent level of safety, the connection with a 30 ma RCD protected socket is always encouraged. This must be written down in the instructions for use. Where can one find more information? Documents on the subject: Standard EN 60335-2-41 on the safety of household and similar electrical appliances Particular requirements for pumps. Standard HD 60364 series, Electrical Installation of Buildings National wiring rules Standards can be purchased at national standardization bodies. The European legislation in the field can be found through following internet links: http://ec.europa.eu/enterprise/sectors/electrical/index_en.htm http://ec.europa.eu/enterprise/sectors/electrical/lvd/ Starting from this last link, it is possible to find the list of the notified bodies: http://ec.europa.eu/enterprise/policies/single-market-goods/regulatory-policiescommon-rules-for-products/new-legislative-framework/ http://ec.europa.eu/enterprise/sectors/electrical/documents/additionallegislation/index_en.htm http://ec.europa.eu/enterprise/sectors/electrical/documents/lvd/notifiedbodies/index_en.htm - 7 -
Information sheet swimming pools Page 8 of 8 Plug and socket outlet 230 V Hose Pump Considered the side of the Zone 0 2mtr 1,5 mtr Zone 1 Zone 2 SELV Remarks: Supply 230 V has to be at least long enough to bridge zone 2 and the height (normaly at least 1,2 mtr.) The length of the hose is neglected In zone 2 for this use normally IPX5 (or 4) It is strongly recommended to incorporate in addition a 30 ma RCD It is logically to provide very clear warnings on the SELV unit - 8 -