OP
Deleted member 9648
That reg would be a bit ambiguous to me. I'd class a standard domestic tube element as being insulated, it is earthed after all. An uninsulated element to me would mean an electrode type boiler where AC power isapplied directly to the immersed plates and the load current actually flows through the water being heated but I've never seen these in a domestic application, only in industrial steam generators. If the reg refers to an electrode heater though why doesn't it refer to them by name?
Yes,there was a debate a while back on this very subject,not everyone agreed that the reg applied to electrode type elements,which personally I have never come across.But at the time I argued that the reg did not apply to normal domestic elements which are insulated as you rightly state. Still seems to me the most likely reason(reg) why the inspector has applied a code 2,mistakenly IMO.