EICR Certificate not issued. Not all circuits RCD protected rated C2

[denniso]

Hello,

I've recently had an EICR done on my 2 bed house which is a residential let. This house is about 25 years old built by Charles Church.

The EICR has not been issued due do C2's, there were no C1's
Email with C2s ratings for 1) Not all circuits RCD protected, 2) Bathroom light is a bare build not IP rated and 3) Hall pendant missing skirt cap.
I have no more detail at present ... just an email with bullets.
Just to reiterate I have some circuits with RCDs just not "all" circuits with RCDs!

I have challenged the email from the estate agent and received this response.

"As for the codes, any privately rented property nowdays requires rcd protection across each and every circuit to ensure safety to the tenants, failure of 30mA rcd protection on any circuits causes a C2 code when then the EICR fails as it cannot pass with any C2 codes present. (I'm currently having this problem at 90% of properties I'm conducting EICRs at) so unfortunately it is mandatory. 100% a code 2, it's different if it's in your own household then it's a code 3, but a rented accommodation it's a code 2 as all circuits have to be rcd protect for the safety of the tenants.

I will break the quotation down further for you with a full quotation typed up thoroughly shortly."

So the question and help required is
QUESTION: Is it a REQUIREMENT to have RCDs on "all" circuits to avoid a C2 rating? My position after limited research is no it is not a C2
HELP REQUIRED: How do I proceed? The property manager Romans Estate Agents in Berkshire is the individual supporting the Electricians position!
Report yet to be issued/released by the Estate Agent and or Electrician

 

[Risteard]

As it is a Report it should be issued irrespective of the fact that it may state that the electrical installation is "Unsatisfactory". To put it into context, probably 95% of the inspections I carry out result in "Unsatisfactory" being recorded. The important thing is that you have remedial works carried out as necessary (and certified as appropriate).

Lack of 30mA RCD additional protection is likely to attract different classifications/codes against it in the observations depending on the reason for the requirement. As an example an electric shower without 30mA RCD protection may not be classified the same way as concealed cables buried in the wall at a depth of less than 50mm and not otherwise mechanically protected e.g. with Earthed steel conduit.

It is also incorrect to state that all circuits in domestic dwellings require 30mA RCD protection. Very often that will be the most economic way of installing, but there is no blanket requirement for 30mA RCD protection on all domestic circuits.

 

[GBDamo]

As always the introduction of new legislation has resulted in chaos and chancers.

My take is that all rental properties have to be tested to the 18th edition.

All editions of the regulation have a statement to the effect that they should not be retrospectively applied.

So, unless your property was built to the 18th then it need not fully comply with the 18th. It must however full comply with the edition in use when the property was built/refurbished.

There is as always nuance and some situations will receive a C2 even when not in contravention of the regulations in force at the time.

In brief, some circuits need not be RCD protected. Socket and all bathroom circuits should. General lighting the odd fused spur radial need not.

Ideally, budget allowing, there is a good safety argument for RCD protection of all domestic circuits.

 

[MJPD29]

Hello,

I've recently had an EICR done on my 2 bed house which is a residential let. This house is about 25 years old built by Charles Church.

The EICR has not been issued due do C2's, there were no C1's
Email with C2s ratings for 1) Not all circuits RCD protected, 2) Bathroom light is a bare build not IP rated and 3) Hall pendant missing skirt cap.
I have no more detail at present ... just an email with bullets.
Just to reiterate I have some circuits with RCDs just not "all" circuits with RCDs!

I have challenged the email from the estate agent and received this response.

"As for the codes, any privately rented property nowdays requires rcd protection across each and every circuit to ensure safety to the tenants, failure of 30mA rcd protection on any circuits causes a C2 code when then the EICR fails as it cannot pass with any C2 codes present. (I'm currently having this problem at 90% of properties I'm conducting EICRs at) so unfortunately it is mandatory. 100% a code 2, it's different if it's in your own household then it's a code 3, but a rented accommodation it's a code 2 as all circuits have to be rcd protect for the safety of the tenants.

I will break the quotation down further for you with a full quotation typed up thoroughly shortly."

So the question and help required is
QUESTION: Is it a REQUIREMENT to have RCDs on "all" circuits to avoid a C2 rating? My position after limited research is no it is not a C2
HELP REQUIRED: How do I proceed? The property manager Romans Estate Agents in Berkshire is the individual supporting the Electricians position!
Report yet to be issued/released by the Estate Agent and or Electrician

According to NAPIT, a C2 code is required in the circuits not protected by RCD situation, so although I personally would code it C3, there is a case for supporting the C2 there. I also agree with the statement that you should be doing everything possible to ensure the safety of your tenants, and realistically, upgrading all circuits to have all RCD protection is a step in that direction.

 

[TJ Anderson]

According to NAPIT, a C2 code is required in the circuits not protected by RCD situation, so although I personally would code it C3, there is a case for supporting the C2 there. I also agree with the statement that you should be doing everything possible to ensure the safety of your tenants, and realistically, upgrading all circuits to have all RCD protection is a step in that direction.

A experienced inspector has to be able to apply their discretion when applying codes and also be aware of previous editions of the wiring regulations. Something being "Unsafe" and something that is "Not unsafe but could be made safer" are two different things. An EICR should not be used to up sell improvement works beyond recommendations to rectify unsafe situations.

 

[ChrisElectrical88]

Get the report off her and stick it up here and you will get a better input. They legally have to give you the very even if unsatisfactory. Not all bathroom lights need to be a certain IP rating and a pendent missing a skirt is a C3 for me.

 

[littlespark]

As far as the electrician doing the report is concerned there should be no difference in coding between an owned property and one to be rented.

