EIC and EICR issues

[Googers]

Hi folks, first time poster and soon-to-be landlord's assistant (letting my partner's property out now that she's moved in). We've just had a new consumer unit installed and an EIC produced for the works as required, and the electrician told us he checked every socket and circuit as part of his works - even replaced two faulty sockets during his checks.

Given that he's tested everything (wording from our invoice below states as such) we are wondering if the EIC can be used in place of an EICR. As it's likened to an MOT, you wouldn't MOT a new car, but then a new CU and circuit checks is more of an engine replacement than a new car, yadda yadda...

Invoice states:
1 NEW FUSE BOARD . Replace old fuse board . Supply and fit new 10-way RCBO fuse board with SPD Surge protection . Upgrade meter tails to 25mm . Upgrade main earth to 16mm . Upgrade gas earth bonding to 10mm . Upgrade water earth bonding to 10mm if the existing 6mm is not connected . Test all circuits . Issue Electrical Certificate*

*t's and c's

Anyway, we are supposed to have tenants moving in tomorrow but as we only have the EIC and not the EICR, the agent isn't budging. Has anyone got any experience with using an EIC and supporting info to show that all areas have been checked, or are we going to have to try and arrange an additional check that will delay the tenancy?

Cheers!

 

[Dartlec]

Most EICs for DB changes would not meet the requirements for the landlord regulations.

A rewire or new build EIC is the best of all worlds of course, since it should confirm that cables are correctly routed within zones, properly erected, supported, etc. That is almost always a limitation on a consumer unit change EIC, but also on most if not all EICRs too for practical reasons.

So there is probably an argument that a very thorough EIC which clearly states that it inspected 100% of the installation would be no less safe than an EICR and would comply with the spirit of the legislation regarding testing the installation.

However, the letting agent can't be expected to make that judgement so will fall back on the Government guidance, which states that since it hasn't been rewired or newly built, that an EICR is required.

With most certificate software, it takes minutes to convert one to the other, since the schedule of inspections is identical (at least in my software). The only difference is that the number of LIMS may well be higher on a board change compared to an EICR.

So unfortunately the simplest answer in this case is going to be to get an EICR. The electrician should understand the situation and be willing to do one, either free or for very little additional cost.

If you show him the guidance already noted above, then he may be prepared to change his mind. If not, you can ask him to produce something in writing which clarifies why he believes his certificate complies with the law - that may at least make him think about his views.

Failing that, you may be able to get one done cheaper than normal given than much of the testing and documentation work has been done, but then you are asking another inspector to rely on the word of the previous one, which can be troublesome.

 

[loz2754]

Maybe I’m being stupid, but the government guidance in section 6 does seem to make clear an EIC is acceptable?

Now yes, it does give two specific examples of newly built or completely rewired, but surely if the EIC includes the entire installation in its schedules of inspection and test then it meets the criteria of Section 6 and a CU change most certainly does involve inspection and test of the entire installation.

Tin Hat on.

https://www.gov.uk/government/publi...safety-standards-in-the-private-rented-sector

“What about new build properties or new electrical installations?​

If a property is newly built or has been completely rewired, it should have an Electrical Installation Certificate known as an EIC.

Landlords can provide a copy of the EIC to tenants and, if requested, the local authority. The landlord will then not be required to carry out further checks or provide a report for 5 years after the EIC has been issued, as long as they have complied with their duty or duties under the Regulations”

Not really. The inspection and test schedules are more extensive for an EICR than for an EIC. That's because, as has been stated already, an EIC is only to certify work that is detailed on the front page. An EICR covers the whole installation.
So unless the EIC is for a rewire or new build, it is not an acceptable substitute for an EICR.

 

[Burtones]

In this case, the schedule of test results will apply to the full installation as it has had a board change. It's the schedule of inspections that is the problem as that will only apply to the work carried out and not the full installation hence the eicr still being required.

Like others have said though, with the work and testing the electrician has already completed, with a few sensible limitations, they probably have what they need to issue an eicr from home.

 

[dodger421]

Just to clarify you’re all going to issue an EIC for a board change even if the installation doesn’t comply with BS7671 but your work at the board does?

I’m also just going to throw in Electrical Safety Firsts view of this as their best practice guides are oft quoted here and generally are pretty good. Section 4 Certification Page 8 of their Landlords Guide; emphasis mine


“The EIC will indicate whether the electrical work that has been carried out is ‘new’, an ‘addition’ or an ‘alteration’. The term ‘new’ applies where the whole installation has been installed as new, if a complete rewire has been carried out, or where a consumer unit (fusebox) has been replaced.”

https://www.-----------------------...ndlords-guide-england-and-wales-june-2020.pdf

 

[Dartlec]

Just to clarify you’re all going to issue an EIC for a board change even if the installation doesn’t comply with BS7671 but your work at the board does?

If the board install complies, then you can issue an EIC for your work (or explain the departures from 7671 if you believe you are reasonable to do so). It's just a case of ensuring that the extent of installation box is clearly defined what you did and didn't do to avoid issues in the future.

