FIRE RATED DOWNLIGHTS AND PLASTIC CCU - WHAT SIDE OF THE FENCE?

[NICKYNUNN]

Hi all, about to do a condition report on a grade 2 listed 4 bedroom property, the owner is moving and wants to rent it out. The consumer unit is a PLASTIC split board RCD sited in a cupboard under the only set of stairs .The board and installation is neatly installed (even the bonding cables were clearly marked!).
There are also about 40 downlights at the job, the majority of which arent fire rated.
I need to produce a solid bit of legisaltion/documentation to show the customer ( and to inform myself) if it is necessary to change the downlights for fire rated ones (I think they should be) and if it necessary to change the plastic DB to a metal one (I'm not as sure about this).
Looking online at information from electrical sites and from Landlord sites there seems to be alot of conflicting information. Other sparks I talk to give different answers.
I know what SHOULD be done regarding the downlights but I need something solid in black and white to show the client ,who isn't keen on changing them all.
Any opinions greatly appreciated , any direction towards solid documentation appreciated even more

 

[telectrix]

the plastic CU is a C3.

if the house is 1 family occupied , (no rented out flat above sort of thing), then the whole house is a single fire compartment and fire rated downlights are not required by any legislation. desirable, but not mandatory.

 

[DPG]

You can't really try and force the customer to change 40 downlights.

 

[telectrix]

i'd be more concerned if some cretin might fit the downlights with halogen bulbs.

 

[westward10]

If you are undertaking an EICR the answers to these questions should already be in your head.

 

[Dustydazzler]

I don't know what so many people get their knickers in a knot about plastic insulated consumer units, they aren't electrically dangerous. If I were undertaking considerable work at the property I might recommend it be upgraded but apart from that its a simple observation on the condition report.

Non fire rated DLs is a funny one, Drop afew down and check the overall condition. Quite often the cables above are brittle from years of heat. Likewise often the lights are situated tight against a joist which is all black and scorched. In this situation it is recommended they need repositioning. I have never had a customer refuse an upgrade on the lights if the old ones look all burned and toasty.

 

[timhoward]

I think 'll risk offending the OP by asking, are you aware of best practise guide 4? It's a helpful document if you are at an earlier stage of the never-ending journey of refining the art of EICRs.
( https://www.electricalsafetyfirst.org.uk/media/2149/bpg4-1.pdf )

Regarding downlights, I'm mainly looking for cables lying straight over them, obvious signs of heat damage, poor condition of wiring, and single insulated cables entering them. Question in my mind is "am I willing to put my name to this being safe". It's quite rare for downlights to warrant C2 if the above are all fine. If it's a HMO then a bit more to think about.

 

[NICKYNUNN]

the plastic CU is a C3.

if the house is 1 family occupied , (no rented out flat above sort of thing), then the whole house is a single fire compartment and fire rated downlights are not required by any legislation. desirable, but not mandatory.

Thank you, how would you code the non fire rated downlights?

 

[NICKYNUNN]

I think 'll risk offending the OP by asking, are you aware of best practise guide 4? It's a helpful document if you are at an earlier stage of the never-ending journey of refining the art of EICRs.
( https://www.electricalsafetyfirst.org.uk/media/2149/bpg4-1.pdf )

Regarding downlights, I'm mainly looking for cables lying straight over them, obvious signs of heat damage, poor condition of wiring, and single insulated cables entering them. Question in my mind is "am I willing to put my name to this being safe". It's quite rare for downlights to warrant C2 if the above are all fine. If it's a HMO then a bit more to think about.

Thanks,I'd really like to change all the down lights to fire rated, but unless I can show the client in a simple "you can/you can not " document then shes not gonna go for it,as it will be a big additional cost.I was wondering if the fact that this will be a privately rented property will have any baring on the coding?.
Im gonna give best practise 4 another read, I'm sure there isnt a hard clear rule.
Should/could the non fire rated downlights then be coded as a C3 ?

 

[NICKYNUNN]

If you are undertaking an EICR the answers to these questions should already be in your head.

The answers are not in my head, I haven't under taken the work yet.I'm asking for other peoples opinions?
How do you code these?