I’m sure there’s another thread on here mentioning that the new rules for all rented to have an EICR is worded wrong.

What happens in a few years when the 19th comes out?

 

[Vortigern]

Either way an RCBO is about £20 and fitting say £35 so what's the problem?

 

[MJPD29]

A experienced inspector has to be able to apply their discretion when applying codes and also be aware of previous editions of the wiring regulations. Something being "Unsafe" and something that is "Not unsafe but could be made safer" are two different things. An EICR should not be used to up sell improvement works beyond recommendations to rectify unsafe situations.

I am fully aware of that. I am not a member of NAPIT either but they code it as a C2. Merely pointing that out.

 

[James]

In my opinion, the regs have always been taken as correct at date of installation.
If something is deemed safe and up to standard when installed, I don’t like the presumption that it is unsafe when new regs are published.
I am sure there is a comment in the regs book that says pretty much the same thing but I am not going to look for it tonight.

Remember, if they did this with mot tests, there would not be a single classic car allowed on the road.
Are we saying that all classic cars are dangerous?

 

[DPG]

Either way an RCBO is about £20 and fitting say £35 so what's the problem?

The cost is not the issue though, the report should be accurate.

 

[denniso]

All,

I absolutely agree safety first!
Cost is not the issue
I want to understand if "not have all circuits RCD protected" is an automatic C2 rating
- Page 12 of the Best Practice Guide attached - implies to me no this is not a C2.
I am on here for guidance from experts. I am NOT an electrician. I would/ do appreciate your response and guidance.

 

[westward10]

Best Practice Guides are not required documents to have or follow similarly, you also have the NAPIT guide often giving different advise. It is up to the individual how they Code things usually through knowledge and experience although most often this is not the case.

 

[HappyHippyDad]

All,

I absolutely agree safety first!
Cost is not the issue
I want to understand if "not have all circuits RCD protected" is an automatic C2 rating
- Page 12 of the Best Practice Guide attached - implies to me no this is not a C2.
I am on here for guidance from experts. I am NOT an electrician. I would/ do appreciate your response and guidance.

It is not an automatic C2, however it could well be a C2. Lots of landlords are starting to ask the same question and I think we need to focus on the fact that an RCD is a life saver.
If the electrician has given it a C2 and the estate agent is agreeing with the electrician then I think it's best to get the work carried out.
I always think that not having an RCD is like driving around in a car without a seatbelt on. You're fine until you have a crash.

 

[telectrix]

I always think that not having an RCD is like driving around in a car without a seatbelt on. You're fine until you have a crash.

i would more liken it to having a seatbelt but not an airbag. similar to having ADS but no RCD.

 

[ChrisElectrical88]

Have you got a certificate for it yet? Just out of interest what did you pay for the report?

 

[davesparks]

If something is deemed safe and up to standard when installed, I don’t like the presumption that it is unsafe when new regs are published.
I am sure there is a comment in the regs book that says pretty much the same thing but I am not going to look for it tonight.

There is an often misunderstood statement in the regulations that compliance with a previous edition does not necessarily mean something is dangerous, potentially dangerous or in need of improvement.

This does not say that 'if it complied when it is installed then it is ok'
[automerge]1595258321[/automerge]

Hello,

I've recently had an EICR done on my 2 bed house which is a residential let. This house is about 25 years old built by Charles Church.

The EICR has not been issued due do C2's, there were no C1's
Email with C2s ratings for 1) Not all circuits RCD protected, 2) Bathroom light is a bare build not IP rated and 3) Hall pendant missing skirt cap.
I have no more detail at present ... just an email with bullets.
Just to reiterate I have some circuits with RCDs just not "all" circuits with RCDs!

I have challenged the email from the estate agent and received this response.

"As for the codes, any privately rented property nowdays requires rcd protection across each and every circuit to ensure safety to the tenants, failure of 30mA rcd protection on any circuits causes a C2 code when then the EICR fails as it cannot pass with any C2 codes present. (I'm currently having this problem at 90% of properties I'm conducting EICRs at) so unfortunately it is mandatory. 100% a code 2, it's different if it's in your own household then it's a code 3, but a rented accommodation it's a code 2 as all circuits have to be rcd protect for the safety of the tenants.

I will break the quotation down further for you with a full quotation typed up thoroughly shortly."

So the question and help required is
QUESTION: Is it a REQUIREMENT to have RCDs on "all" circuits to avoid a C2 rating? My position after limited research is no it is not a C2
HELP REQUIRED: How do I proceed? The property manager Romans Estate Agents in Berkshire is the individual supporting the Electricians position!
Report yet to be issued/released by the Estate Agent and or Electrician

What a load of bull-poo!

The regulations are the same for all installations, it doesn't matter whether it is rented or not.
There are a number of reasons for installing RCD protection on circuits, depending on the exact situation a lack of RCD protection can be either a C2 or C3 item.

An EICR is not a certificate, it is a report.

The job you have employed them to do is carry out a report, if they have refused to provide you with the report then don't pay them and get another electrician to do it.
They have no right, or reason, to withhold the report based on the outcome of the report.

The overall assessment of an installation cannot be 'fail' it can only be 'satisfactory' or 'unsatisfactory'

 

[UKPN]

As far as the electrician doing the report is concerned there should be no difference in coding between an owned property and one to be rented.

I’m sure there’s another thread on here mentioning that the new rules for all rented to have an EICR is worded wrong.

What happens in a few years when the 19th comes out?