Most issues where the an installation doesn't comply with 7671 to an extent that affects safety would be resolved by a correctly done board change (RCD protection, correctly chosen MCBs, etc.)

Were there any C1 conditions, then I'd not re-energise them unless they were resolved, but I'd make sure the client knew that before I started.

There are some other 'critical' parts, such as main bonding, for example, that would also normally be upgraded or verified before a board was changed.

Anything else, like non IP rated lights in Zone 2 might not be, but having them on an RCD would clearly add safety in any case.

It will usually not be possible to confirm cable routes for a board change, but then most EICRs don't either.

The mantra I work to mostly is to leave things safer than when I arrived.

Having said that, if a new board is being replaced urgently (for example because of a melted terminal), then there might well be non compliances that were not corrected, but the customer should be made aware of them.

Where time permits, I usually do an EICR in effect (or the testing for one at least) before I do a board change anyway, because it helps me identify potential causes for unwanted RCD tripping.

So tl;dr: It might be possible for an EIC for a board change to be correctly issued, but there still to be C2s at the property, C1s are probably much less likely.

 

[dodger421]

Which is my point. The non-compliance’s would be recorded and effectively indicate that the EICR would be unsatisfactory anyway. If you don’t list any departures or non-compliance’s your signature on the EIC for a board change says the entire installation complies with BS7671 because the board change affects the entire installation.

GN3, section 1.4 makes that clear.

 

[Dartlec]

Which is my point. The non-compliance’s would be recorded and effectively indicate that the EICR would be unsatisfactory anyway. If you don’t list any departures or non-compliance’s your signature on the EIC for a board change says the entire installation complies with BS7671 because the board change affects the entire installation.

GN3, section 1.4 makes that clear.

Don't have GN3 to hand, but I'd imagine there will always be grey areas where signing for a carefully written "extent of installation" is not automatically the same as signing an EICR. The immediate example would be a pendant in Zone 2 - I wouldn't refuse to change the board because of it, though the client would be informed of it and encouraged to upgrade. That's different from a C2 on an EICR which requires remedial work within 28 days (under the legislation).

Then the letting agent or landlord would have to know enough to judge whether any particular EIC was to the same standard as an EICR and start to judge whether any issues noted were equivalent to a C2 or a C3, which is never going to be possible.

A well done EIC might cover as much as or more than an EICR with lots of limitations and there will be lots of overlap between the two, but when the guidance states that for an existing property EICR is the appropriate certificate it is always going to be difficult to argue that an EIC covers things.

From the other perspective, there is no reason why an electrician who has completed a thorough EIC could not also issue an EICR with minimal effort and if he will not do so you might have to wonder why.

The guidance may well develop in time, and there will probably have to be a few tragedies or court cases before things are tweaked. Perhaps in time there will be a certain wording on an EIC that will allow it to be used, but the new model forms in the draft amendment appear to limit the schedule of inspection to much fewer things on an EIC compared to an EICR.

I suspect that some of the EICRs done by companies that do 4 a day are not fully indicative of a safe installation, but will tick a box for the agent so will continue to be the 'required' route until things change.

 

[dodger421]

I agree with all of that, and I’ll caveat the entire thing by saying I’m basically playing devils advocate because I’m stuck in isolation thanks to this wonderful pandemic.

Ultimately I see no reason the electrician wouldn’t issue an EICR as well as an EIC if requested to. I guess I’m just arguing at the stupidity of the following situation which is what the rules are effectively mandating

EICR carried out, unsatisfactory with all issues able to be resolved by board change.

Board change carried out, EIC issued which has to inspect and test every point to meet the requirements of GN3/BS7671.

EICR has to also be issued to confirm the EIC for the board change has resolved the original unsatisfactory EICR.

Having nothing better to do I’ve sat and compared the schedules of inspection for the EIC and EICR from GN3. They’re laid out differently, and the EICR drills down a lot more to individual levels, but the gist of the content for both of them is the same in a shorter format on the EIC.

Instead of drilling down 8 separate items for inspection in a Location containing a bath or shower, the EIC has a catch all single sentence.

 

[Burtones]

your signature on the EIC for a board change says the entire installation complies with BS7671 because the board change affects the entire installation

If you tick the 'alteration' box and state in the extent that the schedule of inspections applies to the board change only then surely you're not signing that the entire installation complies?

 

[Dartlec]

I agree with all of that, and I’ll caveat the entire thing by saying I’m basically playing devils advocate because I’m stuck in isolation thanks to this wonderful pandemic.

Ultimately I see no reason the electrician wouldn’t issue an EICR as well as an EIC if requested to. I guess I’m just arguing at the stupidity of the following situation which is what the rules are effectively mandating

EICR carried out, unsatisfactory with all issues able to be resolved by board change.

Board change carried out, EIC issued which has to inspect and test every point to meet the requirements of GN3/BS7671.

EICR has to also be issued to confirm the EIC for the board change has resolved the original unsatisfactory EICR.

