EICR Certificate not issued. Not all circuits RCD protected rated C2

[Simon47]

Personally I think government are OK on this - you inspect & test to current regs*, and if there are C1 or C2 defects then the installation is dangerous and needs rectification. I lay the blame for the confusion at the door of the scams who have a vested interest in drumming up work for their members. I note that a lot of the discussion here relates to guidance from the scams - and specifically guidance suggesting defects be rated more seriously that some here think is warranted.

* Well, it would be if that's what the regs actually said.

 

[EricMark]

I would say the whole problem is the EICR was never intended to be used to show if a property can be rented out, if to fit a new socket I will need to have a new consumer unit fitted, I need to know. I need to know what needs to be done to comply with current edition, so yes it is done to current edition.

There is a problem in I don't have a copy of the 14th Edition so I could not say if the property complied with it or not. This is from 17th Edition don't have 18th to hand.

BS 7671:2008 Requirements for Electrical Installations was issued on 1st January 2008 and is intended to come into effect on 1st July 2008. Installations designed after 30st June 2008 are to comply with BS 7671:2008.

Note the word "designed" so that quote says it does comply with 17th Edition if designed before 30st June 2008 and complied with edition current at the time.

C1, C2, C3 do not say does not comply with regulations, it says how dangerous it is, there was a 4 which said complies with previous edition, but that was scrapped. So ' Danger present. Risk of injury. Immediate remedial action required.' is the same what ever edition one is using. The same with 'Potentially dangerous - urgent remedial action required.' if it is potentially dangerous then that can't change depending on which edition. 'Improvement recommended.' however will depend on the edition used.

So the big question what makes some thing which was not potentially dangerous in 1992 when BS 7671 first came out, potentially dangerous today? The answer must be the equipment used today which was no available in 1992, so what we are looking at is the switched mode power supply, in 1992 we would transform voltage then regulate there were very few items which rectified mains, so the only change that I can see is the types of RCD used to protect with a TT supply. So I can see a good reason to issue a C2 when the RCD used on a TT supply is type AC. That is about the only thing which in 1992 was safe but in 2018 is not safe.

Can anyone think of anything else which is not safe today but was safe in 1992?

C2 does not mean does not comply with BS 7671:2018 it means potentially dangerous, and over the years the electrical characteristics of properties change, be it the water pipes changed to plastic, or the switch plates changed to metal, or even the supply voltage dropped from 250 to 230.

If I as an electrician but not a member of any scheme do any electrical work I need to issue a minor works or installation certificate, and if any of that work is on the list of notifiable work I need to inform and pay the LABC fee before I start, which is little more than a tax, the law has changed slightly in now in England I need to hold a level 3 or higher qualification, in Scotland seem to remember I must have attended a course in last 5 years, but in essence since I have passed my C&G 2391 I can if I got some professional indemnity insurance start doing EICR's which are legal. I can't issue a compliance certificate or a completion certificate, but I can make a report.

It seems SSE have an insurance, which for under £70 a year covers the house holder for any repairs to the electrical installation and there is a full report made before they take on the property and a yearly check done. Read about it on another forum, and the home owner was adamant his house was OK as nothing had been reported wrong, he has a TT system with a 100 mA RCD with no type marked on it. We were trying to tell him he needed a 30 mA RCD before fitting a new 9.5 kW shower, and the Wylex fuse board although the fuses had been replaced with MCB's was also past its use by date.

So most electricians do not want to end up in court, so we play safe, at least I do, and as far as an EICR goes that means following the electrical safety councils best practice guide even if I don't agree with it, I want to if I have to stand up in court to say I followed the recommendations. And to be frank I have all RCBO protection in my house, so to say to some one else you don't need it does not some how ring true, I made a mistake and thought I was fitting type B as that is what is said on the boxes, seems fitted type AC, so I have ordered 2 type A to replace those feeding the sockets.

So if you go into a property with those silly power line units fitted on a TT supply, do you give it a C2 unless fitted with type F RCD? If not why not?

 

[EricMark]

It should be borne in mind that, as stated in the introduction to BS 7671, existing installations that have been constructed in accordance with earlier editions of the Standard may not comply with the current edition in every respect, but this does not necessarily mean that they are unsafe for continued use or require upgrading

Consumer units having rewirable fuses can continue to provide satisfactory service (cover removed for illustrative purposes)

Where some thing has been changed for example the earthing arrangement in a bathroom to a latter edition clearly it all needs to be to same edition, so it may NEED RCD protection.

