Please take some time to read through this. It is written by Widdler's father. I found it on a governement website.. It certainly speaks my mind.
Written evidence submitted by Phil WattsI am writing in response to your invitation for submissions from interested parties on the adequacy of the operation of the current Building Regulations so far as they apply to electrical and gas installation and repairs in dwellings.
I have been in electrical contracting, including domestic work, for the last 25 years, and still work “on-site”, mainly in a Consultative capacity, but involve myself in as much practical installation as time allows.
Over the last seven years I have “migrated” into teaching and training, and currently teach three days a week at East Berkshire College in Langley, Berkshire, delivering Level 3 NVQ Diploma in Electrotechnical Technology (City & Guilds 2357) and Level 3 Certificate in Electrotechnical Technology (City & Guilds 2330).
I also run my own private Training College, Ascot College, where I teach the electrical short courses:
City & Guilds 2382–12, Level 3 Certificate in the Requirements for Electrical Installations (BS7671:2011);
City & Guilds 2392–10, Level 2 Certificate in Fundamental Inspection and Testing of Electrical Installations;
City & Guilds 2391–10, Level 3 Certificate in Inspection, Testing and Certification of Electrical Installations;
City & Guilds 2391–20, Level 3 Certificate in Design, Erection and Verification of Electrical Installations;
City & Guilds 2393–10, Level 3 Certificate in the Building Regulations for Electrical Installations in Dwellings; and the
City & Guilds 4065–10, Level 2 Award or Certificate in Health and Safety in the Workplace.
I also assess NVQ’s and am a Technical Member of the Institution of Engineering and Technology. My reason for giving a “mini-CV” is not because I want to sell myself, but rather to indicate my unique range of experience. I know many electricians, and a lot of college lecturers, but there are not so many that teach in the public sector and the private sector, AND also still work on the tools, at the “sharp end” of any changes in legislation. It is my belief that:
The current system is inadequate in safeguarding health and safety in domestic dwellings.
The system is being administered incorrectly.
There is widespread confusion about what is required, Part P, qualifications etc.
Electricians, electrical contractors, electrical installers and electrical engineers should be licensed
The current system is inadequate in safeguarding health and safety in domestic dwellings
Many non-notifiable works are being carried out incorrectly.
This is due to lack of knowledge and understanding of electrical systems.
These works present a hazard to health and safety in many circumstances.
Removing the option of non-notifiable works will streamline the Regs and make them more effective.
Non-notifiable works includes changing socket outlet and switch plates, which are often replaced with a more decorative option, ie brass or chrome or some other metallic finish. These MUST be earthed by connection to the circuit protective conductor, but often in the case of switch plates especially, this is overlooked, as the existing cpc is often terminated into the back of the switch box.
Non-notifiable works includes replacing ceiling roses, where often there is confusion over the correct connections, due to the colouring of the conductor insulation on switch lines. I have often been called “retrospectively” to sort out a situation where a “DIYer” has connected “all the reds together and all the blacks together” (or browns and blues) and then cannot understand why the circuit trips out as soon as they try to re-energise. Also the rose may be changed for a luminaire, which, if Class I, requires earthing, and often this is overlooked.
Many decorative luminaires do not have adequate space for proper termination of all the circuit conductors on a standard lighting circuit, so these connections are often made into “connector-blocks” and then stuffed into the ceiling void above the luminaire, where they cannot be reached for maintenance, and I have even seen the broken remains of ceiling roses used for this purpose, hence “live” connections are left lying openly under the floors of bedrooms.
There are still many older installations in use that do not incorporate a circuit protective conductor in the lighting circuits, as was the standard when they were installed. It is imperative that no Class I equipment, switches, controls or luminaires are connected to these circuits, and this again is an area where non-qualified “DIYers” lack the knowledge and understanding to safely work on these systems. There are safe methods of installation (as suggested by the Best Practice Guides issued by the Electrical Safety Council), and these are best left to qualified electricians to deal with.
