MCS Quality Management System

[Treadwarm]

Isn't that scenario exactly what we have done to achieve MCS? We've been there done that. Consider what we went through on our first port of call to a potential customer. If it wasn't for us taking what is a huge financial gamble, and trust me I don't run a multi million pound company, as a two man band we wouldn't be where we are today. Our financial outlay is as simple as make or break. The saying speculate to accumulate has never been truer here.

No matter what the purpose of MCS it is seen as a level of competence which also includes installation. If it didn't why inspect an installation on assessment? In my opinion there's no difference in MCS, to Part P, to being NICEIC or alike. Consider if we allowed someone else to use one of our rewires to achieve Part P. I think it would be considered as fraud in my opinion and possible life threatening! You can not confirm the third party is fully aware of all the requirements unless you can witness and inspect what has been done. I kow alot of people who have reams of paper and certificates to show what they are qualified in but when it comes to putting it into practice their as much good as ----- on a fish!! No matter what the advantage the assessed company can not provide evidence of a correct installation so the scenario is with the first customer no different. "Have you actually installed a system?" NO!

The other consideration to the "if they don't have the funds to install to their own property" is it would also be unlikely to have the funds to finance the first commercial installation also. Not many PV suppliers I know of offer credit to newly established installers.

I know the actual installation process isn't taxing but neither is it a job anyone can do. There is a high element of competence required in several fields and trust me when I say I've seen the good the bad and the ugly! By approving companies who have never installed this will increase and like a lot of schemes MCS will lose its importance as it has in other industries.

As a MCS accredited company I find the circumstances allowing people to achieve MCS without even taking any tools off the van totally outrageous. Using sub contracted labour is not the issue. I think this debate will run and run until such time either MCS stands back and agree the system requires improvement or the entire scheme ends up in the scrap bin. The only end result being a lot of companies who have invested in the industry being left out of pocket.

One final question. On one of these "borrowed" installations used for inspection, was the MCS assessor fully aware of the fact that the installation was not conducted by the assessed company and that the system is in no way prove of their ability to conduct an installation?

I have never been asked during an inspection did you actually fit this installation. and I do not know of a way they could check other than watching me fit it.

 

[Treadwarm]

Either the MCS website and most of it's documentation needs rewriting or there's something wrong here.

I don't agree that just anyone can fit a PV system. It's a dangerous job - both to customer AND installer. You don't just compromise on things like this just because someone can't afford to prove they can do the work.

I don't think anybody has said that just anybody can fit a PV system when connecting into the grid, This is proven by having to carry the necessary certification from NIC EIC for electrical competence (without this you wont get MCS).

But you CAN and this is 100% gain MCS by using a sub contractor who carries the NIC EIC certification for electrical competence as long as you have been on a PV training course (3days / £300).

I think they need to decide if the MCS scheme is a paperwork / design certification with similar controls to ISO9001 or it is an installation standard and if so the installation inspection needs to be in a controlled environment.

My opinion is that MCS should cover both the documentation and installation, so a working a QMS to ISO9001 standard with specific reference to the practical installation of your chosen technology. This should be backed up by an in house installation service that is trained and assessed in a similar fashion to current electrical or plumbing assessments on a rig in a training facility with faults for the installers to spot and rectify.

What are your thoughts on this???

 

[SolarCity]

I think the MCS should run just like the NICEIC - or at least like the NICEIC should be. Wearing the logo should be a badge of quality, not just a receipt for £400 which is what it is now.

 

[Markc]

I have never been asked during an inspection did you actually fit this installation. and I do not know of a way they could check other than watching me fit it.

So I can also take it that the information was not volunteered to the inspector either? I think possibly the only way to get this to bed will be to ask the MCS direct: "Can an existing installation that has been installed by another contractor be used for my assessment?"

 

[Markc]

I completely agree that using someone else's installation is morally wrong but it is a possibility that people will be forced into especially as the requirement to take a punt on someone who is not MCS accredited becomes less and less. I would much prefer the steering group behind MCS to introduce a UKAS accredited testing facility based solely on the installation with manufactured fault to rectify and on site common issue that will occur from time to time (replacing tiles etc) to ensure competency

All accredited Certification Bodies will have been accredited by UKAS under EN45011 to undertake certification assessments under the MCS - So taken this on board it has to up to the certification body, NIC, Napit etc to confirm compliance. I can only state NICEIC rules on this as that's our certification body but I would expect all bodies to be working off the same sheet:


1.16 Installation Company means an organisation that is responsible for all of the following
activities: supply, design or design review, installation set to work and commissioning
microgeneration systems and technologies.
1.17 Installation Work means the design, construction, inspection, testing and/or maintenance of work
falling within the scope of MCS 001


4.1 NICEIC will certify an enterprise if all of the following requirements are met .

The applicant enterprise:
a) is an installation company
b) can demonstrate a minimum of two installations within the appropriate technology being applied for. The standard of work shall be not less than that affording conformity with MCS 001, and appropriate British Standard and other Industry Codes of Practice


6.2 Inspections will cover both quality management systems and completed installations unless agreed in advance with NICEIC to inspect an incomplete installation

 

[SolarCity]

So I can also take it that the information was not volunteered to the inspector either? I think possibly the only way to get this to bed will be to ask the MCS direct: "Can an existing installation that has been installed by another contractor be used for my assessment?"