The biggest problem I see where RCD's have been added is where when on fails to keep essential supplies i.e. freezer only option is to run cables up/down stairs, the risk of tripping over cables on the stairs likely exceeds the risk from shock not having a RCD.

 

[Simon47]

What has changed is both the perception of, and attitude to, risk. At one time, it was considered "normal" to have a bayonet plug on appliances and plug them into a light socket with no earth - while the risks from doing that have not changed (if anything they've reduced with things like double insulated appliances), our attitude to the risk of doing that have changed and we no longer consider it "safe".

 

[UKPN]

The aspects to be covered in an EICR include
Identification of non-compliances with the current edition of BS 7671, or installation defects, which may give rise to danger.

Must we go through this every time regarding eicr’s?
It is only logical that they are inspected against the current wiring regulations.
We all acknowledge the HSE foreword about how older installations are not necessarily unsafe etc etc, we cannot dig into the archives of wiring regulations based on when an installation was first put into service as safety has well and truly evolved.

Thats your opinion,

Front of what book?

It is made very clear in BS7671 that EICRs are carried out to the current edition and any non-compliance which has a safety implication should be coded accordingly. You are probably falling into the common trap of misreading the note that points out that compliance with a previous edition does not necessarily mean something is unsafe.
The key point about this is 'not necessarily' meaning it may or may not be unsafe, but non compliance with previous editions on its own is not grounds for something being unsafe.
Fused neutrals and red and black conductors comply with previous editions, one is safe and not coded, one is unsafe an coded.

Playing with words, (again) lets say you have a water main earth, .3ohms. perfectly alright.

 

[EricMark]

My under standing is every issue of wiring regulations has a start date after which anything designed after that date should comply, I will agree it is hard to work out the date an installation was designed, so with lack of paperwork giving design dates, then only option is to test to current standards. This is also only option when it is clear alterations have been made. But the regulations are very clear as to dates they cover. Of course other problem is I don't have a copy of the 14th and 15th edition.

However simple fact is items don't become dangerous simply because of a change in standards, wiring can degrade, and items can be damaged, but if the installations was OK without a RCD in 1998 then it is still OK without an RCD.

So we have two supply types, TT, and TN, as as far back as I can find reference to a TT supply has required some type of earth leakage trip on all circuits, so with a TT supply lack of RCD is clearly a failure irrespective of age. With a TN supply it depends on the ELI, where the earth loop impedance is 0.8 ohm which is allowed with TN-S then it may well be the ELI for some circuits is not low enough, but with an ELI of 0.35 ohm as found with a TN-C-S supply then it unlikely any circuit is below the accepted levels. So as long as the ELI is low enough, lack of a RCD does not produce a danger, so can not be a C2 it can only be a C3.

So no RCD and ELI below required value C3 above C2.

The coding 4 was removed from the EICR, years ago there was a code 4 to say does not comply with current regulations, but it was decided this caused confusion and the EICR was simply to say if safe, not to say if it complied with current regulations, and if safe in 1954 and nothing has degraded then it is still safe.

I was reading the Scottish government guide lines on doing an EICR for rented property, and I noted it said lack of an RCD may be a failure, not is a failure, but may be, and yes if a TT supply it is unlikely to cause the circuit to automatic disconnect in the event of a fault so that would be a failure.

Remember we are not looking as compliance with BS7671 we are looking for danger, this brings up one interesting point with use of RCD as the only method of auto-disconnection. If the MCB can also trip as with TN supply this does not really matter, only looking at TT supplies. What I am looking at is the type of RCD, we have type AC, A, F and B and since we also have a type B MCB with RCBO's there has been a problem, we should refer to curve B with MCB and type B with RCD so no errors, but I bought type B RCBO's thinking the RCD part was type B only to find actually type AC.

So this depends on appliances in the home, with inverter fridge/freezer or washing machine we really need type A, with powerline adaptors then type F, so with a TT supply the result of the EICR can be dependent on the equipment used in the house, as to how a tenant would act if we said sorry you can't use powerline adaptors in this house as it is all RCBO as to date no RCBO type F is available so sorry you need to either move out within 28 days or stop using powerline adaptors I don't know?

 

[davesparks]

Thats your opinion,

Playing with words, (again) lets say you have a water main earth, .3ohms. perfectly alright.

I am not playing with words.

By that I assume you mean a water pipe being used as the means of earthing and having an impedance of 0.3 ohms?

This is not immediately dangerous not potentially dangerous (within reason), so it cannot be a C1 or C2. It is not compliant, and it could be improved, but the improvement would not improve the safety of the installation as it is, so I don't see a C3 could be applied either.

