MCFT Technical Bulletin - RCD’s in Commercial Kitchen Circuits - April 2021

Following a recent fatality in a commercial kitchen, the HSE have issued strong guidance that:

1. there are instances where manufacturers’ instructions to protect devices with RCD’s have not been complied with
2. a risk evaluation would extend that to the majority of metal cased (Class 1) appliances with electrical connections – practically all appliances in commercial kitchens.

There has apparently been no reported fatality from electrocution from a circuit protected by an RCD or RCBO breaker.

Note the emphasis in the following IET guidance on the risk evaluation of circuits with socket outlets:

In order for the omission of RCD protection to any socket-outlet on the basis of risk assessment to be permitted by Regulation 411.3.3, the risk assessment must determine that the RCD protection is not necessary. The risk assessment must be documented and a copy of it must be attached to the Electrical Installation Certificate or (where applicable) Minor Electrical Installation Works Certificate covering the installation of the socket-outlet.

The person who prepared the risk must be prepared to justify his or her conclusion that RCD protection was not necessary, possibly in a court of law, especially if someone was killed or injured as a result of the RCD protection being omitted.

 (Source IET Guidelines, comment on BS 7671 [17^th Edition]:2008+A3:2015.)

The point being that risk assessment would be to support situations where an RCD is NOT required, rather that justifying when they are required. And interpretation of this guidance is that this Risk Assessment over-rides any previously assumed latitude not to have to upgrade legacy systems.

Given the increased risk from heavier duty appliances – and their ongoing vulnerability from daily wear-and-tear and susceptibility to misuse – it is difficult to envisage successful arguments against RCD protection of circuits providing power to commercial kitchen appliances.

Please note : this initial alert is offered in our capacity as your contractors on kitchen equipment – not as electricians or electrical engineers. Neither are we able to offer our services to install these breakers – which would be carried out by your usual electrical contractors. (Initial experience is that this can be less than straight-forward – certain appliances eg large dishwashers require Type C Breakers and 300Ma rating rather than the recommended Type B 30Ma.)

We would be pleased to talk this through with you or your electrical contractors should you require further elaboration.

For ourselves, going forward, we will be taking the following actions

1. New Installations : we will, at the time of quoting for new equipment, bring this requirement to your attention such that you or your electrical contractors might verify that appropriate protection is in place; we will not be able to effect final electrical connection without it.
2. First (Major) Annual Service ; we will be ascertaining the level of protection for all vulnerable appliances and commenting on our service reports – to allow you to evaluate and take action.

We are also taking this action as part of our duty of care to our employees who will be working on appliances in your kitchens and would be grateful if you could acknowledge receipt of this notice along with an indication of proposed action.