EICR issue. Need advice

[Concernednewbielandlord]

Hi, I'm new to being a Landlord (wasn't my plan!) Anyway I contacted a company online who arrange for electricians from around the country to perform EICR reports. The property is a small studio flat, 10 years old. (The electrician stated approx 20 yrs old on the report.) The report came back 'unsatisfactory' due to a couple of issues:
1. 6.6 Suitability of equipment for external influences for installed location in terms of IP rating. (701.512.2)
2. Need to change all spotlights (20 of them)
These were both marked as Further Investigation Required.
Yesterday I received a quote to replace all 20 downlights from the electrician via the company who have been handling the certification. I phoned the company who arranged the electrician questioning the report as I had no idea what my next step was re Further Investigation Req, They came back to me stating that the electrician had got it wrong and the two issues should have been marked as C2's and stated that the whole building had the same IP rating problem.
I'm not sure where to go from here. The flat is 10 years old and was built by Berkeley Homes. I'm assuming the IP ratings must have changed since the lights were installed?
Excuses if I'm sounding a bit naïve but I am new to this and a female (say no more!!)
I'd really appreciate some advice. Thanks

 

[DPG]

Can you post the report on here, but with names and addresses redacted.

The downlighter issue may be to do with them not being fire rated (bearing in mind it's a flat), but better if we can see the details.

 

[ChipFanDave]

Excuses if I'm sounding a bit naïve but I am new to this and a female (say no more!!)

Please don't say this, it's irrelevant naïve males and females who are not electricians, tradesmen or technically knowledgeable in this area are constantly being taken for a ride or ignoring good advice in equal measure. As DPG said post up the report and if possible the original electrical installation certificate if you have it. Please remove any personal information.

 

[Concernednewbielandlord]

Can you post the report on here, but with names and addresses redacted.

The downlighter issue may be to do with them not being fire rated (bearing in mind it's a flat), but better if we can see the details.

Thanks so much for your prompt response, the document is a pdf and can't be altered but I can sort it out another way. I'll do it this evening.

 

[Concernednewbielandlord]

Please don't say this, it's irrelevant naïve males and females who are not electricians, tradesmen or technically knowledgeable in this area are constantly being taken for a ride or ignoring good advice in equal measure. As DPG said post up the report and if possible the original electrical installation certificate if you have it. Please remove any personal information.

Thank you David. I've responded to DPG with the following, so I will post later on.....

Thanks so much for your prompt response, the document is a pdf and can't be altered but I can sort it out another way. I'll do it this evening.

 

[Concernednewbielandlord]

Hi guys, here is the report minus personal details. As I mentioned the electrician stated today that he made a mistake and the two issues stated as FI's should be C2's.Thanks

 

[pc1966]

Hi guys, here is the report minus personal details. As I mentioned the electrician stated today that he made a mistake and the two issues stated as FI's should be C2's.Thanks

Thanks for posting the redacted report.

I think you should ask them specifically what the reasons for the C2 rating are.

The C3 (not a reason to fail) on regulation 512.2 on environment is a general section about environmental suitability. It is hard to see how all the downlights would need changed under that regulation. There are more important ones on fire protection, but that is not the rule cited there.

The 'FI' for regulation 701.512.2 is the same idea but explicitly for bathrooms. As it seems unlikely you have anything in "zone 0" (basically in the bath) it means less than 1mm access to any electrical fittings within zones 1 or 2 (which is around 1m from any shower/bath - a search will pull up diagrams showing the zones in more detail).

It is sounding a bit dodgy to me, so I would ask them by email or similar (so you have a written explanation) of the specific issues and why they fail the regulations.

If you want some information on the whole EICR coding process, there is a free Best Practice Guide #4 from here:

https://www.----------------------------/professional-resources/best-practice-guides/

 

[littlespark]

My thoughts.

IP ratings are for protection against dust and water basically… nothing to do with fire… that’s a different regulation.
If the building has fire breaks between floors, ie concrete floors rather than then fire protected downlights aren’t needed as fire can’t spread.
It may be IP rating of downlights in a bathroom.

They haven’t ticked the boxes for operation of rcd test button.


Looks like an exercise on generating unnecessary work.

 

[pc1966]

Just to add - you do not have to use the same company who did the EICR to rectify anything.

If you have a trusted contractor then it is the simplest and easiest for them to do both, but all you need is evidence that any "unsatisfactory" issues have been resolved that can be appended to the original report. So if you don't feel happy about them you can get another sparky in to check/fix issues.

