Off-peak consumer for storage heaters EICR

[Weebobz]

Off-peak consumer board supplying storage heaters has no RCD protection. Does this require upgrading to comply with latest landlord regulations.

 

[westward10]

Have you had an EICR done or are you doing an EICR?

 

[westward10]

Hello?

 

[Weebobz]

Have you had an EICR done or are you doing an EICR?

Doing

Hello?

Difference of opinions between two testers, my understanding is this should be renewed and come March this year will become mandatory for all rental properties that all Electrical circuits are RCD protected.

 

[timhoward]

understanding is this should be renewed and come March this year will become mandatory for all rental properties that all Electrical circuits are RCD protected.

We inspect against current regs.
So what in the current regs requires them to be RCD protected? They are not domestic lighting, not sockets, and not outside.
Often the only grounds for C2 would be impact protection for cables buried in walls <50mm which is normally difficult to determine on an EICR and no one has managed to drill into them yet!
Unless I have a good reason they are normally a C3 for me.

What new legislation is happening in March?

 

[mainline]

We inspect against current regs.
So what in the current regs requires them to be RCD protected? They are not domestic lighting, not sockets, and not outside.
Often the only grounds for C2 would be impact protection for cables buried in walls <50mm which is normally difficult to determine on an EICR and no one has managed to drill into them yet!
Unless I have a good reason they are normally a C3 for me.

What new legislation is happening in March?

From 01/03/2024 a key requirement is that all electrical installations must be protected by a residual current device (RCD). This is part of many other electrical requirements in rented properties in Scotland.

 

[Weebobz]

We inspect against current regs.
So what in the current regs requires them to be RCD protected? They are not domestic lighting, not sockets, and not outside.
Often the only grounds for C2 would be impact protection for cables buried in walls <50mm which is normally difficult to determine on an EICR and no one has managed to drill into them yet!
Unless I have a good reason they are normally a C3 for me.

What new legislation is happening in March?

All landlords have a legal obligation to ensure their property meets the Repairing Standard at the start of a tenancy and at all times during a tenancy. From 1 March next year (2024) the Repairing Standard is being changed to add the following requirements:-

• water pipes must be free of lead (where this cannot be ascertained water testing must be carried out to check for the presence of lead piping)
• electrical installations must be protected by a residual current device (RCD)
• properties must have a fixed space heating system (a permanent installation in the property which is plumbed or hard wired and capable of maintaining a temperature of 21⁰C in at least one room and 18⁰C elsewhere, when the outside temperature is minus 1⁰C.)
• installations for fuels other than gas and electricity to be in a reasonable state of repair and in proper working order
• any common parts pertaining to the property must be able to be accessed and used safely
• the property must have satisfactory provision for, and safe access to, a food storage area and food preparation space
• where the property is in a tenement, common doors must be secure and fitted with satisfactory emergency exit locks and a secure entry system

 

[timhoward]

From 01/03/2024 a key requirement is that all electrical installations must be protected by a residual current device (RCD). This is part of many other electrical requirements in rented properties in Scotland.

All landlords have a legal obligation to ensure their property meets the Repairing Standard at the start of a tenancy and at all times during a tenancy. From 1 March next year (2024) the Repairing Standard is being changed to add the following requirements:-

I'm still researching, but that appears to be the headline, and the detail seems to be:

D.55
In order to comply with the Repairing Standard, there must be one or more Residual Current Device (RCD) with rated residual operating current not exceeding 30 mA in the main or principal consumer unit. Normally, as a minimum, this will cover the socket-outlet circuit. However, the protection requirements will vary depending on the installation in the let property. As set out in D.60 – D.73, in order to comply with the Repairing Standard, landlords should ensure that an EICR is completed every five years. The EICR assesses the installation against BS 7671. This British Standard includes the requirements for RCD protection. Therefore, landlords should refer to the EICR report for the appropriate RCD protection for their installation. The absence of an RCD means that the house does not comply with the Repairing Standard.

