by Mark Botha, Vector editor, and Chris Yelland, investigative editor, at
EE Publishers Converting conventional fluorescent luminaires with magnetic ballasts and T8 tubes to luminaires with electronic ballasts and T5 tubes by means of so-called "conversion kits" is claimed to provide technical advantages, energy efficiency improvements, and much needed energy savings... (more)In most cases, however, the reality is quite different, with the following problems:
Conversions generally involve opening the luminaire, removing the capacitor and starter, rewiring the luminaire, and fitting the new T5 tube and electronic ballast assembly. This on-site modification of existing type-tested and certified products covered by a mandatory compulsory safety specification surely renders the modified luminaires uncertified and therefore illegal.
In many cases, the insertion of the T5 tube assembly into a luminaire with the fitting energised results in live end-pins that present a lethal electric shock hazard to the installer. Furthermore, in some cases, the new T5 tube assemblies have unearthed metal parts without a double insulated design that is both unsafe and illegal.
In many cases the photometrics of the modified luminaires are quite different to that of the original luminaires through the introduction of a different tube diameter, length and rating, and the incorporation of a reflector above the tube to focus the light downwards. This can render the lighting level and lighting ratios of the modified installation non-compliant with the lighting requirements of the Occupation Health and Safety Act.
It has transpired that the National Regulator for Compulsory Specifications (NRCS) has issued Letters of Authority for T8/T5 conversion kits to certain importers, when such kits are in fact not covered by any compulsory South African specification regulated by the NRCS, which renders such certification highly irregular and perhaps illegal.
It is known that Eskom has been approving and subsidising a number of T8 to T5 fluorescent lighting conversion projects involving many thousands of fittings as part of its demand side management (DSM) programme. But since being informed of the above by lighting industry experts and EE Publishers, the utility has posted the following "urgent message" on its website:
Eskom has been made aware of the safety issues pertaining to T5 adaptor retrofits of T8 lamps and therefore requests that these retrofits be put on hold. This subject to the Industry Lighting Workshop to be held on 1 February 2012. Information pertaining to the workshop to follow.
The workshop in question was held as planned, and the matter was debated at length until it was essentially agreed that in fact no applicable standards exist, and Eskom would produce a "directive on T8 to T5 conversions going forward". When asking whether to continue installing these products, one delegate at the workshop was advised to adhere to the dictates of the Consumer Protection Act in the absence of regulatory standards.
Addressing the workshop, Rob Henderson, a senior lighting specialist at Eskom, referred to a recommendation published by the European Union Low Voltage Directive (LVD), which points to a "common failure" involving unprotected access to live components, presenting an "easily accessible electric shock hazard".
These concerns were raised at the 26th LVD administrative co-operation working group (ADCO) meeting and it was concluded that market players from manufacturers to importers, distributors and retailers are largely unaware of the safety risks posed by replacement tube assemblies.
Regarding the "modification" of luminaires, the LVD states that industry players who bring to market modification kits must ensure that incorporation of these kits does not render the luminaire unsafe. This may require a precise definition of the types of luminaries suitable for conversion, clear instructions and procedures on how to check the modified luminaire.
The LVD further advises that industry players who bring to market products either for retrofitting be responsible for the safety and compliance of these products, and calls for technical documentation which includes risk assessments and descriptions of technical solutions adopted and verification procedures followed.
The industry has been warned, and no-one, including Eskom, can say that they were not aware of the dangers to the public!