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

[EricMark]

I must admit I see a problem in using old editions of wiring regulations, one is you don't have them to check on, and two you often don't know the age of the installation. We should get the last EICR before we start, and that should tell us if any new work has been done since last inspected, and show once we do our own inspection and test if anything has degraded.

I can see the point in the absence of the previous EICR may be we should assume new, and that the report is being used by the LABC inspector to verify it has been installed to current standards.

However all the deviations should get a C3 unless ‘Potentially dangerous’. Urgent remedial action required. And so the question arises even if a new installation does the lack of RCD protection with a TN supply make the installation potentially dangerous? either it does or it doesn't it does not really matter when installed.

So look at another deviation from the British wiring regulations, let us say some one who is continually moving between Germany and Britain wants a house built with all German sockets, this does not comply with British wiring regulations, however the Part P document says to a relevant standard, so there is nothing stopping one from following German regulations, bit of a problem reading them as don't read German, and can't use a scheme membership to say the comply, it would need a completion certificate, however it is permitted under British law.

My point is we need to look for it being potentially dangerous rather than not complying with British regulations it would need to comply with CENELEC harmonization documents, but not British.

So if a German firm decide it wants 5 houses made available for its key workers in the UK with German sockets it can have them built, and I have been to UK houses built for USA serviceman again to USA standards, with 120 volt outlets, never tested the frequency before you ask. And this is permitted.

So clearly an EICR does not need to follow the BS 7671, and where the electrical safety council say in their best practice guide we should not issue a C2 I think one needs a very good reason to say otherwise.

 

[davesparks]

So clearly an EICR does not need to follow the BS 7671, and where the electrical safety council say in their best practice guide we should not issue a C2 I think one needs a very good reason to say otherwise.

An EICR is a part of BS7671, the standard defines what an EICR is and it is a report on an installation in accordance with BS7671.

The electrical safety council is a self titled entity which has no real power in the industry.

 

[westward10]

There seems to be two sides of the coin with people who carry our EICRs. One side you have competent people with knowledge and experience who require no Guides and may only occasionally refer to BS7671. The other side are those who overcomplicate matters by referring to Guides and doubting what is required from BS7671, this is lack of knowledge and competence derived from taking a testing qualification and thinking it opens the door to ability. We are now seeing this other side on here on a frequent basis.

 

[Ian1981]

There seems to be two sides of the coin with people who carry our EICRs. One side you have competent people with knowledge and experience who require no Guides and may only occasionally refer to BS7671. The other side are those who overcomplicate matters by referring to Guides and doubting what is required from BS7671, this is lack of knowledge and competence derived from taking a testing qualification and thinking it opens the door to ability. We are now seeing this other side on here on a frequent basis.

Nail hit on the head there!

 

[UKPN]

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.


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?

What a load of bull!

 

[Dartlec]

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.

I don't disagree with anything you say. The problem currently seems to be that via legislation, the Government has introduced a situation where you to some extent DO have to upgrade a rented property if you cannot get a satisfactory EICR.

In the past there may have been the situation where an inspector would fail a property, but give the retest date of a year in which to correct things, because the reasons for failure were not dangerous enough or likely enough to happen that immediate action was necessary (This would be some of the C2s, and almost never a C1 I guess)

Now an unsatisfactory report means work has to be completed within 28 days, which will likely mean taking the electricians available, even if they are expensive. Yet none of this was properly explained to the landlords (or tenants) in my experience.

I've recently EICR'd two flats built 15 years ago, both with no RCD protection on anything but the sockets. They have metal framed walls as is the norm. If I had given C2 for lack of RCD protection on that basis, or on the basis of cables less than 50mm deep, as the NAPIT guidance seems to suggest (I'm with NICEIC so go with the ESF guide), then the landlord would likely have had to replace the consumer unit. Switching all the circuits onto the single RCD provided would just mean breaching other parts of the regulations

(These are Legrand, so retrofit RCD may be available assuming the board is designed for it, but even so it's a significant cost to suddenly introduce with a months notice)

Given the lack of answers I can get from the building owners as to fusing and isolation etc, a board change would likely be a real pain too - and not just a 1 hour job special.

Mind you, given the way these flats were thrown up, I'm not sure the electrical installation was ever designed by anyone, let alone to regulations!