I would however make a note so that the customer is informed that it is not an ideal situation and explain why.
[automerge]1596747556[/automerge]

My under standing is every issue of wiring regulations has a start date after which anything designed after that date should comply, I will agree it is hard to work out the date an installation was designed, so with lack of paperwork giving design dates, then only option is to test to current standards. This is also only option when it is clear alterations have been made. But the regulations are very clear as to dates they cover. Of course other problem is I don't have a copy of the 14th and 15th edition.

However simple fact is items don't become dangerous simply because of a change in standards, wiring can degrade, and items can be damaged, but if the installations was OK without a RCD in 1998 then it is still OK without an RCD.

EICRs are carried out to the current regulations regardless of when they were installed.

No items do not become dangerous because the regulations have changed. The regulations are changed when something is found to be dangerous that was previously thought to be safe, or has become unsafe due to other factors.
The item which is now viewed as dangerous has (usually) always been dangerous, it is our understanding of the danger which has changed, not the danger itself.
Regulations also change when new technology or unstanding allows improvements to be made for safety.

No, an installation which was not required to have an RCD in 1998 is not OK now, if it is required to have an RCD by current standards then it is noted on the EICR and given an appropriate code, often a C3 'improvement recommended' because a safety improvement can be made.

 

[EricMark]

EICRs are carried out to the current regulations regardless of when they were installed.

Nearly correct, and the current regulations say an installation designed after the date should follow the regulations, and every set has some thing like this

BS 7671:2008 Requirements for Electrical Installations was issued on 1st January 2008 and is intended to come into effect on 1st July 2008. Installations designed after 30st June 2008 are to comply with BS 7671:2008.

followed by

Existing installations that have been installed in accordance with earlier editions of the Regulations may not comply with this edition in every respect. This does not necessarily mean that they are unsafe for continued use or require upgrading.

so following current regulations means you use the regulations in force at the time of the design.

It has nothing to do with when installed, it was when it was designed that matters. That was your only error with that statement. Where legislation has caused a change then yes we have to reflect that in the report, but even today properties designed before 1966 can still have no earth terminated at lighting equipment as long as the notices are affixed and there are no exposed metal parts likely to connect to earth i.e. Class II.

There are some things which did not exist in 1950's and we do need to consider changes like solar power and electric cars which may require an RCD which was not invented at the time of the design. And also things like the water and gas supply being now plastic, or TN-S being changed to TN-C-S so we can not ignore what has happened since it was designed.

The example that comes to mind is the use of powerline adaptors which it would seem necessitate the use of type F RCD's where the RCD is the prime protective measure. i.e. TT installations. Where the problem arises these are simply plugged in, so simply unplugging them means it's no longer a potential danger, the same clearly applies with overloaded sockets, and inverter fridge, freezers, and washing machines.

Other problems are the lack of previous editions to check what was required, my earliest is BS7671:2001 even the Scottish Government in their guide lines point out lack of RCD protection would only be a C2 in certain circumstances, i.e. TT supplies, and the Electrical Safety Council with their best practice guide 4 issue 5 also point out having the old Wylex fuse board is not a reason to issue a C2.

When I took my C&G2391 we had a 4th code, does not comply with current edition, that was removed, as it simply does not matter, what we are looking for is how safe the installation is, not if it complies with current edition. And there are some things I would mark as C2 even though they did comply when the installation was designed, a good example is an ELCB-v.

We need professional indemnity insurance to complete an EICR because we are giving a professional opinion, we are not simply following the current BS7671 or any other document, we are using our years of experience to decide if safe.

Would you believe it when I say I read an EICR with a C1 listed and the circuit was still live, and the fault not corrected, my first question was when it is classed as dangerous why did you turn it back on? Answer we didn't the inspector left it switched on, how can you really trust anyone doing an EICR who does not either correct or isolate when he finds a C1? Maybe he likes prison food?

Oddly although I live in Wales it is the Scottish law I have been looking at, and that clearly states any C1 has to be made safe before the inspector leaves the premises. And if repaired a minor works or installation certificate must be attached to the EICR.

 

[Grant1987]

My under standing is every issue of wiring regulations has a start date after which anything designed after that date should comply, I will agree it is hard to work out the date an installation was designed, so with lack of paperwork giving design dates, then only option is to test to current standards. This is also only option when it is clear alterations have been made. But the regulations are very clear as to dates they cover. Of course other problem is I don't have a copy of the 14th and 15th edition.

