S008 Communique to cabling suppliers

What do the S008 changes mean to cabling suppliers?

In August 2020, the mandatory telecommunications cabling regulations (AS/CA S008 – ‘Requirements for customer cabling products’ and AS/CA S009 – ‘Installation requirements for customer cabling (Wiring Rules)’) were updated to accommodate significant regulatory, industry and technological changes that have been introduced since the previous editions of the regulations.

Both standards had an 18-month phase-in period to allow the ICT and related industries to get familiar with the changes and put them into effect. This adjustment period was particularly relevant to cabling product suppliers to phase-in products (AS/CA S008) and to cabling installers to get familiar with the changes (AS/CA S009), as well as educators to update their course content. During that time – from 1 September 2020 till 29 February 2022 – either edition of the regulations (AS/CA S008:2010 or AS/CA S008:2020 for products and AS/CA S009:2013 or AS/CA S009:2020 for installation) were applicable.

Note: Both regulations make reference to the Cabling Provider Rules (CPR), which can be obtained from the Federal Register of Legislation website https://www.legislation.gov.au/Series/F2014L01684

However, the phase-in period has ended, so only the 2020 editions of these regulations apply now. So it’s vital for the ICT and other building services industries to know these regulations well and to understand the changes to their respective previous editions.

Noting this fact, the telecommunications regulator – Australian Communications & Media Authority (ACMA) – recently issued the statement “Registered cablers must comply with the 2020 Wiring Rules” stressing: “Cablers cannot use the 2013 Wiring Rules – they must now comply with the requirements of the 2020 Wiring Rules.” So AS/CA S009:2020 is now the single applicable legal instrument as the Wiring Rules.

Key Changes to AS/CA S008:

The objective of the AS/CA S008 regulation is to set out minimum requirements for products used in a telecommunications system to contribute to its safety and integrity, and of the Telecommunications Network to which it is, or will be, connected.

Specifically, the primary aims of AS/CA S008 are:

  • protecting the integrity of a Telecommunications Network or Facility;
  • protecting the health and safety of persons;
  • ensuring access to emergency services; and
  • ensuring interoperability with a standard telephone service.

The principal differences between AS/CA S008: 2020 and the previous 2010 edition are:

  • New Electrical Energy Source classifications (ES1, ES2, ES3) and related terminology used in AS/NZS 62368.1;
  • New definitions for “generic cabling”, “mains supply”, “pit or access hole product” and “registered engineer”;
  • Prohibited markings for underground conduit;
  • New fitness-for-purpose requirement for cabling products;
  • Blown fibre tube system requirements now include those with pre-installed elements;
  • New specification for ES3 generic cable, including conductor resistance, sheath colour and labelling;
  • New compatibility recommendation for 6-position modular plugs and sockets and the use of ‘8P-to-6P insert’ adaptors; and
  • New pit and access hole requirements including cover labelling, installation methods and testing documentation.