And if the answer to that question is "Yes", then it has to be one of the most ridiculous 'assessments' possible.

 

[Treadwarm]

I am a little concerned that you guysthink that I am saying you are allowed to use someone else's installation. I am 100% that if you told a certification body that someone else has done your installation and you are just using it to get a pass they would fail you.

My problem is that at no point during the three assesmentd I have had and friends of mine have had, have we been asked to prove we did the installation.

 

[Markc]

You don't have to actually do an installation yourself, if you know of someone who has done an installation you could use this as an example to show the assesor. You build your project pack and hand over pack around this installation as if you have completed it from initial enquiry to calcs to commissioning. The assesor will be able to see that you understand the installation process and audit you in 12 months to ensure you are doing it correctly.

Sorry Treadwarm you have said exactly that. "you don't actually have to do an installation yourself" If I now speak out of line well so be it, but what YOU are doing is fraud! You are miss representing companies to achieve MCS without going through the procedures to ensure ability. You must see how this looks!

My problem is that at no point during the three assesmentd I have had and friends of mine have had, have we been asked to prove we did the installation.

You should not be expected to prove the installation is one of your own! It is assumed under the rules of enrolment prescribe by the certifying body. You sign a declaration on assessment to confirm this!

That's like saying if you don't ask I don't tell! You have promoted on an open forum the use of fraudulent tactics to achieve an accreditation that we all on here have worked bl**dy hard for and at extreme cost to us! Quite frankly I absolutely disgusted and angry about what you have posted. Mr Joe Public reads these posts here, Joe public that may well have an interest in having a renewable installed. How does this type of posting stating we achieve MCS by fraudulently representing someone else work help?

What your first post should of said is "you don't have to have conducted an installation if you can use someone else's and keep the fact secret so as not to achieve a major non compliance, "Mum's the word!""

And if this gets taken off due to content, so be it!

 

[Treadwarm]

Mark I have simple highlighted a situation that is becoming more and more common in gaining MCS. I care enough about this issue to raise it on forums like this and discuss it with CB's to highlight an issue that could fource installers into doing this fraudulant yet increasingly common action.

Am I so wrong for raising the issue and discussing it to make more people aware or should I carry on like others and say well if you can't get your first installation tough "this is business" in your words.

I have had to publicise this loop hole as more and more installers are using it and if we stick together we could get the mcs to see it.

Once again I appreciate your points but with due respect you can't point the finger at me for raising thid issue if the mcs has not picked up on this to put a stop to it. And I would be interested to know if you are thinking of writing to your CD or do you think you have done enough by complaining to me for raising it ???

This may be the reason why other certification is such a joke if people think when they have it sod everybody else rather than working at it to
improve the standard(s)

 

[TedM]

Treadwarm, if you are as concerned as you say to close this 'loophole' then I suggest you respond to the current DECC consultation on microgeneration - Microgeneration Strategy consultation - Department of Energy and Climate Change - which covers MCS and quality issues. List in as much detail as possible all the loopholes that you have seen that allow MCS accreditation to be obtained in the manner you have described.

I presume you have also raised this directly with the various MCS steering committees? What was their reply?

 

[Markc]

I can't gather if you're promoting the use of such tactics to gain MCS or highlighting them as a way of raising awareness of the loop hole?

Reading your earlier posts you state it's unfair to discriminate potential installers due to them not being able to afford the first installation or not being able to install due to age or alike yet now it's you are in contact with the CB's to raise awareness. The unfairness isn't down to the lack of funds, age or ability. As we all agree correct documented sub contracting is permitted and as an industry is promoting jobs and that is NOT in question. But the first installation to be assessed MUST be installed by the company being assessed. If it can not be afforded well then sorry but yes "that's business!" To conduct your own installation in materials costs are down to £1000 - £1500. Still a lot of money but not in the same scale as what I paid early 2010. So is it now accepted by some that this cost is unfair?

Standards have and will continue to improve and as they do some will still endeavour to exploit loop holes, that's life and will never change. No matter how tight the procedures. No certification body can stand and witness the installation and it would be ridiculous to think they could. Hence the declaration.

You ask if I am happy to just point the finger at you or do something. There's no finger pointing at you other than what you have posted previously. You have raised and promoted this activity and by reading your own earlier post you will see how it reads. I stand by my posts and comments 100%. I do feel strongly enough about this to contact my CB and MCS but by reading the rules of enrolment I suspect I know what the response will be.

 

[Treadwarm]

I have raised my concerns to Corgi and will be doing the same with NIC in January I have spoke to a couple of people on the main steering group who are looking into reviewing the standards but I have not yet heard anything. I will put my points on the DECC site first thing tomorrow. Thanks for the advice.

 

[Treadwarm]

Mark I can confirm 100% that I do NOT condone the use of other installers work as your own, I simple informed the guy who asked the question that this is a route more and more people are using, I did not say I recommend it but to be fair I did not say I do not recommend it so fair point.

I will let you know how I get on raising this issue with the steering group and CB's

 

[Markc]

I have raised my concerns with MCS, DECC and NICEIC tonight. I will post responses once or if received.

 

[MorganPVI]

Not surprised, but thanks for making your link to the mcs company clear Treadwarm.

I'd hope the MCS assessor was able to pick up on the papertrail of the assement system, if it's someone elses work i'd hope he/she were compentent enough to pick up the signs and investigate more and ask some pointed questions.