However simple fact is items don't become dangerous simply because of a change in standards, wiring can degrade, and items can be damaged, but if the installations was OK without a RCD in 1998 then it is still OK without an RCD.

So we have two supply types, TT, and TN, as as far back as I can find reference to a TT supply has required some type of earth leakage trip on all circuits, so with a TT supply lack of RCD is clearly a failure irrespective of age. With a TN supply it depends on the ELI, where the earth loop impedance is 0.8 ohm which is allowed with TN-S then it may well be the ELI for some circuits is not low enough, but with an ELI of 0.35 ohm as found with a TN-C-S supply then it unlikely any circuit is below the accepted levels. So as long as the ELI is low enough, lack of a RCD does not produce a danger, so can not be a C2 it can only be a C3.

So no RCD and ELI below required value C3 above C2.

The coding 4 was removed from the EICR, years ago there was a code 4 to say does not comply with current regulations, but it was decided this caused confusion and the EICR was simply to say if safe, not to say if it complied with current regulations, and if safe in 1954 and nothing has degraded then it is still safe.

I was reading the Scottish government guide lines on doing an EICR for rented property, and I noted it said lack of an RCD may be a failure, not is a failure, but may be, and yes if a TT supply it is unlikely to cause the circuit to automatic disconnect in the event of a fault so that would be a failure.

Remember we are not looking as compliance with BS7671 we are looking for danger, this brings up one interesting point with use of RCD as the only method of auto-disconnection. If the MCB can also trip as with TN supply this does not really matter, only looking at TT supplies. What I am looking at is the type of RCD, we have type AC, A, F and B and since we also have a type B MCB with RCBO's there has been a problem, we should refer to curve B with MCB and type B with RCD so no errors, but I bought type B RCBO's thinking the RCD part was type B only to find actually type AC.

So this depends on appliances in the home, with inverter fridge/freezer or washing machine we really need type A, with powerline adaptors then type F, so with a TT supply the result of the EICR can be dependent on the equipment used in the house, as to how a tenant would act if we said sorry you can't use powerline adaptors in this house as it is all RCBO as to date no RCBO type F is available so sorry you need to either move out within 28 days or stop using powerline adaptors I don't know?

This is the side of electrics which I dislike you are over complicating the situation and the simple electrician like myself ? without all the waffle let’s upgrade the consumer unit and bring the property up to current standards. I know this isn’t always possible as £££ is the defining factor and you will find ways to avoid doing so but as much as possible upgrade

 

[EricMark]

Who said electrics was easy? I started with an apprenticeship and collage day release, and then a period just muddling along with everyone else, in the late 90's I returned to UK and every second word out of electricians mouths seemed to be 16th Edition says, and in the end bit the bullet and returned to first college and then university, and yes when I returned I realised how many errors I had been making.

I also realised I was not that good at maths, and I do think there was a lot of luck involved when I got my degree, however it did teach me how to read, and so many things I thought I knew were wrong as been reading about them out of context.

In BS7671:2008 it says "Joints shall not be made in cables except where necessary as a connection into a circuit." however that only refers to exhibitions, shows and stands, it is so easy to hunt the document and miss some preamble as to what this section is talking about. For years I thought a socket had to be at least a meter from a sink, it seems that was 14th edition although I don't have a copy to check.

And of course this is the problem we don't have a library of books to check regulations, we have to make a judgement is this dangerous, is it likely to become dangerous, or will the owner need to modify this in near future and should he be warned.

New showers invariably say RCD must be fitted, and the regulations have said for many years manufactures instructions should be followed, so even if designed in 1960, when fitting a new shower a RCD needs adding, same with boilers, and many other items. I really did expect my cooker with induction hop to say RCD must be fitted but no.

Personally what at 13 years old, (he is over 40 now) my son started to study to be a radio ham, I felt I wanted to protect him, so since around 1992 my house has been RCD protected, however father-in-laws house was sold last year and still had no RCD's fitted and it was him who got me to fit them to protect my son. This house was quickly changed to all RCBO, again I think that makes sense. But I can't give a house a C2 for no RCD however much I like them unless TT.

 

[Grant1987]

Who said electrics was easy? I started with an apprenticeship and collage day release, and then a period just muddling along with everyone else, in the late 90's I returned to UK and every second word out of electricians mouths seemed to be 16th Edition says, and in the end bit the bullet and returned to first college and then university, and yes when I returned I realised how many errors I had been making.

I also realised I was not that good at maths, and I do think there was a lot of luck involved when I got my degree, however it did teach me how to read, and so many things I thought I knew were wrong as been reading about them out of context.