Source: The Repairing Standard Statutory Guidance - https://www.gov.scot/publications/repairing-standard-statutory-guidance-private-landlords/pages/16/

To me, at face value, it is saying that socket circuits need protection, and an EICR against BS7671 applies for the remainder?

 

[Weebobz]

I'm still researching, but that appears to be the headline, and the detail seems to be:

D.55
In order to comply with the Repairing Standard, there must be one or more Residual Current Device (RCD) with rated residual operating current not exceeding 30 mA in the main or principal consumer unit. Normally, as a minimum, this will cover the socket-outlet circuit. However, the protection requirements will vary depending on the installation in the let property. As set out in D.60 – D.73, in order to comply with the Repairing Standard, landlords should ensure that an EICR is completed every five years. The EICR assesses the installation against BS 7671. This British Standard includes the requirements for RCD protection. Therefore, landlords should refer to the EICR report for the appropriate RCD protection for their installation. The absence of an RCD means that the house does not comply with the Repairing Standard.

Source: The Repairing Standard Statutory Guidance - https://www.gov.scot/publications/repairing-standard-statutory-guidance-private-landlords/pages/16/

To me, at face value, it is saying that socket circuits need protection, and an EICR against BS7671 applies for the remainder?

For me as the off peak consumer unit is a standalone board with no RCD, then we do not comply to the repairing standard as of March this year. As stated

The absence of an RCD means that the house does not comply with the Repairing Standard.

 

[timhoward]

For me as the off peak consumer unit is a standalone board with no RCD, then we do not comply to the repairing standard as of March this year. As stated

For me, the off peak consumer unit is not the "main or principle consumer unit".

I have seen quite a few situations where over-zealous application of latest regulations against a budget has actually left things in a more dangerous condition dur to poor workmanship and materials.
I'm obviously not saying you would do that, but if everyone in Scotland changes every off-peak board then I bet the number of consumer unit fires will go up next year.

 

[Weebobz]

For me, the off peak consumer unit is not the "main or principle consumer unit".

I have seen quite a few situations where over-zealous application of latest regulations against a budget has actually left things in a more dangerous condition dur to poor workmanship and materials.
I'm obviously not saying you would do that, but if everyone in Scotland changes every off-peak board then I bet the number of consumer unit fires will go up next year.

This is a good point, but surely still requires a EICR to BS7671, which previously hadn't been captured by the person who tested the house back in 2020. For me a C3 code is suffice as you have highlighted its not as clear cut as I first presumed.

 

[timhoward]

still requires a EICR to BS7671, which previously hadn't been captured by the person who tested the house back in 2020. For me a C3 code is suffice as you have highlighted its not as clear cut as I first presumed.

From BS7671's point of view, RCDs can be required for fault protection, impact protection, or additional protection.
It can often be a reasonable limitation of the EICR (front page) that they aren't going to excavate every wall to check the depth of buried cables, meaning Impact Protection would have to be very obviously deficient to code it.
It's quite likely that for the storage heaters the installation meets the current regs for fault protection and additional protection (section 411.3)
So I do actually find it completely plausible that a sparks who understands the regs might not code it at all.

 

[Weebobz]

From BS7671's point of view, RCDs can be required for fault protection, impact protection, or additional protection.
It can often be a reasonable limitation of the EICR (front page) that they aren't going to excavate every wall to check the depth of buried cables, meaning Impact Protection would have to be very obviously deficient to code it.
It's quite likely that for the storage heaters the installation meets the current regs for fault protection and additional protection (section 411.3)
So I do actually find it completely plausible that a sparks who understands the regs might not code it at all.

Missing the board out completely from the EICR though is non compliant.

 

[ukiri]

Timhoward didn`t say miss the board off the eicr , he said it might not required a code.

 

[Weebobz]

Timhoward didn`t say miss the board off the eicr , he said it might not required a code.

Never said he did?