Having nothing better to do I’ve sat and compared the schedules of inspection for the EIC and EICR from GN3. They’re laid out differently, and the EICR drills down a lot more to individual levels, but the gist of the content for both of them is the same in a shorter format on the EIC.

Instead of drilling down 8 separate items for inspection in a Location containing a bath or shower, the EIC has a catch all single sentence.

View attachment 61778View attachment 61779

No problem, I enjoy a good discussion and never assume I'm 100% right on anything.

As I understand the legislation, it's not actually necessary to get the EICR reissued as satisfactory. The original EICR + the EIC that confirms the remedial work was done is sufficient as a whole to prove compliance. In fact, a single piece of paper from the landlord that says "all remedial works done k thx bye" is technically all that is called for.

Of course, that is going to cause problems with letting agents too, as they will just have a tick box for EICR - so in most cases it leaves the landlord in a tricky situation trying to get the EICR reissued.

 

[dodger421]

I agree with all of that, and I’ll caveat the entire thing by saying I’m basically playing devils advocate because I’m stuck in isolation thanks to this wonderful pandemic.

Ultimately I see no reason the electrician wouldn’t issue an EICR as well as an EIC if requested to. I guess I’m just arguing at the stupidity of the following situation which is what the rules are effectively mandating

EICR carried out, unsatisfactory with all issues able to be resolved by board change.

Board change carried out, EIC issued which has to inspect and test every point to meet the requirements of GN3/BS7671.

EICR has to also be issued to confirm the EIC for the board change has resolved the original unsatisfactory EICR.

Having nothing better to do I’ve sat and compared the schedules of inspection for the EIC and EICR from GN3. They’re laid out differently, and the EICR drills down a lot more to individual levels, but the gist of the content for both of them is the same in a shorter format on the EIC.

Instead of drilling down 8 separate items for inspection in a Location containing a bath or shower, the EIC has a catch all single sentence.

View attachment 61778View attachment 61779

Don't have GN3 to hand, but I'd imagine there will always be grey areas where signing for a carefully written "extent of installation" is not automatically the same as signing an EICR. The immediate example would be a pendant in Zone 2 - I wouldn't refuse to change the board because of it, though the client would be informed of it and encouraged to upgrade. That's different from a C2 on an EICR which requires remedial work within 28 days (under the legislation).

Then the letting agent or landlord would have to know enough to judge whether any particular EIC was to the same standard as an EICR and start to judge whether any issues noted were equivalent to a C2 or a C3, which is never going to be possible.

I’d also point out that you’d have written that as a non-compliance with BS7671. The EIC now states the installation doesn’t comply with BS7671, which is what the landlord legislation requires. I’d like to think that sort of statement could be interpreted by anyone, but I am fully aware that general stupidity reigns in society so maybe not :-D

 

[Dartlec]

I’d also point out that you’d have written that as a non-compliance with BS7671. The EIC now states the installation doesn’t comply with BS7671, which is what the landlord legislation requires. I’d like to think that sort of statement could be interpreted by anyone, but I am fully aware that general stupidity reigns in society so maybe not :-D

You've clearly not deal with the same landlords/letting agents as me

 

[dodger421]

If you tick the 'alteration' box and state in the extent that the schedule of inspections applies to the board change only then surely you're not signing that the entire installation complies?

Your board change has affected the entire installation. The relevant inspection and testing requirements of Chapter 64 must therefore apply to the entire installation no?

 

[loz2754]

Your board change has affected the entire installation. The relevant inspection and testing requirements of Chapter 64 must therefore apply to the entire installation no?

A board change does not affect the entire installation. It affects every circuit fed by that board, but not every accessory connected to those circuits. So all you do is test at the end of each circuit, you would not inspect every accessory.
Also, what if there is more than one board, but I only changed one of them? An EIC would be issued for that one board change, but the rest of the installation would not necessarily have been affected. Whereas an EICR would state in the extent and limitations that I have inspected the entire installation, subject to the usual limitations. All boards, all circuits, all accessories.
That's the difference between an EIC and an EICR. IMHO of course.

 

[dodger421]

Correct, poor terminology on my part. All circuits fed from that board must be fully inspected and tested to ensure they comply with BS7671. And any sub-boards fed from that board would be included. Additional boards may not be included, but I’d guess that’s unlikely in most private rentals?

If the accessory is connected to a circuit in the CU you’ve changed then it’s affected by the CU change. So you’ll still need to test IR with 2-way switches in both positions for example.

How do you know where the end of a circuit is if you haven’t inspected and tested it though? You need to measure R1+R2 at every point as sampling isn’t allowed in an EIC (and your corresponding tests for an RFC need to be conducted at every point too). Do you do that with a blindfold on so you can say you didn’t inspect anything other than your work at the board?

I think we can all agree when you do a board change you don’t do all of your testing sat in front of the board if you’re doing it properly. And that’s when you’ll see things like non-IP rated lights in Zone 2 and you’ll document those non-compliance’s accordingly.