Adding lighting points and adding socket outlets (and fused spurs) to existing circuits involves extending the length of the circuit in addition to the installed design. This will then increase the value of earth fault loop impedance (Zs) for the altered circuit. The circuit will need to be tested to check that the Zs value is still within the parameters laid down in BS7671:2011, to ensure that the circuit protective device still operates within the disconnection time (0.4 seconds for TN-S and TN-C-S systems or 0.2 seconds for TT systems). If the disconnection time is not achieved, circuit conductors may overheat causing damage, or even a fire. Again, only qualified electricians will have sufficient understanding of these issues.
Any additional socket outlet installed will generally need to be protected by an RCD, (which may be integral with the socket for ease of installation), which will need to be tested in accordance with BS7671:2011. Appropriate testing equipment and knowledge is again required.
Any cabling installed to supply “additional sockets, switches and lighting points on an existing circuit” will need to be installed in accordance with BS7671:2008, as well as the Building Regulations. Design and installation knowledge and experience is required if these cables are to be installed correctly and safely, for example, cable calculations must be correctly performed for cables that run through thermal insulation, are grouped with other circuits, are exposed to ambient temperatures above 30 degrees or are protected by BS3036 semi-enclosed fuses. Cables not 50mm deep if concealed into a wall must be adequately mechanically protected, or protected by an RCD, as well as being in the proposed safe zones. Only qualified electricians will have sufficient knowledge and understanding to ensure that these “non-notifiable” works are carried out safely.
Anyone working on electrical systems should have full understanding of the dangers that electricity poses, and in line with the Health and Safety at Work Act 1974 and the Electricity at Work Regulations 1989, proper isolation of all live conductors should be carried out BEFORE any electrical work is started. Again, I have experienced many times where this has not been the case when people are undertaking electrical work in their own home.
To summarise, non-notifiable work is just as likely to cause the same hazards and risks as the notifiable work, as currently defined. By deeming the above types of work to be non-notifiable, we are leaving a loophole whereby non-qualified persons are altering electrical installations and having a detrimental effect on the safety of themselves and the persons currently residing there, visitors, future tenants or occupiers, and possibly neighbouring properties and emergency services in the event of fire.
Most non-notifiable work does not get tested or certified, despite the existence of the Minor Works Certificate, as the vast majority of those carrying out these works are unqualified and are not experienced in inspection and testing. By removing the category of “non-notifiable minor work”, the confusion over what is and is not notifiable will be removed. Only qualified electricians will be able to work on electrical systems, and all work will get inspected, tested and certified properly, and be effectively documented for future information.
Some people will not be happy at the prospect of not being able to do what they want in their own home, and DIY shops may be worried about losing sales, but I believe the benefits to home safety far outweigh these issues. Besides, people can still have whatever they want in their homes, but they will just need to have it done properly and safely by a qualified electrician. They can still buy the accessories from the DIY shops, (I do actually quite often select luminaires from these sources), but they will be installed by someone who knows what they are doing, and the work will be certified at the end, which surely, is what every responsible person wants.
The system is being administered incorrectly
Some local Building Control bodies are still unsure/incapable of administering the system.
The Competent Person/Enterprise self certification scheme is flawed.
Domestic Installer schemes are undermining the system.
In my experience, there is a great deal of uncertainty over the administration of the Building Regulations, specifically Part P—Electrical safety. I have dealt with a number of different Building Control bodies over time, and there has been a range of responses to notification. One that I applied to in fact did not understand exactly what needed to be done, and I effectively talked them through it!
I even had to tell them how much to charge me, and then they admitted that they did not have anyone suitably qualified to come out and inspect my work against the requirements. Another, as recently as December 2011, just asked for a completed Electrical Installation Certificate, and they were happy with that! It is apparent that many local Building Control bodies have not got sufficient resources, either in terms of suitably qualified staff, or time, or both, to administer this system correctly.
Another avenue, of course, is self certification, as a registered competent enterprise. I have, in the past, been an NICEIC approved electrician, as it was necessary for the type of work I was undertaking at the time. I am currently the Qualifying Supervisor for an NICEIC approved firm, in one of my consultative roles, but personally do not subscribe to any of the approving bodies, for a number of reasons.