Absolutely, littlespark, 1 day the 18th finishes, the next day the 19th starts. What happens? rewire everything?
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There is an often misunderstood statement in the regulations that compliance with a previous edition does not necessarily mean something is dangerous, potentially dangerous or in need of improvement.

This does not say that 'if it complied when it is installed then it is ok'
[automerge]1595258321[/automerge]


What a load of bull-poo!

The regulations are the same for all installations, it doesn't matter whether it is rented or not.
There are a number of reasons for installing RCD protection on circuits, depending on the exact situation a lack of RCD protection can be either a C2 or C3 item.

An EICR is not a certificate, it is a report.

The job you have employed them to do is carry out a report, if they have refused to provide you with the report then don't pay them and get another electrician to do it.
They have no right, or reason, to withhold the report based on the outcome of the report.

The overall assessment of an installation cannot be 'fail' it can only be 'satisfactory' or 'unsatisfactory'

Eicr is a report, Well I think that's what the "R" is for!

 

[davesparks]

Eicr is a report, Well I think that's what the "R" is for!

Yes, that is why I said it is not a certificate, it is a report.

What is your point?

 

[denniso]

All,

attached here is the EICR report .. to me it does not contain a lot of detail
Your opinions please.

How much detail in a typical report should I expect?
What is the rationale for C2s ratings ? Are they justified?

 

[Risteard]

It's a very poorly compiled report to be fair.

You should redact names and addresses from it though, including those of the company responsible.

There is no requirement for 30mA RCD protection of all circuits. Although in practice this may well be needed on all circuits, it will actually be for a number of different reasons. These reasons should have been given rather than some incorrect statement.

There's no such thing as an "Amendment Type 3" board - but presumably he is referring to one made of non-combustible material or housed in a cabinet made from non-combustible material.

Likewise the bathroom luminaire may well have an IP rating, but presumably the issue is that it is an inadequate IP rating.

Lots and lots of boxes ticked in the Schedule of Inspections. I am doubtful that all of those things were checked and that all of them were compliant.

 

[Strima]

The lack of RCD protection for some circuits would normally attract a C3 as the sockets have RCD protection, caveat that all cables are run in zones etc.

Without seeing the other C2 items it's hard to say but I would err on the side of caution and agree with the inspector.

 

[westward10]

All,

attached here is the EICR report .. to me it does not contain a lot of detail
Your opinions please.

How much detail in a typical report should I expect?
What is the rationale for C2s ratings ? Are they justified?

I have deleted the report. Can you resubmit it so it does not show the contractors details and your address.

 

[UKPN]

The lack of RCD protection for some circuits would normally attract a C3 as the sockets have RCD protection, caveat that all cables are run in zones etc.

Without seeing the other C2 items it's hard to say but I would err on the side of caution and agree with the inspector.

I have deleted the report. Can you resubmit it so it does not show the contractors details and your address.

All,

attached here is the EICR report .. to me it does not contain a lot of detail
Your opinions please.

How much detail in a typical report should I expect?
What is the rationale for C2s ratings ? Are they justified?

I the wiring was done before the 18th ed the worst would be C3, if that.
Unless you have bare wires etc sticking out then you would advise immediate attention, so no C1/2 anyway.

 

[davesparks]

I the wiring was done before the 18th ed the worst would be C3, if that.
Unless you have bare wires etc sticking out then you would advise immediate attention, so no C1/2 anyway.

Coding does not change based on when something was installed, the inspection is carried out to the current edition of BS7671 and all items coded in accordance with the current edition.

 

[UKPN]

Coding does not change based on when something was installed, the inspection is carried out to the current edition of BS7671 and all items coded in accordance with the current edition.

Incorrect. as per front of book.

 

[Ian1981]

The aspects to be covered in an EICR include
Identification of non-compliances with the current edition of BS 7671, or installation defects, which may give rise to danger.

Must we go through this every time regarding eicr’s?
It is only logical that they are inspected against the current wiring regulations.
We all acknowledge the HSE foreword about how older installations are not necessarily unsafe etc etc, we cannot dig into the archives of wiring regulations based on when an installation was first put into service as safety has well and truly evolved.

 

[davesparks]

Incorrect. as per front of book.

Front of what book?

It is made very clear in BS7671 that EICRs are carried out to the current edition and any non-compliance which has a safety implication should be coded accordingly. You are probably falling into the common trap of misreading the note that points out that compliance with a previous edition does not necessarily mean something is unsafe.
The key point about this is 'not necessarily' meaning it may or may not be unsafe, but non compliance with previous editions on its own is not grounds for something being unsafe.
Fused neutrals and red and black conductors comply with previous editions, one is safe and not coded, one is unsafe an coded.

 

[Simon47]

My experience with agents is that they tend to take what "the exoerts" tell them as gospel. I've had a number of communications that I've been able to tear apart - the sort of misinformation we've come to expect from the scams, filtered via an agent who doesn't know any better.

 

[Dartlec]

I don't have a copy of the Napit document to refer to, but my Youtube watching of late seems to be showing up some discrepancies between them and the ESF Best Practise guide, which is hardly reassuring to those of us still trying to find our way through the maze.

Personally, I'd say a reasonable attitude might be that a socket that is likely to be used for external use and is not RCD protected might well be a C2 (though replacing that socket with an RCD socket might resolve the issue), while a socket for a fridge in a 2nd floor flat (with suitable Zs and all other things being equal) might well be a C3.

Neither case is inherently "unsafe" though, so we are left to make judgements about what is an acceptable level of minimum safety, in the same way that 70s cars can still pass an MOT, without many of the safety features of 90s cars.

