NAPIT demanding we reconcile all our MCS certs with building regs notifications back to 2010

[Gavin A]

Has anyone else had this demand?

NAPIT are now attempting to insist that we need to go through our records of hundreds of installs since 2010 and fully account for a 15% discrepency between the number of MCS certs issued and the number of building regulations notified via NAPIT.

The vast majority being for pre 2013, which from my memory was the date at which NAPIT changed their system to give a specific category for solar PV / thermal. Could anyone else confirm this please?

From 2010-13 we notified for single circuit as that was what we were told to do, and the only suitable option, NAPIT now seem to be insisting that we should go back and notify them all as also being solar PV - though they've amended this to being back to sept 2011 when they say it became a requirement, I'm sure NAPIT didn't have the option on the portal, and that I queried it, and that we never received any instructions from them to do it etc. (I have our emails from that period and there's nothing).

We do a lot of new builds which we don't notify as we don't do the electrical work and it's getting building control sign off, and back in the early days we were doing 1 MCS cert per inverter as I'm sure we used to have to add the inverter serial number on the cert, so multi-roof installs would have 2-3 MCS certs.

I explained all this but they're still attempting to insist on it, though I'm pushing the ball back into their court to provide evidence of any systems that we've done wrong that were our fault that they've been done wrong.

I can see where the idea for doing this came from, it must have seemed quite simple in the MCS meeting discussing it, but the reality is very different.

ANyone else had this at all?

 

[whinmoor]

Did you have your inspection recently? Was this picked up as a NC?

 

[Gavin A]

yes, had it on Monday. It seems to have been, I'm not entirely sure on what basis they're demanding that we do it, but they basically asked to know the number of MCS certs issued then tried to match that with the number of Building Regs notifications and wanted us to explain the difference.

That was fair enough, but we've given a reasonable explanation which they now want us to back up with a line by line analysis of every system to account for every single discrepency in full, which is completely unreasonable IMO being as most of them are down to their systems not being set up properly in the first place.

 

[Gavin A]

15 views, no other response except from Medoria, can I assume that this isn't something that everyone else has been expected to do at this years assessment?

 

[whinmoor]

Did you have a different inspector this time? Was it the dude I warned about in another posting? Did his first name and surname begin with the same letter?

I have a “Building Regulations Compliance Certificate from 2011 for my own system which says as the schedule of work: “Installed photovoltaics (PV modules) / House Dwelling”. This doesn’t mention the “single circuit”.

We had a problem with notifications a couple of years ago. It was raised as an NC at our annual inspection.

What happened was that when we did a regular domestic PV job, we’d notify as follows:

Work type – Microgeneration
Work – Install a photovoltaic system
Location – House Dwelling
Quantity – 1
Gr. Deal – False
Status – Notifiable to LA

The inspector wanted us to add a second line item saying:

Work type – Electrical
Work – Install one or more new circuits
Location – House Dwelling
Quantity – 1
Gr. Deal – False
Status – Notifiable to LA

This meant that we had to re-issue dozens of certificates (costing £s) with both line items. This cleared the NC.

When we had a commercial job, I asked NAPIT how to notify the second line item for electrical. There didn’t appear to be a suitable description for “Location”.

Then they changed their tune and said that it’s never necessary to add the “Install one or more new circuits” item as everything’s covered by the “Install a photovoltaic system” listing.

I asked for compensation for the expense of re-issuing loads of certificates unnecessarily and received a fair amount of notification credit which took months to burn through.

The person I dealt with at NAPIT was Nikki Wyatt – Customer Services Manager: 01623 812988.

 

[Gavin A]

interesting, thanks.

In terms of the 2011 change to the solar pv thing then it looks like they must have changed the portal at that point, but I've not got any email notification from them that this has been done and I have a dozen or so emails from them in the month they claim to have notified us so it's not like we've just deleted the emails or they've gone to spam.

 

[Worcester]

Hi Gavin, we had a very similar set of discussions with Napit!

Definitely got a Jobsworth this time (on a lot of points), our Assessor drove over 100 miles each way as it seems thay have cut back - Initials KM - he left such a good impression I can't even remember his name. We've now had 5 assessors in 7 years... and this one raised a bunch NC's when that last 2 years were clear, and all of those this time were open to interpretation (on one site PVSOL gave us a worse output due to better shading analysis and they insisted that the MCS method should have greater prominence).
Even had us considering swapping certifying body..

So much for "Randomly generated set of clauses to check" if they've done this to a number of us.

Same as yourself on new builds where we weren't signing anything off - however they (initially) insisted on and raised an NC / Advisory and wanted:
1) A Building Regs cert for every installation
2) Copies of Electrical certs for every installation (even when not our responsibility as per your scenario)

Eventually they accepted a statement to that fact it's not our responsibility.

Building Regulations Submissions
A large proportion of our work is new build, as such we provide a commissioning certificate to the main contractor and they gain Building Regulations sign off, the inspector usually only needs to see the MCS and Commissioning Certificates.
We also have corporate customers that handle all building regulations compliance and submissions themselves.
Furthermore a number of installations have multiple MCS certificates, as previously you could not add more than one product to a certificate, as such there will always be a discrepancy between the MCS registrations and Building regulations certificates issued
As such a large proportion of our work is not, and will not be notified to Building Control through the Napit database.
​

We refused them the Electrical certs (they wanted us to get copies from the main contractor !!!!)

Also when we do other notifiable electrical work that goes through NICIEIC so that kind of stuffed them...

Our contract database includes all details like MPAN, Building Regs Submission Number, Electrical Cert # etc and we did find a couple that we had actually overlooked, so we did retrospectively register those.

Was this really an MCS compliance against MCS_001 or a way for NAPIT to try to raise cash?

APPENDIX A
12. Control of work in progress
"In completing the handover, the MCS Contractor shall confirm that all notifiable work under the Building Regulations has been conducted as agreed in the contract (see Clause 8)."
8. Contracts and customer requirements
says "Responsibility for planning and building control compliance is clearly identified."​

 

[Gavin A]

Thanks for that, I went back initially with something fairly similar to that but they seemed quite insistent. going to return to the theme and point out that they never emailed the guidance to us, and that the guidance itself was written in a future tense so doesn't indicate that it was actually set up at the time, and it makes no mention of commercial or new build having to be notified, so even if we had received it I wouldn't really have been any the wiser.

Sod going back through hundreds of customer folders manually to attempt to work out which ones didn't get notified and if there were legit reasons for it or not, I'm pretty sure we'll have done 99% of them to the standard we were aware needed doing, other than a few recently where we'd slipped up due to change of staff.