The self-certification scheme works to a point, in that assessed enterprises “complete” the relevant documentation (certification) after carrying out the works, and send these to the approving body, and for a few pounds the documentation and notification process is completed. The local Building Control receive the documentation from the approving bodies, and issue the notification documents, and the person ordering the work receives the complete set of documents, and everyone is happy.
However in my experience, not everyone who receives “competent enterprise/person status” from the approving bodies is actually competent, let alone a qualified electrician! Domestic Installer courses run by some of the approving bodies last just five days, and one-and-a-half days of that are spent on assessment! Even though they are not supposed to be for inexperienced persons, I am aware that this is not always stringently controlled. Just this week I had a student relay to a class that I was taking, his account of an enquiry he made to the NICEIC about Domestic Installer status. He was advised that all he needed was the City & Guilds 2382 “17th Edition” qualification and that in their view he was “overqualified” because he was completing the City & Guilds 2330 Level 3, and wanted to continue his training with the 2392 and 2391 courses. This may well be an uninformed sales individual relaying incorrect information, but it is apparent that it is not an isolated incident.
Domestic Installer schemes seem to be creating another class of electrical operative, who have not got the required knowledge and understanding of design, installation practices, inspection and testing or certification to be classed as an electrician. These skills cannot be gained on a five day course, but require the commitment of completing a course such as the City & Guilds 2330 Level 3, or the City & Guilds 2357 Level 3 Diploma, plus some of the short courses. Or are we suggesting that domestic electrical installations and safety are not so important and can be completed to a lower standard? I do hope not. In which case, those operating under the banner of “Domestic Installer” or “Part P Qualified” should be “encouraged” to prove their competence properly, by the gaining of meaningful qualifications or assessment.
The awarding bodies have used the competent person scheme as a recruitment tool, and I am dismayed sometimes by the lack of knowledge that some of these “competent persons” display. There are no real checks on qualifications and knowledge, and for larger firms there is still only the requirement for one Qualifying Supervisor who knows how to install and inspect and test properly, and then the whole firm can become an approved enterprise. In this way a firm may have dozens of operatives and many vans, all displaying “approved contractor” or “domestic installer” banners, which the public are being educated to trust, yet they may actually get a non-qualified person completing their work!
Written evidence submitted by Phil WattsI am writing in response to your invitation for submissions from interested parties on the adequacy of the operation of the current Building Regulations so far as they apply to electrical and gas installation and repairs in dwellings.
I have been in electrical contracting, including domestic work, for the last 25 years, and still work “on-site”, mainly in a Consultative capacity, but involve myself in as much practical installation as time allows.
Over the last seven years I have “migrated” into teaching and training, and currently teach three days a week at East Berkshire College in Langley, Berkshire, delivering Level 3 NVQ Diploma in Electrotechnical Technology (City & Guilds 2357) and Level 3 Certificate in Electrotechnical Technology (City & Guilds 2330).
I also run my own private Training College, Ascot College, where I teach the electrical short courses:
City & Guilds 2382–12, Level 3 Certificate in the Requirements for Electrical Installations (BS7671:2011);
City & Guilds 2392–10, Level 2 Certificate in Fundamental Inspection and Testing of Electrical Installations;
City & Guilds 2391–10, Level 3 Certificate in Inspection, Testing and Certification of Electrical Installations;
City & Guilds 2391–20, Level 3 Certificate in Design, Erection and Verification of Electrical Installations;
City & Guilds 2393–10, Level 3 Certificate in the Building Regulations for Electrical Installations in Dwellings; and the
City & Guilds 4065–10, Level 2 Award or Certificate in Health and Safety in the Workplace.
I also assess NVQ’s and am a Technical Member of the Institution of Engineering and Technology. My reason for giving a “mini-CV” is not because I want to sell myself, but rather to indicate my unique range of experience. I know many electricians, and a lot of college lecturers, but there are not so many that teach in the public sector and the private sector, AND also still work on the tools, at the “sharp end” of any changes in legislation. It is my belief that:
The current system is inadequate in safeguarding health and safety in domestic dwellings.
The system is being administered incorrectly.
There is widespread confusion about what is required, Part P, qualifications etc.
