My reply to the letter mentioned below in this stream to the ESS
Dear Mr Stannard,
Section 1.1.3 Compliance, states-
Part 2 of this standard contains means of compliance for gas installations with appliances and equipment generally under 250 MJ/H (70 Kw) and Part 3 contains means of compliance for gas installations with appliances and equipment generally over 250 MJ/H (70 Kw). Alternative means of compliance may be used provided they can be demonstrated to meet or exceed the performance criteria of Part 1.
The above excerpt from NZ 5261, is in relevance to my application in positioning an appliance and is only in association to part 2, not part 3 as inferred in your email below.
I had sized the pipe correctly, made of materials fit for the purpose, which was fixed to the wall sufficiently (both pipe and appliance), and I positioned the water heater well with in the parameters of two documents. These are the only parameters that are open to influence in installing an appliance open to a gasfitter.
You have stated-
“Energy Safety does not believe it was envisaged that the approach of applying a mixture of standards would be applied to domestic and similar smaller capacity installations”.
And
“In any case, as I have advised you previously, any departures from Part 2 should have been documented to demonstrate how the essential requirements of Part 1 are met.”
In light of your comments, please can you-
· direct me to the reference documents that state that this all should have been documented, relevant by date.
· direct me to the reference documents that state that a “mixture of standards” is not acceptable, relevant by date.
· explain how that the point 1.1.3 “compliance” ,mentioned above, is to be interpreted and where does it say not to mix standards, relevant by date.
Of note is that the new AS/NZS 5601 takes a similar tact regards to compliance and alternative solutions-
From the new AS/NZS 5601, that will replace NZ 5261-
“Where a Standard is cited as part of a means of compliance or in an Appendix, any Standard with equivalent performance requirements may be used as an alternative means of compliance in New Zealand”.
I am sure the UK authors’ of the “J” document would have had safety as their main intention and that fumes do not enter the building, in as much as the document refers specifically to a “FAN FORCED APPLIANCE, UNDER AN OPENING WINDOW”.
And in that vein I offer the below evidence as proof of performance, taken from an earlier email from me to you.
The rigidity of the clearances for a flue terminal in relation to an opening window within 5261 is undermined by the attached Canadian Standard, which is stated in NZ 5261 in part 3 as being a standard that if adhered to means you have complied, on page 121 of NZ 5261 , and is also produced in 2000. It states in 8.14.8 that (iii) 3 ft (900 mm) for inputs exceeding 100 000 Btuh (30 kW); please note that there is no upper limit for mega joule rating or whether it is fan driven, which 5261 does and allows much smaller distances for fan forced flues. This would allow a gravity type flue 900mm below an opening window with the fumes behaving like cigarette smoke drifting upwards where as the appliance in question would eject to fumes some 3 or 4 metres away perpendicular to the dwelling, where they would be diluted before potentially returning to any opening in to the building.
Also Table 16 in 5261 allows for an “active” mechanical inlet, mentioning specifically a spa blower, 500mm nearer than a “passive” open window. This is confusing because it would place the fumes directly below the occupier of the spa, with them masked by the steam, in one of the smallest rooms in the house, which is also not allowed for. So we have a situation where a very powerful fan sucking air into a building is allowed 500mm nearer than a window that is just open, with no vacuum behind it.
The attached British document is the one I would like you to pass judgment on its use, specifically clearances from opening windows for fan forced flues, which allows for 300mm, nearly half the 540mm on site. I also bring to your attention the reports mentioned in the Rinnai letter and ask you to view in light of this and that is from an Australian Gas Authority.
Also of note the clearances for table 16 were amended in May 05, specifically for clearances to opening windows, all be it for horizontal measurements.
There are other numerous references to other British Standards and would have thought if these were ok then this one would be too, British Standards are recognised around the world and as a mark of quality and safety.
This British Standard is still used by over 65 million people who live, in some areas, in much denser numbers very close together. The weather is very much the same as NZ and gas has a much larger per capita use by a far greater population of the UK. The houses are built in a western style very similar to NZ, the biggest difference being that we have much more space here in NZ.
Can I in the future use this document in positioning a fan forced appliance under an opening window, a simple yes or no would be sufficient, please explain your reasons for no.
Please be aware this will form part of my legal action against my loosing my home, business, reputation and time with my kids. I have had to work away for 18 months, please see attached document for the history of how a corrupt and nepotistic Industry Board and their appointed “impartial” investigator effected my family, I do this not for sympathy but to make sure you are fully informed.
There is also a definition that I want to make sure you are aware of…. Collusion… secret cooperation between people in order to do something illegal or underhand.
QUESTION- Which of the people in the attached document had the publics health and safety fore most in their intentions…. And be aware this mans work is still out there, well over a decade worth.
Thank you Paul Gee.