It seems rather like the powers that be are trying to be too prescriptive on one hand (with ANY C2 requiring an unsatisfactory rating, for example), while refusing to be clear or consistent in guidance, which is itself published separately and not necessarily binding on the standards we are all supposed to be following.

In other words, it's all a complete dog's breakfast as usual!

 

[Simon47]

Personally I think government are OK on this - you inspect & test to current regs*, and if there are C1 or C2 defects then the installation is dangerous and needs rectification. I lay the blame for the confusion at the door of the scams who have a vested interest in drumming up work for their members. I note that a lot of the discussion here relates to guidance from the scams - and specifically guidance suggesting defects be rated more seriously that some here think is warranted.

* Well, it would be if that's what the regs actually said.

 

[EricMark]

I would say the whole problem is the EICR was never intended to be used to show if a property can be rented out, if to fit a new socket I will need to have a new consumer unit fitted, I need to know. I need to know what needs to be done to comply with current edition, so yes it is done to current edition.

There is a problem in I don't have a copy of the 14th Edition so I could not say if the property complied with it or not. This is from 17th Edition don't have 18th to hand.

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.

Note the word "designed" so that quote says it does comply with 17th Edition if designed before 30st June 2008 and complied with edition current at the time.

C1, C2, C3 do not say does not comply with regulations, it says how dangerous it is, there was a 4 which said complies with previous edition, but that was scrapped. So ' Danger present. Risk of injury. Immediate remedial action required.' is the same what ever edition one is using. The same with 'Potentially dangerous - urgent remedial action required.' if it is potentially dangerous then that can't change depending on which edition. 'Improvement recommended.' however will depend on the edition used.

So the big question what makes some thing which was not potentially dangerous in 1992 when BS 7671 first came out, potentially dangerous today? The answer must be the equipment used today which was no available in 1992, so what we are looking at is the switched mode power supply, in 1992 we would transform voltage then regulate there were very few items which rectified mains, so the only change that I can see is the types of RCD used to protect with a TT supply. So I can see a good reason to issue a C2 when the RCD used on a TT supply is type AC. That is about the only thing which in 1992 was safe but in 2018 is not safe.

Can anyone think of anything else which is not safe today but was safe in 1992?

C2 does not mean does not comply with BS 7671:2018 it means potentially dangerous, and over the years the electrical characteristics of properties change, be it the water pipes changed to plastic, or the switch plates changed to metal, or even the supply voltage dropped from 250 to 230.

If I as an electrician but not a member of any scheme do any electrical work I need to issue a minor works or installation certificate, and if any of that work is on the list of notifiable work I need to inform and pay the LABC fee before I start, which is little more than a tax, the law has changed slightly in now in England I need to hold a level 3 or higher qualification, in Scotland seem to remember I must have attended a course in last 5 years, but in essence since I have passed my C&G 2391 I can if I got some professional indemnity insurance start doing EICR's which are legal. I can't issue a compliance certificate or a completion certificate, but I can make a report.

It seems SSE have an insurance, which for under £70 a year covers the house holder for any repairs to the electrical installation and there is a full report made before they take on the property and a yearly check done. Read about it on another forum, and the home owner was adamant his house was OK as nothing had been reported wrong, he has a TT system with a 100 mA RCD with no type marked on it. We were trying to tell him he needed a 30 mA RCD before fitting a new 9.5 kW shower, and the Wylex fuse board although the fuses had been replaced with MCB's was also past its use by date.

So most electricians do not want to end up in court, so we play safe, at least I do, and as far as an EICR goes that means following the electrical safety councils best practice guide even if I don't agree with it, I want to if I have to stand up in court to say I followed the recommendations. And to be frank I have all RCBO protection in my house, so to say to some one else you don't need it does not some how ring true, I made a mistake and thought I was fitting type B as that is what is said on the boxes, seems fitted type AC, so I have ordered 2 type A to replace those feeding the sockets.

So if you go into a property with those silly power line units fitted on a TT supply, do you give it a C2 unless fitted with type F RCD? If not why not?

 

[EricMark]

It should be borne in mind that, as stated in the introduction to BS 7671, existing installations that have been constructed in accordance with earlier editions of the Standard may not comply with the current edition in every respect, but this does not necessarily mean that they are unsafe for continued use or require upgrading

Consumer units having rewirable fuses can continue to provide satisfactory service (cover removed for illustrative purposes)

Where some thing has been changed for example the earthing arrangement in a bathroom to a latter edition clearly it all needs to be to same edition, so it may NEED RCD protection.

The biggest problem I see where RCD's have been added is where when on fails to keep essential supplies i.e. freezer only option is to run cables up/down stairs, the risk of tripping over cables on the stairs likely exceeds the risk from shock not having a RCD.

 

[Simon47]

What has changed is both the perception of, and attitude to, risk. At one time, it was considered "normal" to have a bayonet plug on appliances and plug them into a light socket with no earth - while the risks from doing that have not changed (if anything they've reduced with things like double insulated appliances), our attitude to the risk of doing that have changed and we no longer consider it "safe".

 

[UKPN]

The aspects to be covered in an EICR include
Identification of non-compliances with the current edition of BS 7671, or installation defects, which may give rise to danger.

Must we go through this every time regarding eicr’s?
It is only logical that they are inspected against the current wiring regulations.
We all acknowledge the HSE foreword about how older installations are not necessarily unsafe etc etc, we cannot dig into the archives of wiring regulations based on when an installation was first put into service as safety has well and truly evolved.

Thats your opinion,

Front of what book?

