Good to see our MPs are still hard at work

Discussion in 'Electricians' Talk' started by Comlec, Mar 18, 2020.

  1. Comlec

    Comlec Well-Known Member

  2. MGW

    MGW Well-Known Member

    But what will that really mean to electricians, up to the EICR being required by law, we could write down what we wanted, if we thought the CU should be changed to a metal one with all RCBO's we could put that into recommendations, and it would be likely talked over with owner, but "the electrical safety standards are met;" and it states those are standards laid out in 18th Edition. No provision to say any new work etc.

    So 17th said "BS 7671:2008 Requirements for Electrical Installations was issued on 1st January 2008 and is intended to come into effect on 1st July 2008. Installations designed after 30st June 2008 are to comply with BS 7671:2008." I suspect some thing similar in 18th? Which means instead of testing to 18th and giving C1, C2 or C3, we would need to test to the edition in force when each circuit was designed, a near impossible task as we normally don't know when designed.

    Remember the landlord has to give the tenant a copy within 28 days, so anything put on the EICR will be seen by the tenant, so a comment that RCD protection is recommended, can be seen as RCD must be fitted to comply with safety standards laid out in 18th edition. What has happened to "The Regulations are non-statutory."? if required to be followed by law, then they become statutory.
     
  3. Comlec

    Comlec Well-Known Member

    An EICR is a report and should only record non-compliance it does not make recommendations. However, that won’t stop the conmen who ‘recommend’ upgrade work in their EICRs.

    See this extract from Napit Codebreakers.
     

    Attached Files:

  4. spinlondon

    spinlondon Well-Known Member

    Don’t understand why we would have to test to the edition in force at the time of design.
    Would only have to do that for initial verification.
    Periodic testing is always done to the edition current at the time of testing.
     
    Comlec likes this.
  5. Sparkielev

    Sparkielev Well-Known Member

    Have done a few EICRs in the last few weeks where the consumer unit was plastic under a staircase, I gave them a C3 but was reluctant to do that
     
  6. spinlondon

    spinlondon Well-Known Member

    I installed a metal Consumer Unit under the stairs in my parent’s house in 1995.
    Only took the IET 20 years to catch up with me.
     
  7. MGW

    MGW Well-Known Member

    I think you have miss understood what I was trying to say, if an EICR has any fault reported, does not matter if C1, C2, or C3 or even not coded, the way the law is worded the landlord has 28 days to correct it.

    The new law is making the BS7671:2018 law for rented accommodation, so we have to go by exactly what BS7671:2018 says, not what we think is reasonable, or what Napit says, or anyone else, we have to go by what BS7671:2018 says, and if it says "Installations designed after 30st June 2008 are to comply with BS 7671:2008" sorry not got copy of 2018 but assume says the same with different dates, then we would need to use the edition current at the time of design, which I agree is daft, the BS 7671 was never designed to be a law, and to turn it into one is wrong.

    Yes we all want to strive to make homes as safe as possible, but where a house has been rewired in 2008 to say just 10 years latter with no degrading of the installation it is no longer compliant is going OTT. Be it cables run in plastic trunking or metal consumer units, to expect landlords to have major changes to the electrical system because cables may fall when we know it is a very low risk is going OTT, yes we would not install new where they can fall with heat from a fire, but to go around fitting heat resistance fixings within 28 days of the inspection is going OTT.

    Even the BS 7671 its self did not give such a short time, it was published well before it came into force, and it says there is no requirement to up grade existing until some thing new is added, so either we have to inspect and test to the version current at time of installation, or landlords will need to up grade to latest edition, as if on the form we enter C3 then law says he must fix in 28 days.

    I tried to get mothers house rewired, fastest I could get it done was 2 weeks, and shortest waiting time before starting was 3 weeks, that was ringing around all firms I could find in North Wales area. So I know from experience getting work done in 28 days is not as easy as it seems. It was costing £600 a week for mother in a care home while it was being done, so believe me I did all I could to get it done fast.
     