Electricians, electrical contractors, electrical installers and electrical engineers should be licensed
The current system is inadequate in safeguarding health and safety in domestic dwellings
Many non-notifiable works are being carried out incorrectly.
This is due to lack of knowledge and understanding of electrical systems.
These works present a hazard to health and safety in many circumstances.
Removing the option of non-notifiable works will streamline the Regs and make them more effective.
Non-notifiable works includes changing socket outlet and switch plates, which are often replaced with a more decorative option, ie brass or chrome or some other metallic finish. These MUST be earthed by connection to the circuit protective conductor, but often in the case of switch plates especially, this is overlooked, as the existing cpc is often terminated into the back of the switch box.
Non-notifiable works includes replacing ceiling roses, where often there is confusion over the correct connections, due to the colouring of the conductor insulation on switch lines. I have often been called “retrospectively” to sort out a situation where a “DIYer” has connected “all the reds together and all the blacks together” (or browns and blues) and then cannot understand why the circuit trips out as soon as they try to re-energise. Also the rose may be changed for a luminaire, which, if Class I, requires earthing, and often this is overlooked.
Many decorative luminaires do not have adequate space for proper termination of all the circuit conductors on a standard lighting circuit, so these connections are often made into “connector-blocks” and then stuffed into the ceiling void above the luminaire, where they cannot be reached for maintenance, and I have even seen the broken remains of ceiling roses used for this purpose, hence “live” connections are left lying openly under the floors of bedrooms.
There are still many older installations in use that do not incorporate a circuit protective conductor in the lighting circuits, as was the standard when they were installed. It is imperative that no Class I equipment, switches, controls or luminaires are connected to these circuits, and this again is an area where non-qualified “DIYers” lack the knowledge and understanding to safely work on these systems. There are safe methods of installation (as suggested by the Best Practice Guides issued by the Electrical Safety Council), and these are best left to qualified electricians to deal with.
Adding lighting points and adding socket outlets (and fused spurs) to existing circuits involves extending the length of the circuit in addition to the installed design. This will then increase the value of earth fault loop impedance (Zs) for the altered circuit. The circuit will need to be tested to check that the Zs value is still within the parameters laid down in BS7671:2011, to ensure that the circuit protective device still operates within the disconnection time (0.4 seconds for TN-S and TN-C-S systems or 0.2 seconds for TT systems). If the disconnection time is not achieved, circuit conductors may overheat causing damage, or even a fire. Again, only qualified electricians will have sufficient understanding of these issues.
Any additional socket outlet installed will generally need to be protected by an RCD, (which may be integral with the socket for ease of installation), which will need to be tested in accordance with BS7671:2011. Appropriate testing equipment and knowledge is again required.
Any cabling installed to supply “additional sockets, switches and lighting points on an existing circuit” will need to be installed in accordance with BS7671:2008, as well as the Building Regulations. Design and installation knowledge and experience is required if these cables are to be installed correctly and safely, for example, cable calculations must be correctly performed for cables that run through thermal insulation, are grouped with other circuits, are exposed to ambient temperatures above 30 degrees or are protected by BS3036 semi-enclosed fuses. Cables not 50mm deep if concealed into a wall must be adequately mechanically protected, or protected by an RCD, as well as being in the proposed safe zones. Only qualified electricians will have sufficient knowledge and understanding to ensure that these “non-notifiable” works are carried out safely.
Anyone working on electrical systems should have full understanding of the dangers that electricity poses, and in line with the Health and Safety at Work Act 1974 and the Electricity at Work Regulations 1989, proper isolation of all live conductors should be carried out BEFORE any electrical work is started. Again, I have experienced many times where this has not been the case when people are undertaking electrical work in their own home.
To summarise, non-notifiable work is just as likely to cause the same hazards and risks as the notifiable work, as currently defined. By deeming the above types of work to be non-notifiable, we are leaving a loophole whereby non-qualified persons are altering electrical installations and having a detrimental effect on the safety of themselves and the persons currently residing there, visitors, future tenants or occupiers, and possibly neighbouring properties and emergency services in the event of fire.