 

[Grant1987]

No you’ve misinterpreted me, I don’t force/make any customer upgrade I “recommend” I think most ppl realise that when they have an old rewireable consumer that offers no rcd protection should be upgraded it doesn’t take a spark to realise that. And as for I shudn be carrying out EICRS that’s ridiculous I’m not saying I C2 an old install Just because it’s an old install but with undersized meter tails, Earth, bonding no rcd protection I don’t know who mentioned not requiring rcd protection but I’ll throw a quote back "Regulation 411.3.4 specifies that additional protection from a 30mA RCD is now required for all lighting circuits in domestic properties, without exception. I won’t copy and paste the socket outlets with potential of outdoor use aswell, so I’m just wondering do you agree with me when I say slot of older installs need upgrading in terms of rcd protection and the rest I’ve mentioned

 

[westward10]

I don't disagree with anything you say. The problem currently seems to be that via legislation, the Government has introduced a situation where you to some extent DO have to upgrade a rented property if you cannot get a satisfactory EICR.

In the past there may have been the situation where an inspector would fail a property, but give the retest date of a year in which to correct things, because the reasons for failure were not dangerous enough or likely enough to happen that immediate action was necessary (This would be some of the C2s, and almost never a C1 I guess)

Now an unsatisfactory report means work has to be completed within 28 days, which will likely mean taking the electricians available, even if they are expensive. Yet none of this was properly explained to the landlords (or tenants) in my experience.

I've recently EICR'd two flats built 15 years ago, both with no RCD protection on anything but the sockets. They have metal framed walls as is the norm. If I had given C2 for lack of RCD protection on that basis, or on the basis of cables less than 50mm deep, as the NAPIT guidance seems to suggest (I'm with NICEIC so go with the ESF guide), then the landlord would likely have had to replace the consumer unit. Switching all the circuits onto the single RCD provided would just mean breaching other parts of the regulations

(These are Legrand, so retrofit RCD may be available assuming the board is designed for it, but even so it's a significant cost to suddenly introduce with a months notice)

Given the lack of answers I can get from the building owners as to fusing and isolation etc, a board change would likely be a real pain too - and not just a 1 hour job special.

Mind you, given the way these flats were thrown up, I'm not sure the electrical installation was ever designed by anyone, let alone to regulations!

Why is this new legislation your problem. An EICR hasn't changed due to this you just carry on as normal. The legislation is the landlords problem.

 

[Simon47]

Yet none of this was properly explained to the landlords (or tenants) in my experience.

As a landload, I've just started a new tenancy. It has been "fun" picking apart emails from the agent.
"You must get an electrical certificate" - nope, you already have one on file, and it's called an EICR.
"It must be done by a registered electrician" - nope.
"It applies to all tenancies" - nope, only new ones until next July
"It must be done every 5 years" - well, sort of
So 5 factual errors in one shirt paragraph. And I did point out that before they go advising others, they really should get the facts right. I can't help thinking that the scams are behind some of the misinformation - they are well known for their carefully worded advice that's "not quite a lie" but definitely intended to misinform.

Thinking about that 28 days bit. If you felt that the situation was that it needs upgrading, but not that urgently, you could put some C3s down and give 6 months till next inspection. That means the landlord has to get another one done within 6 months - and is required to provide your EICR to whoever does it, who (if it isn't you) would then see all the C3s and put 2+2 together.
OK, there's nothing to stop them getting a drive by pass from a blind man - but then they could do that in the 28 days anyway.

Mind you, given the way these flats were thrown up, I'm not sure the electrical installation was ever designed by anyone, let alone to regulations!

If anything like the new builds I've seen, I would not be surprised to find all sorts of non-compliances. Mum was looking at one, had she gone agead I'd have taken great pleasure in calling in the scam and asking what they'd be doing about the fraudulent EIC and the people responsible.

 

[Grant1987]

As a landload, I've just started a new tenancy. It has been "fun" picking apart emails from the agent.
"You must get an electrical certificate" - nope, you already have one on file, and it's called an EICR.
"It must be done by a registered electrician" - nope.
"It applies to all tenancies" - nope, only new ones until next July
"It must be done every 5 years" - well, sort of
So 5 factual errors in one shirt paragraph. And I did point out that before they go advising others, they really should get the facts right. I can't help thinking that the scams are behind some of the misinformation - they are well known for their carefully worded advice that's "not quite a lie" but definitely intended to misinform.

Thinking about that 28 days bit. If you felt that the situation was that it needs upgrading, but not that urgently, you could put some C3s down and give 6 months till next inspection. That means the landlord has to get another one done within 6 months - and is required to provide your EICR to whoever does it, who (if it isn't you) would then see all the C3s and put 2+2 together.
OK, there's nothing to stop them getting a drive by pass from a blind man - but then they could do that in the 28 days anyway.

If anything like the new builds I've seen, I would not be surprised to find all sorts of non-compliances. Mum was looking at one, had she gone agead I'd have taken great pleasure in calling in the scam and asking what they'd be doing about the fraudulent EIC and the people responsible.