  8. spinlondon

    spinlondon Well-Known Member

    Does the legislation state all observations must be rectified?
    Or does it state a ‘Satisfactory’ report is required?

    (4) Where a report under sub-paragraph (3)(a) indicates that a private landlord is or is potentially in breach of the duty under sub-paragraph (1)(a) and the report requires the private landlord to undertake further investigative or remedial work, the private landlord must ensure that further investigative or remedial work is carried out by a qualified person within—

    (3)(a)ensure that the electrical safety standards are met during any period when the residential premises(8) are occupied under a specified tenancy;
     
    Last edited: Mar 19, 2020
  9. Comlec

    Comlec Well-Known Member

    @MGW the SI does not make BS761:2018 law.
    “electrical safety standards” means the standards for electrical installations in the eighteenth edition of the Wiring Regulations, published by the Institution of Engineering and Technology and the British Standards Institution as BS 7671: 2018(5);

    The specific part of BS7671:2018 that we need to use is suggest by the SI
    ..ensure every electrical installation in the residential premises is inspected and tested at regular intervals by a qualified person;

    So, we need to look at CHAPTER 65 PERIODIC INSPECTION AND TESTING from the current regs as to how to comply with the testing regime.

    And yes, NAPIT and other industry bodies give valuable advice to both sparks and their customers on how EICRs should be conducted.

    Finally, nowhere in the SI is there a implication that all rental properties must comply with the current regs as if they were a new installation. If this was the intention change to the law, then it would have fallen at the first hurdle given the lobbying power of the ARLA and the like. What we have is a compromise that will enforce on all landlords the inspection regime that has been part of BS7671 for a long time and already implemented by responsible landlords.

    As the 28 day limit. Good I say, virtually all C2 work should be able to be done in that timescale. If the installation is in such a state that it needs major work to bring to a satisfactory standard then the property should not be being let in the first place. I am sick of spending hours doing EICRs and issuing unsatisfactory reports on for the remedial work required to be ignored.

     
  10. Comlec

    Comlec Well-Known Member

    I agree Spin this is going to be a real problem. Landlords will want a report with the word 'Satisfactory'. however, if the report is unsatisfactory there is no real mechanism within BS7671 to issue an amended reported once the remedials are complete. I think it would be much better if it worked like the MOT system (Fail - fix - MOT)

    I recently sent this to a property manager to try and clear up the confusion.

    The initial inspection generates an EICR and if satisfactory no further paperwork is necessary.
    I have three options to deal with an unsatisfactory Report.

    1. If the C2 observations can be rectified with repairs or direct replacement of parts then I am happy to complete the work and issue a Satisfactory EIRC.
    2. If the C2 observations are rectified with work that requires the issue of a MWC (Minor Works Certificate) then this will be issued and can be appended to the original EICR.
    3. If the C2 observations are rectified with work that requires the issue of a EIC (Electrical Installation Certificate) then this will be issued and can be appended to the original EICR. If an EIC is issued then the LABC will be notified under Part P of the Building Regulations.
    So at the end of the process you should have either
    An EICR (Satisfactory)
    Or
    An EICR (Unsatisfactory) and replacement EICR (Satisfactory)
    or
    An EICR (Unsatisfactory) and a MWC(Minor Works Certificate)
    Or
    An EICR (Unsatisfactory) and an EIC(Electrical Installation Certificate), and a Building Regulations Compliance Certificate.
     
  11. spinlondon

    spinlondon Well-Known Member

    That sub paragraph (3)(a) could be taken as requiring the premises to comply with the current edition, not just at the beginning of the tenancy, but also any amendments or new editions introduced during the life of the tenancy.

    A code C3, generally means the installation doesn’t comply with the current edition/amendment, but is not unsafe.
     