Most non-notifiable work does not get tested or certified, despite the existence of the Minor Works Certificate, as the vast majority of those carrying out these works are unqualified and are not experienced in inspection and testing. By removing the category of “non-notifiable minor work”, the confusion over what is and is not notifiable will be removed. Only qualified electricians will be able to work on electrical systems, and all work will get inspected, tested and certified properly, and be effectively documented for future information.
Some people will not be happy at the prospect of not being able to do what they want in their own home, and DIY shops may be worried about losing sales, but I believe the benefits to home safety far outweigh these issues. Besides, people can still have whatever they want in their homes, but they will just need to have it done properly and safely by a qualified electrician. They can still buy the accessories from the DIY shops, (I do actually quite often select luminaires from these sources), but they will be installed by someone who knows what they are doing, and the work will be certified at the end, which surely, is what every responsible person wants.
The system is being administered incorrectly
Some local Building Control bodies are still unsure/incapable of administering the system.
The Competent Person/Enterprise self certification scheme is flawed.
Domestic Installer schemes are undermining the system.
In my experience, there is a great deal of uncertainty over the administration of the Building Regulations, specifically Part P—Electrical safety. I have dealt with a number of different Building Control bodies over time, and there has been a range of responses to notification. One that I applied to in fact did not understand exactly what needed to be done, and I effectively talked them through it!
I even had to tell them how much to charge me, and then they admitted that they did not have anyone suitably qualified to come out and inspect my work against the requirements. Another, as recently as December 2011, just asked for a completed Electrical Installation Certificate, and they were happy with that! It is apparent that many local Building Control bodies have not got sufficient resources, either in terms of suitably qualified staff, or time, or both, to administer this system correctly.
Another avenue, of course, is self certification, as a registered competent enterprise. I have, in the past, been an NICEIC approved electrician, as it was necessary for the type of work I was undertaking at the time. I am currently the Qualifying Supervisor for an NICEIC approved firm, in one of my consultative roles, but personally do not subscribe to any of the approving bodies, for a number of reasons.
The self-certification scheme works to a point, in that assessed enterprises “complete” the relevant documentation (certification) after carrying out the works, and send these to the approving body, and for a few pounds the documentation and notification process is completed. The local Building Control receive the documentation from the approving bodies, and issue the notification documents, and the person ordering the work receives the complete set of documents, and everyone is happy.
However in my experience, not everyone who receives “competent enterprise/person status” from the approving bodies is actually competent, let alone a qualified electrician! Domestic Installer courses run by some of the approving bodies last just five days, and one-and-a-half days of that are spent on assessment! Even though they are not supposed to be for inexperienced persons, I am aware that this is not always stringently controlled. Just this week I had a student relay to a class that I was taking, his account of an enquiry he made to the NICEIC about Domestic Installer status. He was advised that all he needed was the City & Guilds 2382 “17th Edition” qualification and that in their view he was “overqualified” because he was completing the City & Guilds 2330 Level 3, and wanted to continue his training with the 2392 and 2391 courses. This may well be an uninformed sales individual relaying incorrect information, but it is apparent that it is not an isolated incident.
Domestic Installer schemes seem to be creating another class of electrical operative, who have not got the required knowledge and understanding of design, installation practices, inspection and testing or certification to be classed as an electrician. These skills cannot be gained on a five day course, but require the commitment of completing a course such as the City & Guilds 2330 Level 3, or the City & Guilds 2357 Level 3 Diploma, plus some of the short courses. Or are we suggesting that domestic electrical installations and safety are not so important and can be completed to a lower standard? I do hope not. In which case, those operating under the banner of “Domestic Installer” or “Part P Qualified” should be “encouraged” to prove their competence properly, by the gaining of meaningful qualifications or assessment.
The awarding bodies have used the competent person scheme as a recruitment tool, and I am dismayed sometimes by the lack of knowledge that some of these “competent persons” display. There are no real checks on qualifications and knowledge, and for larger firms there is still only the requirement for one Qualifying Supervisor who knows how to install and inspect and test properly, and then the whole firm can become an approved enterprise. In this way a firm may have dozens of operatives and many vans, all displaying “approved contractor” or “domestic installer” banners, which the public are being educated to trust, yet they may actually get a non-qualified person completing their work!
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