EICR and RCD Protection

Discussion in 'Electricians' Talk' started by TheAllenFamily, Apr 5, 2021.

  1. MGW

    MGW Screwfix Select

    was a major change where bonding was relaxed if there was RCD protection, we see a lot of homes where the bonding has been lost but the RCD not added, this means a home which seems to be as it was in 2008 often is not as some plastic pipes has resulted in bonding being lost.

    So although BS7671 with every edition gives a design date after which any new installation needs to comply with it, so not retrospective, and a C2 code is potentially dangerous, not does not comply with any regulation, so if it complied in 1992 then it still complies today, so no requirement for RCD protection unless bonding has been removed.

    However I fitted RCD protection to my own house all circuits in around 1994, and had mothers house rewired in around 2016 so I could fit RCD protection, and this house RCD protection added within first 6 months of moving in.

    If you look at the Emma Shaw case there was a whole host of faults which caused her death, and at the time of her death RCD protection was not required on all circuits, and it was the electrical foreman who was blamed for using unskilled labour, however had RCD protection been used it would have stopped her death. The tenant does not really have the option of fitting RCD protection only the landlord can do that, I think a 28 day limit to get it done is unreasonable, and the landlord should be free to arrange when it is done to suit other things, including allowing tenants to run down any freezer stock, where to upgrade it requires a CU change, but even if not legally obliged, morally however they should be fitted.
  2. adgjl

    adgjl Member

    In my opinion, carrying out an EICR to a withdrawn version of BS7671 is pointless and a waste of money. The only standard that can apply to an EICR is the up-to-date version with the latest amendments. The idea is that you are commenting on its safety for continued use with what is known today, and coding it as such. The only time I have used an old version was to prove in court that the installation didn’t even comply wi the regs at the time of its construction.
  3. MGW

    MGW Screwfix Select

    I see the problem with working to an old version, however to reply to @adgjl since each one says something like "Installations designed after 30st June 2008 are to comply with BS 7671:2008." that of course also means installations designed before 30st June 2008 with comply with an earlier edition, so complying with that earlier edition means they in comply the the current edition.

    So if some thing was designed and note it is design date not completion date, in 1992 then it still only needs to comply with BS7671:1992 to in fact comply with BS7671:2018.

    However there may be a CENELEC harmonization document or a HSE document which are retrospective, so some items found in BS7671:2018 may need complying with even when not in BS7671:1992, hence the "does not necessarily mean that they are unsafe for continued use" as there may be some other document that says it is required now.

    However the EICR code 4 has been dropped, and we are only really interested in code C2, if code C1 then unlikely to be an argument, and code C3 informs but does not give a time limit, Code FI could be contested as code LIM is nearly the same, except one requires correction with 28 days the other does not, so a garage with landlords stuff inside and kept locked likely code LIM and a room locked by tenant likely code FI, but in the main we are looking at code C2.

    Code C2 is potentially dangerous and has no direct link to BS7671, we may use BS7671 to assist in deciding if some thing is potentially dangerous but it is not limited to BS7671, so if the installation instructions say
    and a type AC RCD is fitted then we can still issue a C2 even when it does not break one of the BS7671 regulations, what does seem daft however is it is unlikely anyone doing an EICR will have the packaging to be able to determine if type A or type B is required.

    The Worcester Bosch boiler installation instructions says "Type A RCDs Type A.jpg must be employed where additional protection is required." which would include most domestic premises, but again the warning is in the installation instructions and this means the inspector would need a copy of the installation instructions to know if that is required for the boiler fitted.

    which means the EICR to comply with new landlord law includes items which would have been in the past been covered by inspection and testing of in service electrical equipment, so boiler, immersion heater, built in kitchen items like hob, oven etc, now covered by the EICR, I think this is wrong, as in the past items like boilers would have been only tested by gas safe registered tradesmen, but unless clearly marked gas safe only to remove this cover, then the connections should be checked.

    Of course again code FI or LIM can be used, but if code FI is used then we come up against
    and looking at the installation methods used by tradesmen fitting central heating with no earth wires or earth colours green/yellow used for line wires, one has to raise the question is a gas safe guy qualified to issue an electrical installation certificate or minor works certificate? With my dad's central heating the plumbers put the boiler on a plug, and an electrician was then sent to swap this for a FCU, however he never issued an electrical minor works certificate, which clearly with wiring from the boiler through the ceiling space and down wall to a programmer there should have been a minor works certificate raised.