In BS7671:2008 it says "Joints shall not be made in cables except where necessary as a connection into a circuit." however that only refers to exhibitions, shows and stands, it is so easy to hunt the document and miss some preamble as to what this section is talking about. For years I thought a socket had to be at least a meter from a sink, it seems that was 14th edition although I don't have a copy to check.

And of course this is the problem we don't have a library of books to check regulations, we have to make a judgement is this dangerous, is it likely to become dangerous, or will the owner need to modify this in near future and should he be warned.

New showers invariably say RCD must be fitted, and the regulations have said for many years manufactures instructions should be followed, so even if designed in 1960, when fitting a new shower a RCD needs adding, same with boilers, and many other items. I really did expect my cooker with induction hop to say RCD must be fitted but no.

Personally what at 13 years old, (he is over 40 now) my son started to study to be a radio ham, I felt I wanted to protect him, so since around 1992 my house has been RCD protected, however father-in-laws house was sold last year and still had no RCD's fitted and it was him who got me to fit them to protect my son. This house was quickly changed to all RCBO, again I think that makes sense. But I can't give a house a C2 for no RCD however much I like them unless TT.

I never said it was easy but can be easily simplified by upgrading as much as possible which I’m a firm believer of, I can’t give you quotes or reasons to justify my opinion and personal beliefs but I don’t see how you can be happy with a 40,50 year old install number of issues normally no RCD protection being one, especially with sockets having potential to be used for outdoor use. Undersized tails, Earth, bonding. Whole house being on one ring main. 300mm is the required minimum distance from sink or drainer. I know some of this does not mean a C2 or C1 but it’s due an upgrade isn’t it

 

[Ian1981]

You inspect and test to the current edition of the wiring regulations, this is echoed in such guidance as , gn3, electrical safety first best practice guide 4, practically every guidance resource out there, when it was designed has little relevance, it’s safe for continued use or it’s not.
Most non compliance’s will attract a C3 if things like rcd protection in bathrooms is not present, this was not a requirement years ago but it is now an improvement of safety practice and must be recorded as an improvement of safety on the report.
imagine not coding this because the 15 the edition when the installation was designed to did not require it, what is the point of there being a C3 code in the wiring regulations?
To think this would be acceptable is negligent on the inspectors behalf.
Obviously there is no requirement to upgrade an electrical installation to the current edition, there can’t be, you’d be constantly upgrading things, this is what it means when the regulations comment that older installations designed to bs7671 may not necessarily be unsafe, things like plastic Cu’s are an example of this, where not enclosed in a non combustible cabinet, lack of additional protection for cables buried in wall etc.

 

[Vortigern]

Introduction to all regs really;
The Regulations apply to the design, erection and verification of electrical installations, also additions and alterations to existing installations. Existing installations that have been installed in accordance with earlier editions of the Regulations may not comply with this edition in every respect. This does not necessarily mean that they are unsafe
for continued use or require upgrading.




Regs 651.2
NOTE 2: Existing installations may have been designed and installed to conform to previous editions of BS 7671, applicable at the time of their design and erection. This does not necessarily mean that they are unsafe.

By all means comply with the current edition, but fully comply! The above is in the 18th edition. Too many persons of doubtful character insist items must be upgraded.
Personally I would rather (and happily) salvage what is good and improve an existing installation where it manifestly tests out well. In fact it really annoys me on one job the client wanted me to test their light circuit, I did and found >2Mohm etc. and stated it was good for continued use but may be at it's end of life within a couple of years. Another spark, Long intake of breath, "needs replacing sir" (lie!), and I get pilloried by the client for not telling them that!

 

[Ian1981]

All the regulations are saying is that you do not C2 every non compliance with bs7671 because older installations cannot possibly fully comply so it avoids unnecessary works being carried out.

 

[Simon47]

I never said it was easy but can be easily simplified by upgrading as much as possible which I’m a firm believer of ...

I'll preface this by saying that I could be wrong - I'm prone to missing nuances in communications.

But what your post says to me is that you are one of the charlatans who have decided not to make the effort to learn the regs or to think, you just go in and do the "<sucks through teeth>You need a new CU mate, that'll be £X". You don't design an installation, you apply the rules of thumb from the on-site guide and assume it'll all be OK; you don't think about any deviation from current regs and assess whether it's actually a safety issue, you just tell the customer they need to be upgraded.
As I said, I could be wrong - but your post comes across as indicating that you are the sort of person that shouldn't be doing EICRs, or advising anyone else how they should be done.

No offence intended - it's just how I read you post.