 

[NICKYNUNN]

You can't really try and force the customer to change 40 downlights.

Im not trying to force anything, what would you code the downlights as?

 

[DefyG]

Wouldn't unless evidence of thermal damage, (connector blocks burnt/melted for example)! Incorrectly fitted, incorrect lamps, surroundings burnt?

Should/could the non fire rated downlights then be coded as a C3 ?

No the fittings themselves aren't a problem if correctly installed.

 

[NICKYNUNN]

Wouldn't unless evidence of thermal damage, (connector blocks burnt/melted for example)! Incorrectly fitted, incorrect lamps, surroundings burnt?

No the fittings themselves aren't a problem if correctly installed.

Thanks

 

[NICKYNUNN]

9 out of 10 sparks Ive spoken to say C2 for non fire rated downlights and C3 for plastic board.
I'm pleased I asked on here, I appreciate all the advice.

 

[NICKYNUNN]

Just noticed NAPIT code breakers have it as a C2.
They say "no fire hoods fitted on open back downlights with room above" C2
C3 if there is no room above
??????

 

[timhoward]

As a Napit member, my considered opinion is that the book you mention is only fit for one purpose....

 

[NICKYNUNN]

As a Napit member, my considered opinion is that the book you mention is only fit for one purpose....
View attachment 89661

haha

 

[NICKYNUNN]

So apart from the respected opinions of electricians,which is appreciated, and the advice given in Napits code breakers(not respected by all), there is no bit of literature that says for definite,it simple terms that non fire rated downlights are or are not permissible when carrying out a condition report.

 

[timhoward]

As far as I know BS7671 isn't anywhere near that specific. In a nutshell the luminaire must be suitable for the location.
Have a gander at regs 422.3.1, 422.3.8 and 559.4.1
For purposes of an EICR judgement about whether it's potentially dangerous is mainly down to factors mentioned earlier.

A completely separate question is whether the ceiling needs to be fire resistant (FR), as Tel was saying earlier. If the property is divided into multiple dwellings i.e. flats then the fire rated downlight topic comes into play.
A house rented as a whole doesn't come into this category. (A house of multiple occupation has many extra requirements regarding fire safety but not fire retardant ceilings to the best of my knowledge)

 

[NICKYNUNN]

As far as I know BS7671 isn't anywhere near that specific. In a nutshell the luminaire must be suitable for the location.
Have a gander at regs 422.3.1, 422.3.8 and 559.4.1
For purposes of an EICR judgement about whether it's potentially dangerous is mainly down to factors mentioned earlier.

A completely separate question is whether the ceiling needs to be fire resistant (FR), as Tel was saying earlier. If the property is divided into multiple dwellings i.e. flats then the fire rated downlight topic comes into play.
A house rented as a whole doesn't come into this category. (A house of multiple occupation has many extra requirements regarding fire safety but not fire retardant ceilings to the best of my knowledge)

Thanks for that, I appreciate you taking the time. I will go and have a look at those Regs.

 

[westward10]

Fire protection in listed buildings is of high priority and although the existing ceilings if original or even sympathetically replaced may offer limited protection there may well be retrofitted fire protection you cannot see above them. It is important to know if these light fittings are compromising the fire protection of this building.

 

[DPG]

Im not trying to force anything, what would you code the downlights as?

I wouldn't, assuming they are fitted correctly.

 

[Pretty Mouth]

As others have pointed out, non fire rated downlights are okay in some situations, but not in others. If a downlight is installed in a ceiling that is a fire barrier between 2 fire compartments, then it should be appropriately fire rated.

It's not always obvious if a ceiling is a fire barrier, but there may be clues, eg. ceiling is double plasterboarded, is there a fire door somewhere between the downstairs and upstairs rooms separated by the ceiling, different dwellings and so on.

There is a little bit of info in the Electrician's Guide To The Building Regs (10.2.3, and appendix D in the 17th edition, I need to update). Also, there is an excellent youtube vid by John Ward that you will find very useful:

 

[telectrix]

Thank you, how would you code the non fire rated downlights?

no code unless there's problems like thermal damage, exposed inner insulation, etc.