  12. MGW

    MGW Well-Known Member

    So in essence it says must comply with BS7671:2018, there is no satisfactory or C coding, it either complies or does not comply, there is no room for manurer, this is what I see is what is wrong with the law, it makes BS7671:2018 law, so you would need to follow it by the letter, not use some sensible interpretation, and at the start of every wiring regulation I have read, it says "Installations designed after" so to comply with 2018 you have to use 2008 if designed before 2018, and to comply with 2008 you used 1992 if designed before 2008 and so on.

    I am sure this is not the intention of the law, but it is how it is written. If it said used Electrical safety councils recommended coding then OK, but that is not what it says. When the MOT came out it was not linked to any organisation book, the MOT issued their own book giving exactly what the limits were, so 1/16 play on rim of wheel with a 1" king pin etc.

    Its not the idea of ensuring rented accommodation is safe which is wrong, it is the linking to a book which was never intended to be law.
     
  13. spinlondon

    spinlondon Well-Known Member

    If the legislation requires the premises to comply with the 18th edition, what happens when the 19th edition is introduced?
     
  14. spinlondon

    spinlondon Well-Known Member

    From reading the draft that’s linked to in the OP.
    The landlord is required to ensure the Installation meets the requirements of the 18th edition.
    However there is nothing to say that the person Inspecting the Installation has to report any instances that do not meet the requirements of the 18th edition.

    I do love the definition of a qualified person.
     
  15. MGW

    MGW Well-Known Member

    @spinlondon at last some one who can see my point, and yes same happened with Part P that is linked to BS 7671:2001 in Wales, my be latter edition in England.

    And the "Installations designed after" bit at start of all versions of the regulations means there is no requirement to up date to current edition, read the electrical safety councils best practice guide, and it says pre-1966 installations can still have no earth to lighting circuits.

    But lighting is OK, this has been a big thing for many years, we all know when the rules was changed, but if I remember correctly, 14th Edition stated no socket within 1.5 meters of a tap? But today waste disposal units are often plugged in under the sink, that rule has long gone, as to earthing metal window frames, again long gone, but if you use that "Installations designed after" clause, then if the house was designed, note designed not built, in 1975 it likely needs earth wires to the double glazing to comply.

    Earliest I still have is 16th Edition, I have some guides to earlier editions, but we I am all sure have up to now used common sense and guides from people like electrical safety council which were good enough the following the regulations was not law.
     
  16. ajohn

    ajohn Well-Known Member

    Like many things as clear as mud. It's talking about regular checks of electrical systems. This is covered by the regs which has scope for effectively stating doesn't comply but is ok. Any other interpretation will be like plastic consumer units - some going around saying that must be changed.

    ;) I beat spinlondon on fitting a metal consumer unit - my father flatly refused to have a plastic one fitted. A sideline of his job was more severe accident investigations in factories owned by the company he worked for. Asked him why and he said fires and that using plastic was stupid idea.

    The final one is here
    http://www.legislation.gov.uk/ukdsi/2020/9780111191934
     
    Last edited: Mar 22, 2020
  17. spinlondon

    spinlondon Well-Known Member

    I don’t recall the 14th stipulating any distance for a socket to be from a tap.
    There was a 2m rule for sockets on different phases, cooker switches and cables linking switchgear.
    As I didn’t start becoming an Electrician until after 1976, it could be that earlier versions of the 14th had the 1.5m rule for taps?
     
  18. ajohn

    ajohn Well-Known Member

    But if it was >300mm it would comply with the 17th. If closer according to the 18th it would just not comply with guidance as the kitchen is no longer a special area.

    You guys make life far too complicated for yourself. The legal requirement is only about checks so anything allowed via the 18th checks is ok as the checks should be done accordingly.
     
  19. spinlondon

    spinlondon Well-Known Member

    Sorry, but are you talking about?
    There is no >300mm rule in the 17th.
     
  20. ajohn

    ajohn Well-Known Member

    :confused:Yes I have my numbers mixed up but surely you take my point. Guidance only in the 17th not in the regs according to the guide to building regs anyway.
     

Share This Page