 

[Concernednewbielandlord]

Thanks for posting the redacted report.

I think you should ask them specifically what the reasons for the C2 rating are.

The C3 (not a reason to fail) on regulation 512.2 on environment is a general section about environmental suitability. It is hard to see how all the downlights would need changed under that regulation. There are more important ones on fire protection, but that is not the rule cited there.

The 'FI' for regulation 701.512.2 is the same idea but explicitly for bathrooms. As it seems unlikely you have anything in "zone 0" (basically in the bath) it means less than 1mm access to any electrical fittings within zones 1 or 2 (which is around 1m from any shower/bath - a search will pull up diagrams showing the zones in more detail).

It is sounding a bit dodgy to me, so I would ask them by email or similar (so you have a written explanation) of the specific issues and why they fail the regulations.

If you want some information on the whole EICR coding process, there is a free Best Practice Guide #4 from here:

https://www.----------------------------/professional-resources/best-practice-guides/

Thanks so much, I really appreciate you taking the time to help me out. I have taken your advice and sent an email requesting the specific issues and why they fail the regulations as you suggested. I'll let you know the response!

 

[Concernednewbielandlord]

My thoughts.

IP ratings are for protection against dust and water basically… nothing to do with fire… that’s a different regulation.
If the building has fire breaks between floors, ie concrete floors rather than then fire protected downlights aren’t needed as fire can’t spread.
It may be IP rating of downlights in a bathroom.

They haven’t ticked the boxes for operation of rcd test button.


Looks like an exercise on generating unnecessary work.

Thank you so much for your response, you're so kind. I agree with your last comment. I have sent an email requesting the specific issues and reasons for the fail as suggested by pc1966. We shall see!

 

[UNG]

I often wonder why the people producing these EICR's never proof read them before releasing them to the customer
The date of last inspection appears to be the same as this inspection
The earthing conductor is 16mm² yet the main supply conductor is 10mm²
According to the inspection schedule there is a mixed colour label on the consumer unit when the installation is 10 years old so is post the colour change

Then you get
"Electrical wiring is in unsatisfactory condition" and "Need to change all spotlights"
A little more explanation and a reason why might be a useful addition

The inspection schedule has a lot of ticks where there should be N/A's no details on the earth rod in section J but apparently it is present and good condition and then in the schedule of tests it is an N/A, I'm assuming there is no solar PV or other generation yet it is ticked

Yet another questionable EICR IMO that lacks some attention to detail on the part of the electrician carryiny out the inspection

 

[nicebutdim]

Given that they've already admitted the report contained errors, I'd be questioning precisely why they might expect payment.

 

[Dartlec]

I often wonder why the people producing these EICR's never proof read them before releasing them to the customer
The date of last inspection appears to be the same as this inspection
The earthing conductor is 16mm² yet the main supply conductor is 10mm²
According to the inspection schedule there is a mixed colour label on the consumer unit when the installation is 10 years old so is post the colour change

Then you get
"Electrical wiring is in unsatisfactory condition" and "Need to change all spotlights"
A little more explanation and a reason why might be a useful addition

The inspection schedule has a lot of ticks where there should be N/A's no details on the earth rod in section J but apparently it is present and good condition and then in the schedule of tests it is an N/A, I'm assuming there is no solar PV or other generation yet it is ticked

Yet another questionable EICR IMO that lacks some attention to detail on the part of the electrician carryiny out the inspection

Completely agree about the proof reading - I am very careful now to read mine. And I can't remember the last time I saw someone elses without at least one error, even if minor.

Some of the software doesn't help by incorrectly pre-ticking things, but that is why I always create the pdf and scan through it.

I feel that the courses covering inspection and testing could spend a LOT longer on how to complete the form, which after all is meant to be a legal document with some significant weight - and in a court of law even minor errors are going to look very bad indeed.

 

[Dartlec]

Silly errors aside, a couple of thoughts on the observations, which are what matter for the OP in terms of getting a satisfactory report.

As already mentioned, item 6.6 only applies to locations containing a bath or shower. My guess is that the downlights in there may well not be IP rated, as many new builds 10 years ago didn't seem to bother.

However, often they are (just) outside of zone 2 (2.25m height) so technically do not have a required IP rating. That may be a stupid rule, but it's what the regs state.

Interesting that they have noted the 'issue' on 6.6, not 6.7, which suggests maybe they are using their 'judgement' on suitability. However, unless they are clearly corroded, or showing signs of damage, then I'd question that.