It is made very clear in BS7671 that EICRs are carried out to the current edition and any non-compliance which has a safety implication should be coded accordingly. You are probably falling into the common trap of misreading the note that points out that compliance with a previous edition does not necessarily mean something is unsafe.
The key point about this is 'not necessarily' meaning it may or may not be unsafe, but non compliance with previous editions on its own is not grounds for something being unsafe.
Fused neutrals and red and black conductors comply with previous editions, one is safe and not coded, one is unsafe an coded.

Playing with words, (again) lets say you have a water main earth, .3ohms. perfectly alright.

 

[EricMark]

My under standing is every issue of wiring regulations has a start date after which anything designed after that date should comply, I will agree it is hard to work out the date an installation was designed, so with lack of paperwork giving design dates, then only option is to test to current standards. This is also only option when it is clear alterations have been made. But the regulations are very clear as to dates they cover. Of course other problem is I don't have a copy of the 14th and 15th edition.

However simple fact is items don't become dangerous simply because of a change in standards, wiring can degrade, and items can be damaged, but if the installations was OK without a RCD in 1998 then it is still OK without an RCD.

So we have two supply types, TT, and TN, as as far back as I can find reference to a TT supply has required some type of earth leakage trip on all circuits, so with a TT supply lack of RCD is clearly a failure irrespective of age. With a TN supply it depends on the ELI, where the earth loop impedance is 0.8 ohm which is allowed with TN-S then it may well be the ELI for some circuits is not low enough, but with an ELI of 0.35 ohm as found with a TN-C-S supply then it unlikely any circuit is below the accepted levels. So as long as the ELI is low enough, lack of a RCD does not produce a danger, so can not be a C2 it can only be a C3.

So no RCD and ELI below required value C3 above C2.

The coding 4 was removed from the EICR, years ago there was a code 4 to say does not comply with current regulations, but it was decided this caused confusion and the EICR was simply to say if safe, not to say if it complied with current regulations, and if safe in 1954 and nothing has degraded then it is still safe.

I was reading the Scottish government guide lines on doing an EICR for rented property, and I noted it said lack of an RCD may be a failure, not is a failure, but may be, and yes if a TT supply it is unlikely to cause the circuit to automatic disconnect in the event of a fault so that would be a failure.

Remember we are not looking as compliance with BS7671 we are looking for danger, this brings up one interesting point with use of RCD as the only method of auto-disconnection. If the MCB can also trip as with TN supply this does not really matter, only looking at TT supplies. What I am looking at is the type of RCD, we have type AC, A, F and B and since we also have a type B MCB with RCBO's there has been a problem, we should refer to curve B with MCB and type B with RCD so no errors, but I bought type B RCBO's thinking the RCD part was type B only to find actually type AC.

So this depends on appliances in the home, with inverter fridge/freezer or washing machine we really need type A, with powerline adaptors then type F, so with a TT supply the result of the EICR can be dependent on the equipment used in the house, as to how a tenant would act if we said sorry you can't use powerline adaptors in this house as it is all RCBO as to date no RCBO type F is available so sorry you need to either move out within 28 days or stop using powerline adaptors I don't know?

 

[davesparks]

Thats your opinion,

Playing with words, (again) lets say you have a water main earth, .3ohms. perfectly alright.

I am not playing with words.

By that I assume you mean a water pipe being used as the means of earthing and having an impedance of 0.3 ohms?

This is not immediately dangerous not potentially dangerous (within reason), so it cannot be a C1 or C2. It is not compliant, and it could be improved, but the improvement would not improve the safety of the installation as it is, so I don't see a C3 could be applied either.

I would however make a note so that the customer is informed that it is not an ideal situation and explain why.
[automerge]1596747556[/automerge]

My under standing is every issue of wiring regulations has a start date after which anything designed after that date should comply, I will agree it is hard to work out the date an installation was designed, so with lack of paperwork giving design dates, then only option is to test to current standards. This is also only option when it is clear alterations have been made. But the regulations are very clear as to dates they cover. Of course other problem is I don't have a copy of the 14th and 15th edition.

However simple fact is items don't become dangerous simply because of a change in standards, wiring can degrade, and items can be damaged, but if the installations was OK without a RCD in 1998 then it is still OK without an RCD.

EICRs are carried out to the current regulations regardless of when they were installed.

No items do not become dangerous because the regulations have changed. The regulations are changed when something is found to be dangerous that was previously thought to be safe, or has become unsafe due to other factors.
The item which is now viewed as dangerous has (usually) always been dangerous, it is our understanding of the danger which has changed, not the danger itself.
Regulations also change when new technology or unstanding allows improvements to be made for safety.

No, an installation which was not required to have an RCD in 1998 is not OK now, if it is required to have an RCD by current standards then it is noted on the EICR and given an appropriate code, often a C3 'improvement recommended' because a safety improvement can be made.

 

[EricMark]

EICRs are carried out to the current regulations regardless of when they were installed.

Nearly correct, and the current regulations say an installation designed after the date should follow the regulations, and every set has some thing like this

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.

followed by

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.

so following current regulations means you use the regulations in force at the time of the design.

It has nothing to do with when installed, it was when it was designed that matters. That was your only error with that statement. Where legislation has caused a change then yes we have to reflect that in the report, but even today properties designed before 1966 can still have no earth terminated at lighting equipment as long as the notices are affixed and there are no exposed metal parts likely to connect to earth i.e. Class II.

There are some things which did not exist in 1950's and we do need to consider changes like solar power and electric cars which may require an RCD which was not invented at the time of the design. And also things like the water and gas supply being now plastic, or TN-S being changed to TN-C-S so we can not ignore what has happened since it was designed.