    The new law was not very well thought out, as it was common to have maintenance contracts, like washing machine, and central heating, so these items would not be done with either the EICR or the "PAT" testing and I suppose one could use the LIM code for items under a maintenance contract, however it is the paper trail that causes the problem, and getting all the documents together as a pack for the tenant.

    The Moving Finger writes; and, having writ, Moves on: nor all thy Piety nor Wit. Shall lure it back to cancel half a Line, Nor all thy Tears wash out a Word of it.” and this is a big problem, once an inspector issues a code C2, then some one needs to raise the minor works or other document to show the work has been done, and that person must be a qualified person, so a really simple job, shall we say fit a blank in a consumer unit, needs a minor works raising to show it has been fitted by a qualified person. One would hope an inspector would carry blanks and fit them during the inspection, and in many a consumer unit missing blanks would be a code C1 so the mains should remain off until fitted, but once written down, then need some paperwork to say corrected.
  4. MGW

    MGW Screwfix Select

    I would say above is theatrical, and in real terms much can't be done, even the governments own guide says "The Regulations do not cover electrical appliances, only the fixed electrical installations." however that is not what the law says.
  5. Alan sherriff

    Alan sherriff Active Member

    Zoning of cable runs are now a regulation so if to comply do all cables have to be installed in the zones to suit current regulations , but they were installed to the regs at the time so a rewire ? and if all circuits are rcd protected and the consumer unit is not non flammable or provision in flame proof box do we have to take out and install a metal consumer unit ?? In future there may be a regulation to install surge protection devices ,so then all fitted now have to be converted to accept or stand alone unit ,were does it end , even rewirble are classed as safe if all tests and verification are in order , I think then we all know they are old and tired and even customer would like circuit breakers at the minimum installed along with SUPPLEMENTRY protection ,I have just done eicr on 14 year old appartments with split boards and plastic pipe work and given a c3 for that it was just lights and door bell on non rcd side
  6. adgjl

    adgjl Member

    The quote from the introduction of BS7671 is actually

    “... 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.”

    If you carry out an inspection based on a withdrawn version of the standard and something goes wrong, you may need to defend your position in court and explain why you considered the added safety benefits that the latest edition suggests are not important.
    The Happy Builder likes this.
  7. rogerk101

    rogerk101 Screwfix Select

    No, you won't.
    You'll simply respond to the challenges in court by quoting your quote from the introduction of BS7671, “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.” That covers your ar8e completely.
    • As a spark with many years of experience, you should be able to take an educated guess at the age of the installation, and you probably remember what the regs were in that era.
    • As a spark fresh out of spark training, you would have learned roughly what was in the regs with each previous edition of the regs, and you would use your best judgement.
    If the above is not good enough, and the spark in question was deemed by the court to have been neglectful in carrying out his/her duties, then every spark in the country will ignore the quote from BS7671 and only ever issue C1s and C2s from then on. C3s will cease to exist, so will go the way of C4s. Every installation that is not up to the latest edition will obviously need changing for no other reason than to cover the spark's ar8e, so the quote will have to be removed from the introduction to BS7671.
  8. MGW

    MGW Screwfix Select

    and it continues has been the case for many years.

    And we have seen errors, "A cable concealed in a wall or partition" in 17th edition failed to say this was for low voltage, and it is clear with separated extra low voltage since separated the same protection will not work in all cases and the rules did not cover it, and a little common sense must be used, you don't require a RCD on the 8 volt feed to the door bell.

    And when you do an EICR you are not required since the removal of code 4 to say if it would comply with BS7671 if designed today. And with installations that take time to complete it is the design date that matters not the installation date, so if a design was made in 2007 and the building was not finished until 2009 the installation would still follow the requirements of BS7671:2001 not BS7671:2008 even when the installation certificate was not made out until 2009. Which is why on the installation certificate it states which version of BS7671 has been used.

    The big thing we look for is 1) change in bonding rules which means if new bonding rules are followed then also new rules on RCD protection also become valid. 2) Manufacturers recommendations. So if the manufacturer states
    that needs to be considered.

    It does not take much thought to see the problem, when doing a EICR one is hardly likely to still have the packaging for the Pod Point, the same goes for central heating boiler, the other big one is solar panels. We have had problems with stored energy producing an injected current into the supply for years, the one I remember was a crane dropping its load on the building of T5, where the ward leonard system was affected by a faulty inverter, be it a motor on over run, solar panels, or electric car charging DC injection into an AC system can cause some really odd effects including the making of RCDs less sensitive.