I'd be interested in NAPIT's view on whether 'need to change all spotlights' is a suitable observation on a professional report. IMO it is anything but. The issue (if any) should be explained - how to solve it is then discussed separately.

Item 3 seems to be listed separately from any of the schedules, and has no reference to a suitable reg, so it is impossible to tell WHY they claim they all need changing.

It's also very clear that an FI was inappropriate - if they knew they needed replacing, then no Further Inspection is required!

If they are claiming replacement is essential on the basis of fire rating, then if the flat is like most modern new build flats, the ceiling is not a fire barrier - the concrete structure is designed for that purpose.

That doesn't mean that fire rated downlights might not be a bad idea. And I would bet good money that the existing downlights will be poorly installed, with lots of exposed single insulated cables, but that's not the same as saying they MUST be replaced without giving a good reason based on the regulations.

It will be interesting to see what the response to the OP is.

I don't like the idea of a report being issued with FIs and then them being decided afterwards that they should be C2s - that smacks of someone in the office looking for remedial work. I would certainly be seeking quotes from elsewhere, and requesting a corrected reissue of the report that states C2.

 

[Rockingit]

More holes in that report than my socks, and also similar to my socks I smell a rat. A new 10yr old domestic that's TN-S and a copper water service - in a flat?? I especially like the testing of an AFDD as being satisfactory given that there won't be any from ten years ago!!

I would a) not pay for it and b) ask Napit to attend and verify the findings. It's the only way to stamp out this ridiculous nonsense of rogue inspections that is sweeping the land.

 

[Dartlec]

More holes in that report than my socks, and also similar to my socks I smell a rat. A new 10yr old domestic that's TN-S and a copper water service - in a flat?? I especially like the testing of an AFDD as being satisfactory given that there won't be any from ten years ago!!

I would a) not pay for it and b) ask Napit to attend and verify the findings. It's the only way to stamp out this ridiculous nonsense of rogue inspections that is sweeping the land.

tbf I have seen a relatively new build block with what appeared to be TN-S, but that was because there was a BNO involved.

In this case, with a Ze (or Zdb) of 0.12, that's clearly not the case though.

There may be copper pipes within the block to each flat, but even if the main incomer was not plastic, the bonding should be done for the block not each flat.

Wouldn't be surprised if the house builder just stuck bonding in every flat regardless then anyway, whether needed or not, because someone thought it was needed...

I have seen flats with 2 core SWA for the feed in 10mm, and then a separate 16mm earth, so that is just possible, if unusual...

Would be interesting to see the original EIC, but I wouldn't mind betting it doesn't exist any more and was never handed over with the flat...


Still leaves plenty of holes in the report though...

Couple more for the list:

the test schedule suggests this is fed from an 80A Type B 60898 MCB - Not sure if those even exist. Many flats I've seen have an isolator in a riser cupboard, but never seen higher than 63A.

Phase sequence is apparently confirmed....for a single phase system

The schedule says "associated RCD - N/A" - then gives test readings for it tripping - which are different from either of the actual ones on the dual RCD board.

Main switch BS 60947-3 apparently has a fuse rating of 80A (as well as a current rating) - Wylex do seem to make some interesting kit!

RCDs are apparently providing fault protection (SO many people get this one wrong on certs)

Finally, the chances of the inspector actually testing all L/N circuits at 500V and getting perfect (>200) readings unless the flat is completely empty with every appliance removed, are about as high as this country having a functioning electrical competency scheme in place any time soon!

But it's fine, because this report was done by a "Senior Electric Inspector"

 

[UNG]

It's surprising what you miss at times just looked through that EICR again and it's not valid as it recommends in section F a retest date of 9/4/2022

Beginning to think this has been done by someone with zero experience of inspection and test

 

[Concernednewbielandlord]

Hi guys, firstly I just want to thank you all so much for your help and taking time out to respond. I didn't know which way to go with this and you've helped enormously.
Thought I'd give you an update. As advised I contacted the company who had provided this electrician and asked for clarification of the issues in writing. They sent him an email marked urgent yesterday morning which I was copied in on and guess what, he hasn't responded and isn't answering his phone. I shall see what today brings!

 

[Rockingit]

It's surprising what you miss at times just looked through that EICR again and it's not valid as it recommends in section F a retest date of 9/4/2022

Beginning to think this has been done by someone with zero experience of inspection and test

You and Dartlec have both spotted what I couldn't be bothered to list (although I'd missed a few myself in a scan read), I think we can ALL agree that this is not an inspection to a suitable standard.