I think the 28 days but he was referring to was any C1 or C2’s ideally you need to be doing them immediately but I believe the maximum recommended timescale is 28 days not 6 months as if something were to go wrong god forbid, Once the 28 days Have elapsed you would then need to stand up in court and explain why your property wasn’t rectified and compliant with current regulations. So if something needs upgrading as I’ve been mentioning in previous posts which categorises a C2 you need to be upgrading now not 6 months time

 

[Simon47]

Yes, C1 or C2 must be fixed in 28 days. But we're discussing things where there's "some debate" as to whether it should be C2 or C3. I was just pointing out that if your professional judgement says that C3 is reasonable, one way to stop it getting ignored for another 5 years would be to give a test interval of (say) 6 months.
But each situation needs to be taken on it's merits.

 

[Grant1987]

Yes, C1 or C2 must be fixed in 28 days. But we're discussing things where there's "some debate" as to whether it should be C2 or C3. I was just pointing out that if your professional judgement says that C3 is reasonable, one way to stop it getting ignored for another 5 years would be to give a test interval of (say) 6 months.
But each situation needs to be taken on it's merits.

Yea true, although I don’t think landlords including yourself would appreciate Being charged in 6 months time for another EICR

 

[davesparks]

Yes, C1 or C2 must be fixed in 28 days. But we're discussing things where there's "some debate" as to whether it should be C2 or C3. I was just pointing out that if your professional judgement says that C3 is reasonable, one way to stop it getting ignored for another 5 years would be to give a test interval of (say) 6 months.
But each situation needs to be taken on it's merits.

There is no need to 'stop it getting ignored' a C3 is a recommended improvement for safety, the customer may ignore the recommendation if they wish.

Setting a test interval of 6 months wouldn't achieve anything, you would just be recording the exact same C3 items on the next EICR.

 

[Grant1987]

As a landload, I've just started a new tenancy. It has been "fun" picking apart emails from the agent.
"You must get an electrical certificate" - nope, you already have one on file, and it's called an EICR.
"It must be done by a registered electrician" - nope.
"It applies to all tenancies" - nope, only new ones until next July
"It must be done every 5 years" - well, sort of
So 5 factual errors in one shirt paragraph. And I did point out that before they go advising others, they really should get the facts right. I can't help thinking that the scams are behind some of the misinformation - they are well known for their carefully worded advice that's "not quite a lie" but definitely intended to misinform.

Thinking about that 28 days bit. If you felt that the situation was that it needs upgrading, but not that urgently, you could put some C3s down and give 6 months till next inspection. That means the landlord has to get another one done within 6 months - and is required to provide your EICR to whoever does it, who (if it isn't you) would then see all the C3s and put 2+2 together.
OK, there's nothing to stop them getting a drive by pass from a blind man - but then they could do that in the 28 days anyway.

If anything like the new builds I've seen, I would not be surprised to find all sorts of non-compliances. Mum was looking at one, had she gone agead I'd have taken great pleasure in calling in the scam and asking what they'd be doing about the fraudulent EIC and the people responsible.

I’m just wondering what was fraudulent in these new builds? I see a whole range of properties and the new builds are by far better in my opinion due to them all being up to date with current regs. The older properties are where the most issues are and that’s where our interpretation of the regs comes into debate on what categorises a C2 or C3. You said I shudn be carrying out EICRS yet you don’t know me or my work. I’m sure the properties I test and Certify are of higher safety standard than the ones you do as you come across as a dodgy landlord who counts his £££ every night.
No offence intended just the way your posts come across to me

 

[Simon47]

You said I shudn be carrying out EICRS yet you don’t know me or my work. I’m sure the properties I test and Certify are of higher safety standard than the ones you do as you come across as a dodgy landlord who counts his £££ every night.
No offence intended just the way your posts come across to me

Well I stated that on the basis of that one post, you did not appear to have the right attitude for doing EICRs. As you point out, and I acknowledged at the time, I can only go off what you write. Your post suggested that all non-compliances must be upgraded and that's the approach you would take with any EICR - which others here have suggested is rubbish (so it's not just a greedy money grabbing landlord's PoV )
As an aside, last year I spent a considerable amount on upgrading the smoke alarm beyond the required "one detector per habitable floor" - adding a non-mandatory heat & CO in the kitchen and a heat in the garage. And a while ago I upgraded both my properties to all RCBO before "RCDs for everything" was a requirement. So you can wind in your "penny pinching landlord" comments - either that or quote examples that support your viewpoint.

I’m just wondering what was fraudulent in these new builds? I see a whole range of properties and the new builds are by far better in my opinion due to them all being up to date with current regs.

