D
DRG
As MDJ said; I worked with a lad in his 40's in the same sort of situation (no nvq3 but no 2391 either). He was time served etc but one of the qualified supervisors just wrote a letter of recommendation saying he has proven he is competent to do the job by the years put in and standard of work done etc. The lad got a card graded Electrician but they said he had to do his NVQ3 before he needed another card.
This was pretty recent so hope it helps you out in some way
This was pretty recent so hope it helps you out in some way