    When a major crane manufacturer failed to see the problem, as electricians all we can really do is follow manufacturers recommendations. So even if the shower looks identical to one it is replacing if it now says RCD protection is required we simply have to provide that RCD protection.

    So when doing a EICR we should be presented with a bunch of paperwork saying when the installation was designed, and also detailing all the work done on the installation since that date, including the installation instructions for shower, hob, boiler, etc. And we can wade through this paperwork and see if there is any requirement like this Worcester Power.jpg where Worcester Bosch have decided the boiler needs Type A RCD protection. And so if only Type AC is fitted then we have to make a decision as to if this is code C3 or code C2, and this is where the problem lies. It does not really matter if code C3 or code C2 we have highlighted the error, so as far as a court goes we have not missed the error, the question is who made the error?

    So if some heating and ventilation engineer has renewed a boiler without also renewing the RCD and upgrading to type A, then clearly he needs recalling to correct his error, where it becomes more of a problem is when some thing supplied by a plug requires RCD protection.

    However as far as the EICR goes, if the lack or wrong RCD has been documented with either a Code C3 or C2 he has done his job, the question is not if he should highlight lack or wrong RCD, the question is should be be a C3 or C2 code, and if the RCD is additional protection then can't see how it can be coded C2, only if it is main protection as with a TT supply or where bonding has been removed can it really be a C2.
  9. Comlec

    Comlec Screwfix Select

    Are you serious??
    Most of the time you are lucky if the consumer unit has the circuits labelled.
    The Happy Builder and rogerk101 like this.
  10. rogerk101

    rogerk101 Screwfix Select

    Regardless of what edition was in force at the time of the installation, responsible (ethical) landlords should 'do the right thing' and install RCDs where they are lacking today.
    Unfortunately the only way to get most of them to do that is to issue a C2. If you just issue a C3, then the majority of them will ignore it, whether because they're tight with their money or because they don't understand enough about the additional safety that RCDs provide.
    In my recent EICR, 11 C2s were eliminated completely by changing my CU to a metal one with SPD and 10 RCBOs. I now sleep very well at night. :D
  11. Mr Rusty

    Mr Rusty Screwfix Select

    @MGW where are you seeing this information on WB boilers? I have downloaded the installation instructions from WB website for the common combi's and am not seeing this? Interested for my own installation which definitely has type AC RCDs and a WB boiler! Plus every light in the house is LED. Brand new installation (2 years ago) by pro sparks.
  12. Comlec

    Comlec Screwfix Select

    I must have missed the Addendum to BS7671 that asked an inspector conducting an EICR to consider the future actions, financial position or social responsibility of the person ordering the report.
  13. MGW

    MGW Screwfix Select

    Not really, yes I know you rarely get the paperwork, but if the client does not provide the paperwork, then should one assume a new installation?
    I really don't know, it was as a result of a discussion over supply to a thermostat, where the poster said it must all come from the same FCU, which I disputed. So he posted the instructions from a number of boilers, where they said it should come from the same supply, well most houses don't have two supplies so can't see this really being an issue, but as we know most thermostats some where some how transform the supply voltage to a much lower voltage to work the electronics, be it a wallmart and a USB supply or built into the thermostat, or using a pair of primary cells, although a Nest Gen 3 thermostat can be powered from the heat link, there is nothing wrong powering it from a completely independent supply supply using USB. I will agree where there are not volt free contacts then yes should be from the same FCU, but any thermostat that has volt free contacts could get its supply from another source. So he was trying to prove I was wrong. Hence the red line around the supply bit.

    Until he posted the extracts I had never seen any boiler ask for type A RCD, in fact only thing I have found asking for type other than AC is an electric car charging point, I would expect also solar panels would ask for better than type AC, but to expect anything supplied with a 13 amp plug to require better than type AC is flawed. Items with 13 amp plugs are installed by ordinary persons who can't be expected to know what a type AC, A, F, or B RCD/RCBO is. So only items which require installing should need better than a type AC, but clearly a boiler is installed.
  14. MGW

    MGW Screwfix Select

    I would agree if code C3 then likely ignored, however if the inspector codes missing RCD as code C3 then he has still told the owner, and he can refer to this fuse-box-1.jpg from the electrical safety council to support why only a C3, if he did not code missing RCD then very different, but in real terms do RCD's need fitting within 28 days? When I realised an error with type AC RCBO's being fitted where really would be happier with type A, I ordered type A from local whole sale outlet, now cancelled after waiting for 4 months and still not arrived. I am sure I could have gone to different supplier, but after some more thought decided it is unlikely any equipment with inject DC at same time as there is a earth leakage fault.