That's simple. If you sign a certificate that says "this installation had been designed, installed, and tested, to comply with BS7671-whatever" then it is fraud if you know OR SHOULD REASONABLY KNOW that such statement is false. That is one half of the definition of fraud in the fraud act - making a statement that is, or you should reasonably know is, false.
The other half is that it should be for fiduciary gain (whether for yourself or for others), or to cause another a loss. In the case of the electrical contractor signing off on a new build, the gain is getting paid for it.
And yes, the deviations from BS7671 are such that no competent electrician could be ignorant of the applicable regs. Unless you would suggest that an electrician not familiar with 522.6.202 can be considered competent to design and install a system ?
I would suggest that apart from having been done to different versions, many newbuilds these days are of significantly lower workmanship than you would find a few decades ago. Obviously that's an "on average" thing - there will be some new ones done well, and some older ones done poorly, but overall I'd say standards of workmanship have fallen steadily over the years. I think we all know why - the dive for the bottom of the swamp in pricing and the resultant penny pinching that goes with it. As an example, do you think it is "good workmanship" to make no practical provision for electric cooking during the install ? On the plumbing side, you'll generally see all plastic piping with push-fit connections - and I bet all the sharp edges are deburred in line with manufacturer's instructions before forcing them past the rubber seals that I'm sure we all agree will last longer than a well soldered copper joint

Setting a test interval of 6 months wouldn't achieve anything, you would just be recording the exact same C3 items on the next EICR.

That was in response to a comment that 28 days will put many landlords into a situation of being hostage to "whoever is available at the time" regardless of cost or quality of work. By agreement with the landlord, you might choose to code something marginal (picking something topical, lack of RCD protection) as C3 and set a retest date of 6 months hence - thus giving him the time to get it done by his preferred contractor (might be you) who might not have been able to fit it in at short notice, while not permitting it to be kicked down the road for 5 years. Lets say it's a case of fitting a new CU - doing a new EICR at the same time as the EIC for the new CU is barely any extra work.
I'm not suggesting that this changes the level of danger - it's merely a pragmatic approach one might take.
As an analogy, MoT tests for cars involve a lot of "professional opinion". Any car of MoT age, even some brand new ones, will have some corrosion - it's down to the tester's opinion as to whether that is bad enough for a fail, not so bad as causing a fail, but something that needs fixing, or not significant and he might mention it to the vehicle owner without it going on the test records. I have a good rapport with my tester, and he knows that I take an interest in my vehicles - you have to when you've a 30+ year old Land Rover.
Were he testing a vehicle for an owner that treats an MoT as an alternative to proper maintenance, you know the type, the "fix anything it fails on but otherwise don't do any maintenance" - then he's probably going to be someone stricter than with someone who treats it as an opportunity to see underneath and tap the experience of the tester. Because we have a history of him pointing things out (such as "that's getting a bit scabby, but it's OK for now") and seeing a new (e.g. bulkhead outrigger) next time it comes in, he generally errs on the side of advisories rather than fails (where it's open to him) because he knows it'll get fixed. With other owners, he knows that it'll get ignored until a week or two before the next MoT and he'll err towards a fail where appropriate. On one occasion, he tapped the bulkhead outrigger (opposite side to the one already mentioned) and said something to the effect of "it's getting a bit thin, don't make a hole in it or I'll have to fail it". it was still structurally sound, just not as strong as when first made - but it got a new one, and not "just before the next MoT.
Lest you be thinking, ah, thats' something you should have been able to see for yourself - some of the issues, probably yes. But it's a lot easier spotting them with the convenience of a lift, and it's a lot easier with the benefit of many years of spotting problems that the owner of a single vehicle might never have come across. Did you know that Land Rover 90/110 models (it's not a Defender !) are prone to corrosion of a particular nut on a particular brake pipe ? No, neither did I - but sure enough it had crept in (that was a fail BTW).
The other thing is that he's in the sort of location where he gets a lot of Land Rovers of all ages. Some places will see very few (Land Rovers and/or older vehicles), and so have a tendency to pick faults with things that are normal - but not what they are used to seeing.

So, what I am suggesting is that the level of risk of any particular fault or non-compliance with the current regs depends to a certain extent on the attitude of the owner/occupier/landlord. Your job when doing an EICR is to assess the level of risk and decide whether that warrants a C1, a C2, a C3, or just a comment to the client. As you seem to have done plenty of EICRs, I'm sure you'll agree that with some occupiers you could tell them something like "X is a bit questionable, I'd recommend you don't use it until it's been sorted" and be confident that a) they'll get it sorted and b) they'll be sensible and not use it till it is. Equally, I'm sure you'll have dealt with some occupiers where you can turn something off, stick warning labels on it, tell the occupier it's really dangerous - and be sure that before you've got everything stowed back in the van it'll be turned back on and in use.
Can you tell me that there is not a single occasion when you'd code something as (say) C3 for one and C2 for the other ?