ACTION PLAN

  1. If you’re a product manufacturer, or involved in the product supply chain, download the 2020 edition of AS/CA S008 from here – free to download, use, copy and distribute.
    1. the document is in pdf format, so it is very easy to use, especially to find key words without reading the entire document.
    2. For help searching pdf documents, see Breakout Box ‘Word search in pdf documents – an essential tool to quickly find information in any pdf document’ below.
  2. AS/CA S008: 2020 is “The Law” in Australia now, so Australians MUST conform to it, whether they know about it or not. Notably, New Guinea also mandates compliance to AS/CA S008 under NICTA criteria. Elsewhere in the South Pacific like New Zealand, Fiji and other Pacific Islands where cabling isn’t as comprehensively regulated, specifications frequently call for compliance to AS/CA S008 anyway. That being the case, it’s in your best interests to know and understand the regulations, so you can consciously be compliant to them.
  3. Key issues to be wary of:
    1. With remote-powering and digital electricity becoming commonplace in our industry, there’s a high likelihood you’ll soon be asked to supply cable and connectivity for services like PoE and PoH, if you haven’t done so already. It’s important for you to be aware of what S008 says about this under the new Electrical Energy Source classifications ES1, ES2, ES3.
    2. With the NBN now installed to almost all buildings throughout Australia, ICT personnel in Australia are likely to encounter the variety of NBN connection types, so it’s important to know exactly what the boundaries or demarcation points are between customer cabling and the NBN. Other nation-wide broadband networks like the UFB in New Zealand utilise similar interfaces at the network boundaries, so knowing what products to use at demarcation points is even more important.
    3. Changes to regulations are challenging to industries like ours that have lengthy supply chains. Products typically take considerable time from design, manufacture, distribution, before eventually being deployed in cabling installations. The risk of products becoming obsolete after ‘sitting on the shelf’ for some time is very real in the ICT industry, so an 18-month phase-in period is factored into the cabling regulations changes. This allows manufacturers time to ensure products are proven compliant to new criteria, while allowing the supply chain to move its ‘old’ stock that was complaint to the previous regulations but may not be complaint to the new regulations. However, after the phase-in period closed March 2022, all products sold MUST be complaint to AS/CA S008: 2020. Note that severe penalties apply for companies selling non-compliant products. And remember – all that is needed is a complaint from a customer, installer, or even competitor to trigger an investigation by the ACMA.
    4. Providing a service to private or business customers, you’re subject to several laws that are designed to protect consumers, the network, the public, the environment, and a host of other things. Although not lawyers with knowledge of every legal issue, ICT infrastructure professionals need to be aware of their responsibilities and accountabilities. In Australia and New Guinea, AS/CA S008 is a legal instrument that co-exists with many other legal instruments such as construction codes (eg NCC in Australia), Workplace Safety laws, Consumer Protection laws, etc. We’re subject to all these laws and more. It’s in your best interest to at least be familiar with the applicable laws to endeavour to be compliant with them. Consider the scenario in Breakout Box ‘What if something goes wrong…even years from now?’ below.

 

Breakout Box

Word search in pdf – an essential tool to quickly find information in any pdf document

When a PDF is opened in Acrobat Reader (the most common format you’ll open S008 in), open the Find window-pane by typing ‘Ctrl’ + ‘F’ keys together.

When the Find window-pane opens (typically in the upper right corner of screen), search by typing the word(s) you’re searching for inside the ‘text box’. The cursor will go to the first instance of the word(s) being searched for, while the Find window-pane will display Select the Next or Previous buttons to move through the search results.

 

Breakout Box

What if something goes wrong…even years from now?

If something goes wrong on a site you’ve supplied goods to – even years ago – you can still be held liable for the consequential loss. Picture this scenario:

A fire starts in a building that you supplied cable and connectors for telecomms services 10 years ago, caused by a faulty electrical switchboard. The building owner makes a $10 million claim on their insurance company, who dutifully pays it out. The law of Subrogation gives the insurance company the right to recoup its money through any entity deemed as contributory to the loss – in this case the faulty electrical switchboard. So the insurance company lays claims against the switchboard manufacturer, the contractor who installed and commissioned it, the engineer who approved it, and the maintenance company who serviced and inspected it after installation (the amounts determined by the percentage of liability deemed by the law).

Not to worry, because you were only involved in the telecomms cabling, nothing to do with the electrical services. However, the fire report said the fire alarm didn’t contact the fire brigade because the “phone line was down”, citing “non-functioning connectors” being found at the fire panel. Now you’re implicated and accountable, because you supplied the connectors to the fire panel. You’ve now been hit with a $2 million claim, noting 20% liability, having contributed to the spread (as distinct from the cause) of the fire. Your initial reaction is to claim on your public liability insurance policy, which seems to protect you until your insurer investigates your claim only to find the products you supplied weren’t compliant to the S008 regulations. Now your policy is void and you have to either pay the $2 million claim out of your own pocket, or fight your insurance company in court, which you’ll likely lose.

The simple message – cover yourself from such exposure by ensuring compliance to the relevant regulations, which can only be done by understanding and applying them.