TfL Ref: 1844-2223
Thank you for your two emails received by Transport for London (TfL) on 1 November 2022 asking for information about LPA Industries Niphan products, following your previous request for information, TfL reference: 1766-2223.
Your request has been considered in accordance with the requirements of the Freedom of Information Act and our information access policy. I can confirm that we hold some of the information you require. You requested the following:
A LPA the manufacturer of the “Niphan” sockets list the following statement on page 12 of their product brochure:
Product compliance
LPA’s Niphan connectors complies with the following standards and directives:
l BS EN 6194B:2009 Connectors safety requirement and tests
l BS EN 60309-1:1999+A2:2012
l Low Voltage Directive (LVD2014/35EU)
l RoHS Directive (2011/66/EU)
The British Standard above in red text is as listed in the brochure and is a misprint.
BS EN 60309-1:1999+A2:2012
recent “due diligence” check by a colleague of the manufacturers claims of compliance to BS EN 60309-1:1999+A2:2012 have highlighted the following:
The LPA Sockets and plugs are not marked as required by Clause 7-“Marking” of this standard, therefore claims of compliance appear to be false and misleading.
Have TfL carried out checks that the products are marked as required by the standard?
Low Voltage Directive (LVD2014/35EU)
If claiming compliance to this directive, products must be CE marked, there was no CE marks on the sample products.
The manufacturer was “vague” or unwilling to provide a copy of a Declaration of Conformity to a colleague. Do TfL have copies of “Declaration of Conformity” for the products?
We can advise that Transport for London (TfL) does not procure these products directly from the manufacturer and they are supplied as a solution via our project supply chain, making TfL the end consumer.
The EN standard does not mandate that the consumer is expected to undertake visual or any other form of compliance checks at the point of installation to validate manufacturers declaration.
Taking these circumstances into account, any further enquiries regarding the manufacturer’s compliance should be taken up directly with the manufacturer or the Office for Product Safety and Standards.
I can confirm that a colleague has contacted the National Inspection Council for Electrical Contracting (NICEIC) regarding the use of products to BS EN 60309-1:1999:+A2:2012 for connection of luminaires to the fixed wiring does not comply with regulation 559.5.1 as this regulation requires a plug and socket to BS EN 60309-2 and advise the following:
“If the installation designer chooses to specify a product that is either used outside of the scope of its intended design or doesn’t have a recognised IEC Standard or BS, the designer would need to provide sufficient justification to demonstrate the installation is no less safe than if a product recognised in BS 7671 were used for compliance in the first instance”
In view of my colleagues findings that the LPA products are not marked as required by Clause 7 of BS 60309-1:1999+A2:2012 they are not compliant as claimed by the manufacturer.
Can you please provide contact details for the dutyholders for:
London Underground
Rail for London
and dutyholders for any other companies within TfL.
In accordance with TfL’s obligations under the General Data Protection Regulation (GDPR), the personal contact details of our duty holders have been withheld from disclosure, as required by section 40 of the FOI. This is because disclosure of this personal data would be a breach of the legislation, specifically the first principle of the GDPR, which requires all processing of personal data to be fair and lawful. It would not be fair to disclose this personal information when the individuals have no expectation it would be disclosed and TfL has not satisfied one of the conditions which would make the processing ‘fair’.
This exemption to the right of access to information is an absolute exemption and not subject to an assessment of whether the public interest favours use of the exemption.
If this is not the information you are looking for, or if you are unable to access it for any reason, please do not hesitate to contact me.
Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.
Yours sincerely
Jasmine Howard
FOI Case Officer
FOI Case Management Team
General Counsel
Transport for London