The example that comes to mind is the use of powerline adaptors which it would seem necessitate the use of type F RCD's where the RCD is the prime protective measure. i.e. TT installations. Where the problem arises these are simply plugged in, so simply unplugging them means it's no longer a potential danger, the same clearly applies with overloaded sockets, and inverter fridge, freezers, and washing machines.

Other problems are the lack of previous editions to check what was required, my earliest is BS7671:2001 even the Scottish Government in their guide lines point out lack of RCD protection would only be a C2 in certain circumstances, i.e. TT supplies, and the Electrical Safety Council with their best practice guide 4 issue 5 also point out having the old Wylex fuse board is not a reason to issue a C2.

When I took my C&G2391 we had a 4th code, does not comply with current edition, that was removed, as it simply does not matter, what we are looking for is how safe the installation is, not if it complies with current edition. And there are some things I would mark as C2 even though they did comply when the installation was designed, a good example is an ELCB-v.

We need professional indemnity insurance to complete an EICR because we are giving a professional opinion, we are not simply following the current BS7671 or any other document, we are using our years of experience to decide if safe.

Would you believe it when I say I read an EICR with a C1 listed and the circuit was still live, and the fault not corrected, my first question was when it is classed as dangerous why did you turn it back on? Answer we didn't the inspector left it switched on, how can you really trust anyone doing an EICR who does not either correct or isolate when he finds a C1? Maybe he likes prison food?

Oddly although I live in Wales it is the Scottish law I have been looking at, and that clearly states any C1 has to be made safe before the inspector leaves the premises. And if repaired a minor works or installation certificate must be attached to the EICR.

 

[Grant1987]

My under standing is every issue of wiring regulations has a start date after which anything designed after that date should comply, I will agree it is hard to work out the date an installation was designed, so with lack of paperwork giving design dates, then only option is to test to current standards. This is also only option when it is clear alterations have been made. But the regulations are very clear as to dates they cover. Of course other problem is I don't have a copy of the 14th and 15th edition.

However simple fact is items don't become dangerous simply because of a change in standards, wiring can degrade, and items can be damaged, but if the installations was OK without a RCD in 1998 then it is still OK without an RCD.

So we have two supply types, TT, and TN, as as far back as I can find reference to a TT supply has required some type of earth leakage trip on all circuits, so with a TT supply lack of RCD is clearly a failure irrespective of age. With a TN supply it depends on the ELI, where the earth loop impedance is 0.8 ohm which is allowed with TN-S then it may well be the ELI for some circuits is not low enough, but with an ELI of 0.35 ohm as found with a TN-C-S supply then it unlikely any circuit is below the accepted levels. So as long as the ELI is low enough, lack of a RCD does not produce a danger, so can not be a C2 it can only be a C3.

So no RCD and ELI below required value C3 above C2.

The coding 4 was removed from the EICR, years ago there was a code 4 to say does not comply with current regulations, but it was decided this caused confusion and the EICR was simply to say if safe, not to say if it complied with current regulations, and if safe in 1954 and nothing has degraded then it is still safe.

I was reading the Scottish government guide lines on doing an EICR for rented property, and I noted it said lack of an RCD may be a failure, not is a failure, but may be, and yes if a TT supply it is unlikely to cause the circuit to automatic disconnect in the event of a fault so that would be a failure.

Remember we are not looking as compliance with BS7671 we are looking for danger, this brings up one interesting point with use of RCD as the only method of auto-disconnection. If the MCB can also trip as with TN supply this does not really matter, only looking at TT supplies. What I am looking at is the type of RCD, we have type AC, A, F and B and since we also have a type B MCB with RCBO's there has been a problem, we should refer to curve B with MCB and type B with RCD so no errors, but I bought type B RCBO's thinking the RCD part was type B only to find actually type AC.

So this depends on appliances in the home, with inverter fridge/freezer or washing machine we really need type A, with powerline adaptors then type F, so with a TT supply the result of the EICR can be dependent on the equipment used in the house, as to how a tenant would act if we said sorry you can't use powerline adaptors in this house as it is all RCBO as to date no RCBO type F is available so sorry you need to either move out within 28 days or stop using powerline adaptors I don't know?

This is the side of electrics which I dislike you are over complicating the situation and the simple electrician like myself ? without all the waffle let’s upgrade the consumer unit and bring the property up to current standards. I know this isn’t always possible as £££ is the defining factor and you will find ways to avoid doing so but as much as possible upgrade

 

[EricMark]

Who said electrics was easy? I started with an apprenticeship and collage day release, and then a period just muddling along with everyone else, in the late 90's I returned to UK and every second word out of electricians mouths seemed to be 16th Edition says, and in the end bit the bullet and returned to first college and then university, and yes when I returned I realised how many errors I had been making.

I also realised I was not that good at maths, and I do think there was a lot of luck involved when I got my degree, however it did teach me how to read, and so many things I thought I knew were wrong as been reading about them out of context.

In BS7671:2008 it says "Joints shall not be made in cables except where necessary as a connection into a circuit." however that only refers to exhibitions, shows and stands, it is so easy to hunt the document and miss some preamble as to what this section is talking about. For years I thought a socket had to be at least a meter from a sink, it seems that was 14th edition although I don't have a copy to check.

And of course this is the problem we don't have a library of books to check regulations, we have to make a judgement is this dangerous, is it likely to become dangerous, or will the owner need to modify this in near future and should he be warned.

New showers invariably say RCD must be fitted, and the regulations have said for many years manufactures instructions should be followed, so even if designed in 1960, when fitting a new shower a RCD needs adding, same with boilers, and many other items. I really did expect my cooker with induction hop to say RCD must be fitted but no.

