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?
[automerge]1595282287[/automerge]

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!