 

[LukeD]

You and Dartlec have both spotted what I couldn't be bothered to list (although I'd missed a few myself in a scan read), I think we can ALL agree that this is not an inspection to a suitable standard.

I should just copy and paste my answer ...Its always the same .The whole set up and Policing of these tests must have been done by someone with the brains of Diane Abbott .Its a total Joke .Today at a Trade showroom, someone was again saying he was making up to a grand a day filling them out and dropping them off . Not just one week.... probably made 80k with no real effort .

 

[UNG]

I should just copy and paste my answer ...Its always the same .The whole set up and Policing of these tests must have been done by someone with the brains of Diane Abbott .Its a total Joke .Today at a Trade showroom, someone was again saying he was making up to a grand a day filling them out and dropping them off . Not just one week.... probably made 80k with no real effort .

And which scam was he with ?.
It's people like that who put people potentially at risk because of their dodgy EICR's

 

[LukeD]

And which scam was he with ?.
It's people like that who put people potentially at risk because of their dodgy EICR's

I doubt he used his real details as it was all cash and he probably had a CV19 government loan etc !. Just cheap landlords wanting a ticket to keep things legal if the tenant ask about it etc

 

[JBW175]

Hi guys, here is the report minus personal details. As I mentioned the electrician stated today that he made a mistake and the two issues stated as FI's should be C2's.Thanks

The first 5 digits of the EICR serial number are the registered electricians operative number with NAPIT, you can check their credentials out on NAPIT website and see if that is the same engineer that carried out the EICR.

I’m sure others will correct me if I’m wrong, but I’m pretty sure that if you’re a company registered with NAPIT, then all your operators need to be registered too, and you can’t just sign off the cert on their behalf. Unlike with the NIC where you only need one QS for the company.

 

[Concernednewbielandlord]

Hi guys, I have an update. So the first electrician who failed the EICR never came back with my request to put the issues in writing. Surprise surprise!
I had someone else there today and has come back stating that only the two lights in the shower room need changing and that I definitely didn't require having all 20 lights in the flat changed as advised by the first guy who came. So, obviously I'm very happy about that and very glad I questioned the first report.
However I now need more advice as the electrician who conducted the check today has quoted 1-1.5hrs at £100 per hour plus cost of lights.
This seems a bit steep to me but I may be out of touch.
If it is steep and I get someone else to do the job would they amend the report from a fail to a pass. I'm not sure how this works.

 

[Rockingit]

Hi guys, I have an update. So the first electrician who failed the EICR never came back with my request to put the issues in writing. Surprise surprise!
I had someone else there today and has come back stating that only the two lights in the shower room need changing and that I definitely didn't require having all 20 lights in the flat changed as advised by the first guy who came. So, obviously I'm very happy about that and very glad I questioned the first report.
However I now need more advice as the electrician who conducted the check today has quoted 1-1.5hrs at £100 per hour plus cost of lights.
This seems a bit steep to me but I may be out of touch.
If it is steep and I get someone else to do the job would they amend the report from a fail to a pass. I'm not sure how this works.

I’d quit whilst ahead if I were you….

 

[Concernednewbielandlord]

I wish I could!
This has been a real saga!

 

[Dartlec]

Hi guys, I have an update. So the first electrician who failed the EICR never came back with my request to put the issues in writing. Surprise surprise!
I had someone else there today and has come back stating that only the two lights in the shower room need changing and that I definitely didn't require having all 20 lights in the flat changed as advised by the first guy who came. So, obviously I'm very happy about that and very glad I questioned the first report.
However I now need more advice as the electrician who conducted the check today has quoted 1-1.5hrs at £100 per hour plus cost of lights.
This seems a bit steep to me but I may be out of touch.
If it is steep and I get someone else to do the job would they amend the report from a fail to a pass. I'm not sure how this works.

£100 an hour to change shower lights does sound steep to me, outside of Central London maybe.

A lot of it is dependent on area and workload of course though - and a lot of firms will find a small job less convenient than a larger job, since it makes scheduling work harder. Whether they are VAT registered may also have an impact of course.

In terms of the report, no-one apart from the original contractor can 'amend the report from a fail to a pass'

However, that isn't what is needed by the legislation (though it's what many estate agents and letting agencies seem to think)

A report that is "unsatisfactory" merely means that there is remedial work that must be completed (specified in the legislation as within 30 days, though with no real basis for that other than picking a number).

As the landlord, you must show that the remedial work has been completed. How is not specified, though invoices/written documentation is the easiest method. (in theory there is nothing stopping a single hand written sheet of paper saying 'all remedial works are complete' from being appended - although of course that looks less than professional and would be easily open to question from anyone in future)

The combination of the original document plus the evidence of remedial work, is your proof that the electrical installation is as required in the regulations.