Personally what at 13 years old, (he is over 40 now) my son started to study to be a radio ham, I felt I wanted to protect him, so since around 1992 my house has been RCD protected, however father-in-laws house was sold last year and still had no RCD's fitted and it was him who got me to fit them to protect my son. This house was quickly changed to all RCBO, again I think that makes sense. But I can't give a house a C2 for no RCD however much I like them unless TT.

 

[Grant1987]

Who said electrics was easy? I started with an apprenticeship and collage day release, and then a period just muddling along with everyone else, in the late 90's I returned to UK and every second word out of electricians mouths seemed to be 16th Edition says, and in the end bit the bullet and returned to first college and then university, and yes when I returned I realised how many errors I had been making.

I also realised I was not that good at maths, and I do think there was a lot of luck involved when I got my degree, however it did teach me how to read, and so many things I thought I knew were wrong as been reading about them out of context.

In BS7671:2008 it says "Joints shall not be made in cables except where necessary as a connection into a circuit." however that only refers to exhibitions, shows and stands, it is so easy to hunt the document and miss some preamble as to what this section is talking about. For years I thought a socket had to be at least a meter from a sink, it seems that was 14th edition although I don't have a copy to check.

And of course this is the problem we don't have a library of books to check regulations, we have to make a judgement is this dangerous, is it likely to become dangerous, or will the owner need to modify this in near future and should he be warned.

New showers invariably say RCD must be fitted, and the regulations have said for many years manufactures instructions should be followed, so even if designed in 1960, when fitting a new shower a RCD needs adding, same with boilers, and many other items. I really did expect my cooker with induction hop to say RCD must be fitted but no.

Personally what at 13 years old, (he is over 40 now) my son started to study to be a radio ham, I felt I wanted to protect him, so since around 1992 my house has been RCD protected, however father-in-laws house was sold last year and still had no RCD's fitted and it was him who got me to fit them to protect my son. This house was quickly changed to all RCBO, again I think that makes sense. But I can't give a house a C2 for no RCD however much I like them unless TT.

I never said it was easy but can be easily simplified by upgrading as much as possible which I’m a firm believer of, I can’t give you quotes or reasons to justify my opinion and personal beliefs but I don’t see how you can be happy with a 40,50 year old install number of issues normally no RCD protection being one, especially with sockets having potential to be used for outdoor use. Undersized tails, Earth, bonding. Whole house being on one ring main. 300mm is the required minimum distance from sink or drainer. I know some of this does not mean a C2 or C1 but it’s due an upgrade isn’t it

 

[Ian1981]

You inspect and test to the current edition of the wiring regulations, this is echoed in such guidance as , gn3, electrical safety first best practice guide 4, practically every guidance resource out there, when it was designed has little relevance, it’s safe for continued use or it’s not.
Most non compliance’s will attract a C3 if things like rcd protection in bathrooms is not present, this was not a requirement years ago but it is now an improvement of safety practice and must be recorded as an improvement of safety on the report.
imagine not coding this because the 15 the edition when the installation was designed to did not require it, what is the point of there being a C3 code in the wiring regulations?
To think this would be acceptable is negligent on the inspectors behalf.
Obviously there is no requirement to upgrade an electrical installation to the current edition, there can’t be, you’d be constantly upgrading things, this is what it means when the regulations comment that older installations designed to bs7671 may not necessarily be unsafe, things like plastic Cu’s are an example of this, where not enclosed in a non combustible cabinet, lack of additional protection for cables buried in wall etc.

 

[Vortigern]

Introduction to all regs really;
The Regulations apply to the design, erection and verification of electrical installations, also additions and alterations to existing installations. 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.




Regs 651.2
NOTE 2: Existing installations may have been designed and installed to conform to previous editions of BS 7671, applicable at the time of their design and erection. This does not necessarily mean that they are unsafe.

By all means comply with the current edition, but fully comply! The above is in the 18th edition. Too many persons of doubtful character insist items must be upgraded.
Personally I would rather (and happily) salvage what is good and improve an existing installation where it manifestly tests out well. In fact it really annoys me on one job the client wanted me to test their light circuit, I did and found >2Mohm etc. and stated it was good for continued use but may be at it's end of life within a couple of years. Another spark, Long intake of breath, "needs replacing sir" (lie!), and I get pilloried by the client for not telling them that!

 

[Ian1981]

All the regulations are saying is that you do not C2 every non compliance with bs7671 because older installations cannot possibly fully comply so it avoids unnecessary works being carried out.

 

[Simon47]

I never said it was easy but can be easily simplified by upgrading as much as possible which I’m a firm believer of ...

I'll preface this by saying that I could be wrong - I'm prone to missing nuances in communications.

But what your post says to me is that you are one of the charlatans who have decided not to make the effort to learn the regs or to think, you just go in and do the "<sucks through teeth>You need a new CU mate, that'll be £X". You don't design an installation, you apply the rules of thumb from the on-site guide and assume it'll all be OK; you don't think about any deviation from current regs and assess whether it's actually a safety issue, you just tell the customer they need to be upgraded.
As I said, I could be wrong - but your post comes across as indicating that you are the sort of person that shouldn't be doing EICRs, or advising anyone else how they should be done.

No offence intended - it's just how I read you post.

 

[EricMark]

I must admit I see a problem in using old editions of wiring regulations, one is you don't have them to check on, and two you often don't know the age of the installation. We should get the last EICR before we start, and that should tell us if any new work has been done since last inspected, and show once we do our own inspection and test if anything has degraded.

I can see the point in the absence of the previous EICR may be we should assume new, and that the report is being used by the LABC inspector to verify it has been installed to current standards.