 

[NICKYNUNN]

As others have pointed out, non fire rated downlights are okay in some situations, but not in others. If a downlight is installed in a ceiling that is a fire barrier between 2 fire compartments, then it should be appropriately fire rated.

It's not always obvious if a ceiling is a fire barrier, but there may be clues, eg. ceiling is double plasterboarded, is there a fire door somewhere between the downstairs and upstairs rooms separated by the ceiling, different dwellings and so on.

There is a little bit of info in the Electrician's Guide To The Building Regs (10.2.3, and appendix D in the 17th edition, I need to update). Also, there is an excellent youtube vid by John Ward that you will find very useful:

Thanks for that

 

[brianmoooore]

As others have said, C3 for the plastic CU and no code for the downlighters, but I would make a strong recommendation in the notes that they are changed for fire rated versions. I've come across the odd mouse's nest built over a nice warm downlight, featuring pieces of nice dry paper.

 

[Pretty Mouth]

It's also worth mentioning that not all fire rated downlights are enclosed, can-type ones. Integral Evofire for example are fire rated, but open backed:

Integral LED Evofire IP65 Fire Rated Downlight

This fire-rated downlight fitting is ideal for installing a GU10 or MR16 LED lamp in a ceiling. It's built to a fully open design, which means there's no metal canister to trap the heat generated by the lamp. This helps to give the light a longer lifetime as well as improving its performance...

www.toolstation.com

 

[loz2754]

There seems to be a bit of confusion as to the purpose of installing fire rated downlights.

Some seem to have got hold of the idea that a fire rated downlight is needed to prevent a fire starting within or around a downlight. This is not the case.

The purpose of a fire rated downlight is solely to maintain the integrity of the fire barrier that has been penetrated by the insertion of the said light fitting, in order to prevent the spread of fire between the fire compartment below the ceiling, to another fire compartment above the ceiling.

In a normal domestic property, there is only one fire compartment, ie the whole building, therefore no fire rated downlights will be necessary.

The situation is different in special cases, for instance, as @westward10 mentioned, if it's a listed building, or if the building is an HMO.

Having said all of that, I personally always fit fire rated downlights, because it makes sense to do so. But there is no regulation, electrical or building, that can be cited in order to enforce them in most domestic properties.

 

[NICKYNUNN]

There seems to be a bit of confusion as to the purpose of installing fire rated downlights.

Some seem to have got hold of the idea that a fire rated downlight is needed to prevent a fire starting within or around a downlight. This is not the case.

The purpose of a fire rated downlight is solely to maintain the integrity of the fire barrier that has been penetrated by the insertion of the said light fitting, in order to prevent the spread of fire between the fire compartment below the ceiling, to another fire compartment above the ceiling.

In a normal domestic property, there is only one fire compartment, ie the whole building, therefore no fire rated downlights will be necessary.

The situation is different in special cases, for instance, as @westward10 mentioned, if it's a listed building, or if the building is an HMO.

Having said all of that, I personally always fit fire rated downlights, because it makes sense to do so. But there is no regulation, electrical or building, that can be cited in order to enforce them in most domestic properties.

Thanks, good to get confirmation that there is no regulation that I may be disobeying. When I started reading into it , the literature was more about the fire integrity of the floor/ceiling with little mention of the lights themselves being burning hot little things sat in among all the tinder crap you can often find under floor boards.
The codebreaker book must responsible for alot of non fire rated downlights being ripped out, certainly when Ive worked helping out on EICRs this has been the case.

 

[loz2754]

Just noticed NAPIT code breakers have it as a C2.
They say "no fire hoods fitted on open back downlights with room above" C2
C3 if there is no room above
??????

1. This does not directly reference whether or not the lights themselves are fire rated. (As has been mentioned by @Pretty Mouth , some open back downlights are fire rated)

2. The bit about "the room above" only applies if the room above constitutes a separate fire compartment, which the book fails to point out.

The problem with the Codebreakers book is that it is only a compilation of opinions, with no real explanations given, and mostly vague references to regulations. It can be useful, but like any such opinions, needs to be taken as advice only, and not rigid rules.

(And yes, I do own a copy and have read it through from cover to cover, making notes of my disagreements and actual errors found)