There is then no further need for a retest until the next 5 year period. There is no requirement to obtain a new report that states 'satisfactory' on the front.

The issue with this is that many people know only to look for the 'satisfactory' box on the certificate and never look any further.

The wrinkle comes where the remedial works are not clearly specified, or indeed are questionable as in your case.

The ideal outcome would be to have a new report done by someone who knows what they are doing - after the lights have been done, so you get a nice simple 'satisfactory'.

One of the issues with the legislation is that the legal responsibility falls upon the Landlord to carry out suitable testing.

If there was an incident and the report you have was investigated by any expert body, I think there are enough issues with it to raise serious questions about its validity as a representation of your installation.

That should not be your issue of course, since you used a supposedly competent person. And it's likely that none of the errors within the report are themselves 'dangerous' in terms of missing red flags that should have been picked up. But it may be something to consider.

An alternative that I think would be acceptable under the regulations, would be for another competent electrician to carry out the required changes (lights in shower) and then issue documentation that states that all necessary remedial work has been carried out. Whether you can find one willing to do that without themselves carrying out further testing is another matter.

Apologies that there is not a 'neater' solution in this case.

IMO the best outcome would be that you pay nothing for the first report and obtain a better quality report from someone who can proofread and knows how to fill in certificates.

 

[Concernednewbielandlord]

£100 an hour to change shower lights does sound steep to me, outside of Central London maybe.

A lot of it is dependent on area and workload of course though - and a lot of firms will find a small job less convenient than a larger job, since it makes scheduling work harder. Whether they are VAT registered may also have an impact of course.

In terms of the report, no-one apart from the original contractor can 'amend the report from a fail to a pass'

However, that isn't what is needed by the legislation (though it's what many estate agents and letting agencies seem to think)

A report that is "unsatisfactory" merely means that there is remedial work that must be completed (specified in the legislation as within 30 days, though with no real basis for that other than picking a number).

As the landlord, you must show that the remedial work has been completed. How is not specified, though invoices/written documentation is the easiest method. (in theory there is nothing stopping a single hand written sheet of paper saying 'all remedial works are complete' from being appended - although of course that looks less than professional and would be easily open to question from anyone in future)

The combination of the original document plus the evidence of remedial work, is your proof that the electrical installation is as required in the regulations.

There is then no further need for a retest until the next 5 year period. There is no requirement to obtain a new report that states 'satisfactory' on the front.

The issue with this is that many people know only to look for the 'satisfactory' box on the certificate and never look any further.

The wrinkle comes where the remedial works are not clearly specified, or indeed are questionable as in your case.

The ideal outcome would be to have a new report done by someone who knows what they are doing - after the lights have been done, so you get a nice simple 'satisfactory'.

One of the issues with the legislation is that the legal responsibility falls upon the Landlord to carry out suitable testing.

If there was an incident and the report you have was investigated by any expert body, I think there are enough issues with it to raise serious questions about its validity as a representation of your installation.

That should not be your issue of course, since you used a supposedly competent person. And it's likely that none of the errors within the report are themselves 'dangerous' in terms of missing red flags that should have been picked up. But it may be something to consider.

An alternative that I think would be acceptable under the regulations, would be for another competent electrician to carry out the required changes (lights in shower) and then issue documentation that states that all necessary remedial work has been carried out. Whether you can find one willing to do that without themselves carrying out further testing is another matter.

Apologies that there is not a 'neater' solution in this case.

IMO the best outcome would be that you pay nothing for the first report and obtain a better quality report from someone who can proofread and knows how to fill in certificates.

Hi, thank you so much for your very comprehensive response, I really appreciate your time and effort in helping me out with sound advice. I have decided to go with the quote I was given. He is going to produce the report after doing the job and therefore I will get a satisfactory report. Hopefully that will be the end of this saga!
Thanks again, I wish you all the very best and carry on the great work!

 

[Concernednewbielandlord]

I have just responded to Dartlec but I'd like to thank all of you for your help. It's been a steep learning curve and I honestly don't know how I would have navigated it all without your input. It's comforting to know there are good and honest people out there when you come up against such an immoral person who for sure is using this tactic to swindle others.
This probably will not shock you but this guy is on the NAPIT site as a recommended electrician. I didn't know that until I started doubting his report and looked him up. Makes me wonder how they screen people.
Anyway, you have all restored my faith!!
Thank you.