However all the deviations should get a C3 unless ‘Potentially dangerous’. Urgent remedial action required. And so the question arises even if a new installation does the lack of RCD protection with a TN supply make the installation potentially dangerous? either it does or it doesn't it does not really matter when installed.

So look at another deviation from the British wiring regulations, let us say some one who is continually moving between Germany and Britain wants a house built with all German sockets, this does not comply with British wiring regulations, however the Part P document says to a relevant standard, so there is nothing stopping one from following German regulations, bit of a problem reading them as don't read German, and can't use a scheme membership to say the comply, it would need a completion certificate, however it is permitted under British law.

My point is we need to look for it being potentially dangerous rather than not complying with British regulations it would need to comply with CENELEC harmonization documents, but not British.

So if a German firm decide it wants 5 houses made available for its key workers in the UK with German sockets it can have them built, and I have been to UK houses built for USA serviceman again to USA standards, with 120 volt outlets, never tested the frequency before you ask. And this is permitted.

So clearly an EICR does not need to follow the BS 7671, and where the electrical safety council say in their best practice guide we should not issue a C2 I think one needs a very good reason to say otherwise.

 

[davesparks]

So clearly an EICR does not need to follow the BS 7671, and where the electrical safety council say in their best practice guide we should not issue a C2 I think one needs a very good reason to say otherwise.

An EICR is a part of BS7671, the standard defines what an EICR is and it is a report on an installation in accordance with BS7671.

The electrical safety council is a self titled entity which has no real power in the industry.

 

[westward10]

There seems to be two sides of the coin with people who carry our EICRs. One side you have competent people with knowledge and experience who require no Guides and may only occasionally refer to BS7671. The other side are those who overcomplicate matters by referring to Guides and doubting what is required from BS7671, this is lack of knowledge and competence derived from taking a testing qualification and thinking it opens the door to ability. We are now seeing this other side on here on a frequent basis.

 

[Ian1981]

There seems to be two sides of the coin with people who carry our EICRs. One side you have competent people with knowledge and experience who require no Guides and may only occasionally refer to BS7671. The other side are those who overcomplicate matters by referring to Guides and doubting what is required from BS7671, this is lack of knowledge and competence derived from taking a testing qualification and thinking it opens the door to ability. We are now seeing this other side on here on a frequent basis.

Nail hit on the head there!

 

[UKPN]

I would say the whole problem is the EICR was never intended to be used to show if a property can be rented out, if to fit a new socket I will need to have a new consumer unit fitted, I need to know. I need to know what needs to be done to comply with current edition, so yes it is done to current edition.

There is a problem in I don't have a copy of the 14th Edition so I could not say if the property complied with it or not. This is from 17th Edition don't have 18th to hand.


Note the word "designed" so that quote says it does comply with 17th Edition if designed before 30st June 2008 and complied with edition current at the time.

C1, C2, C3 do not say does not comply with regulations, it says how dangerous it is, there was a 4 which said complies with previous edition, but that was scrapped. So ' Danger present. Risk of injury. Immediate remedial action required.' is the same what ever edition one is using. The same with 'Potentially dangerous - urgent remedial action required.' if it is potentially dangerous then that can't change depending on which edition. 'Improvement recommended.' however will depend on the edition used.

So the big question what makes some thing which was not potentially dangerous in 1992 when BS 7671 first came out, potentially dangerous today? The answer must be the equipment used today which was no available in 1992, so what we are looking at is the switched mode power supply, in 1992 we would transform voltage then regulate there were very few items which rectified mains, so the only change that I can see is the types of RCD used to protect with a TT supply. So I can see a good reason to issue a C2 when the RCD used on a TT supply is type AC. That is about the only thing which in 1992 was safe but in 2018 is not safe.

Can anyone think of anything else which is not safe today but was safe in 1992?

C2 does not mean does not comply with BS 7671:2018 it means potentially dangerous, and over the years the electrical characteristics of properties change, be it the water pipes changed to plastic, or the switch plates changed to metal, or even the supply voltage dropped from 250 to 230.

If I as an electrician but not a member of any scheme do any electrical work I need to issue a minor works or installation certificate, and if any of that work is on the list of notifiable work I need to inform and pay the LABC fee before I start, which is little more than a tax, the law has changed slightly in now in England I need to hold a level 3 or higher qualification, in Scotland seem to remember I must have attended a course in last 5 years, but in essence since I have passed my C&G 2391 I can if I got some professional indemnity insurance start doing EICR's which are legal. I can't issue a compliance certificate or a completion certificate, but I can make a report.

It seems SSE have an insurance, which for under £70 a year covers the house holder for any repairs to the electrical installation and there is a full report made before they take on the property and a yearly check done. Read about it on another forum, and the home owner was adamant his house was OK as nothing had been reported wrong, he has a TT system with a 100 mA RCD with no type marked on it. We were trying to tell him he needed a 30 mA RCD before fitting a new 9.5 kW shower, and the Wylex fuse board although the fuses had been replaced with MCB's was also past its use by date.

So most electricians do not want to end up in court, so we play safe, at least I do, and as far as an EICR goes that means following the electrical safety councils best practice guide even if I don't agree with it, I want to if I have to stand up in court to say I followed the recommendations. And to be frank I have all RCBO protection in my house, so to say to some one else you don't need it does not some how ring true, I made a mistake and thought I was fitting type B as that is what is said on the boxes, seems fitted type AC, so I have ordered 2 type A to replace those feeding the sockets.

So if you go into a property with those silly power line units fitted on a TT supply, do you give it a C2 unless fitted with type F RCD? If not why not?

What a load of bull!