    I think most landlords will fit RCD protection, my children have used rented accommodation before getting their own homes, and every one had RCD protection.
  15. Comlec

    Comlec Screwfix Select

    In my experience it is rare for landlords to do remedials for C3 observations.
    I suppose the spectrum of landlords is wide and ranges from those who actually despise the tenants who make them rich and those that actually care.
  16. MGW

    MGW Screwfix Select

    I have only rented once in my life, while living in Hong Kong, my children have rented, and there have been some odd problems, like heating where due to being a listed building could not fit double glazing. But in the main landlords have been reasonable.

    When the tenant is not permitted to drill the wall, the wires buried at 50 mm rule hardly applies, and even if a RCD socket does not technically comply due to having wrong BS EN number it clearly does afford protection to the tenants. And smaller properties often have no garden so no supply to outside.

    So in real terms the problem with many homes is only code C2 when some bonding in the bathroom is removed, in most cases it is only C3.

    However what I see as a problem is where additions are done which we all know due to date when done needed RCD protection, we do not know why any manufacturer says RCD protection is required, and it only says manufacturers instructions should be taken into consideration not followed blindly. However where a new shower has been fitted, and the new shower manufacturer says it needs a 30 mA RCD I can't see how any installer can ignore this.

    So in real terms how many homes have nothing in them which says should be RCD protected? I think in real terms every home should be RCD protected, however with owner occupied homes we will select when, I was in this house around 4 months before RCD protection was installed on all circuits, and I see the 28 day rule as being unreasonable, we will often plan work around other events, the freezer is reduced to minimum before going on holiday so any work which may result in freezer not being powered would be better done just before or just after a holiday.

    In other words to suit both landlord and tenant, not forced to be done at a time when we are keeping stocks high as a result of the Colivd19 problems, and keeping tradesman out of homes except in an emergency. So to force work to be done in 28 days where in real terms being done in next 6 months is good enough is wrong.

    So if 701.411.3.3 is complied with as inspectors we should not be trying to force the landlords hand, even if the lack of RCD is only given a code C3 then should anything go wrong in the future the landlord has been informed, so he is libel. In the past even when a landlord has done all they could, google Landlady fined for electrocution and there seems to be loads of hits most before the new laws, I remembered reading about a death in Cornwell where she had engaged an electrician to do the work, but tenant died before he had got around to doing it, clearly a lot less than 28 days, and the question which came to my mind is what could the landlady have done to stop it. And the only option seemed to have been to tell tenants they can't live there until the electrician has visited and corrected any faults. This would be case with code C1 of course, but for a C2 if it is OK for 28 days why not 280 days?
  17. TheAllenFamily

    TheAllenFamily New Member

    Based on feedback that an up-to-date replacement consumer unit would be safer, another electrician has visited to replace the new consumer unit and has issued a green Domestic Electrical Installation Certificate (DCM18).

    Two questions:

    (1) Is the initial 'unsatisfatory' Electrical Installation Condition Report and the indication that remedial works have been undertaken sufficient or is another EICR required?

    (2) It transpires that the electrician who changed the consumer unit is NICEIC registered whilst undertaking his daytime job (for a large company in London), but was doing this work out of hours and he is therefore unable to submit a Part P request. I (now) know that I need to inform the council that works have been completed - I just don't know how.

    Any guidance gratefully received. Thanks in advance.
  18. The Happy Builder

    The Happy Builder Screwfix Select

    Sucker! It would have been far easier and cheaper to employ a person who could notify the work for you.

    I await with interest to see what people will advise you to do about the LABC notification.
  19. The Happy Builder

    The Happy Builder Screwfix Select

    You might think it is a bit harsh calling you a sucker, but the whole point of the exercise was to comply with your legal obligations as a landlord, which you have now failed to do because you employed a moonlighting electrician to do the remedial work and he cannot provide the LABC notification you require.

    Did you check the electrician has any insurance and qualifications? I saw one job that had been done by a moonlighting “electrician” who worked large NICEIC registered company, which was absolutely disgraceful, and when I asked about him in a wholesalers I was told he was actually an unqualified labourer and van driver.

    If he has given you a certificate he probably is the real McCoy, but the certificate on it’s own isn’t enough.
  20. TheAllenFamily

    TheAllenFamily New Member

    Not harsh at all, but apt.

    We were having a new central heating system installed and the plumber recommended the electrician that the plumbing company uses for their electrical work.

    In terms of Part P, this is something that was only raised after the installation and this whole can of worms opened.

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