Minor Works Certificate – Details of Departures from BS7671?

Discuss Minor Works Certificate – Details of Departures from BS7671? in the Electrical Wiring, Theories and Regulations area at ElectriciansForums.net

C

cookiemonster

I had my assessment for joining the competent persons scheme with NICEIC last week. I showed the inspector my first job – one a full rewire with accompanying brand new 17th edition board – passed with flying colours. I then showed the inspector my second site which was the addition on a single socket outlet to the ground floor ring main wired as a spur off an existing kitchen socket. So as an extension to a special location this is a notifyable minor works. So we walked around the kitchen and he examined my handiwork and he seemed impressed. we discussed the issues I had encountered along the way which included discovering that the ring was a broken ring when I tested the circuit and that I had pinpointed this to an outlet that presumably had fed an extractor fan above hob in years gone by. So in fitting and testing this circuit and fixing the broken ring circuit I had arguably made this installation safer. The inspector asked had the circuit passed all circuit tests and I said yes.

So then the inspector starts to examine the paperwork. We get to the box entitled “Details of Departures, if any, from BS 7671”. I here I had put “Two different wire colouring systems in use. Consumer unit pre-dates BS7671 – 17th Edition”. All apparently good so far; he reads on. Then in the Comments box I had put that I had advised the customer that the circuit should really be protected by an RCD. At this point the inspector looks up and asks “is there no RCD on this circuit then?” No as stated on the Details of Departures the consumer unit pre-dates BS7671 – 17th Edition and it doesn’t have an RCD fitted. In fact the consumer unit wasn’t even a split board with a single RCD on let alone split with 2 RCD’s on as per 17th edition. “oh dear” says inspector “that’s not good, not good at all”. It dawned on me that he was trying to tell me that due to the lack of an RCD I’d failed my assessment. Ouch.

The fact that I was going to have to find another £450 quid to be re-tested didn’t exactly endear me to the inspector but truth be told the inspector had been very helpful and friendly and had only highlighted my mistake, so really I’ve got no grounds to knock the bloke.

However, this does raise some issues. I asked the inspector what my options were to put this right. He said I could either fit an RCBO to that circuit – well this was an old Contactum board and the current RCBO’s are not compatible with this old board which is fitted with 60898 mcb’s because where they attached to the bus bar doesn’t line up with the old bus bar positioning. Or failing that I could take a feed of the existing B32 mcb out to a single way RCD protected consumer unit and fit this next to the existing consumer unit. In an ideal world I should update the consumer unit to a 17th edition one. In essence because I was adding a socket to an existing circuit the entire circuit had to bought upto current BS7671 standards e.g. must be 17th edition compliant.

Anyway what I am most curious about is what is the little box on the Minor Works Certificate entitled “Details of Departures, if any, from BS 7671” box there for if no departures are allowed? Or put another way why is a departure in the form of old wiring colours an allowed departure but the absence of an RCD isn’t? Where is the published list of allowable departures and not allowable departures in the 17th Edition? Surely the fact that the inspector seems to be suggesting that an RCD should be incorporated retrospectively whenever a socket outlet is added to an existing circuit on a non 17th edition board then this means that every time we encounter this situation then a consumer unit update is prescribed? In which case what is the point of the Minor Works Certificate for any minor job other than to an installation which already has a current 17th edition consumer unit. Is the Minor Works Certificate relevant to any work carried out to circuits connected to non 17th Edition boards?

This doesn’t seem to make sense to me. Surely you can have a socket outlet fitted to a circuit on a pre-17th edition without having to fit either an RCBO (if the board will accept one) or fit a single way RCD protected consumer unit just for that circuit or update to a 17th edition consumer unit.

In the real world a customer phones me up to ask me to fit an single additional socket outlet to an existing circuit. I arrive and discover that they don’t have a 17th edition board. In fact they don’t even have a split board so it’s not possible to add an RCD to cover all circuits as it not allowed under 17th edition for failure of any one circuit to affect all other circuits. Adding a socket means in most scenarios that a consumer unit change is required. The customer might conclude that I may just be a cowboy builder who is trying to sell him a consumer unit he doesn’t need and tell me to get on my bike. I walk away and he gets to live with his non-RCD protected circuit for a few more years or worse still has a bash at doing the work himself ?

Also it seems a bit strange that as long as I make sure the circuit I work on is complaint (by just fitting an RCBO or single way consumer unit to that circuit only) then I could walk away from the job in the knowledge that the upstairs ring main was non’RCD protected and therefore non compliant and therefore deemed unsafe.

In the instance of my socket outlet circuit with no RCD protection this circuit had passed all other tests obviously including the all-important IR and Zs tests.

Have I got this wrong? I’d be really interested to hear other folks thoughts on this one if you can help. Many thanks,
 
You are a very lucky lad to have a guy pass you on this. Reg 411.3.3 tells you that sockets not under the supervision of a skilled or instructed persons and is under 20amp have to have additional protection of an RCD. So that single spured socket you fitted had to have RCD protection, A lot of sparks fit a RCD FCU and then the socket to comply.

In the 1st amendment to the regs there are proposals that on a MEIWC the use of RCD can be omitted when the designer deems it is not neccessary to fit one, but that is in the future, if it is included, which it still may not.

You have to remember that the existing installation is not retroactive, but any work you do should conform to the BS 7671-2008, that extra socket therefore had to be RCD protected as it stands today
 
I take your point regarding the upstairs ring being non compliant but on a PIR that would really only warrant a code 4 if you go by ESC guidelines.

Like Malcolm says, with the exception of earthing & bonding, it's YOUR work that must be compliant to the latest edition of BS 7671.

Can you use an RCD spur unit to feed your extra socket? Probably the cheaper and easier option.
 
If you are fitting a socket to a non rcd protected ring main, and you put a rcd protected fcu in to protect it, Surely thats no longer a minor works, as by putting in rcd protection in means that that the means of protection has changed from what is already there. So that makes it a notifiable job? together with the implications towards upgrading the earths to latest specs??
 
this is unfortunately what we are up against. The customers do not realise that when all they want is an extra socket with no rcd protection. and u quote lets say £200 plus due to bonding etc to comply, they automatically think that u are ripping them off! We do have to comply to bs 7671 and this sometimes loses us work, but doing it right is what we all face.
It is a difficult bit of red tape which frustrates everybody!
good luck with ur future sparking by the way!
 
Makes you wonder doesn't it, how did we all ever survive without all these RCDs on virtually very circuit these days.

A good number of us should be dead, if you listen to all these Reg's bible bashers...haha!!!
 
This is not a new problem just noticed more because of the need for RCDs. Every time the regs change and wiring carried out on a previous regs wiring, if you adapt it as you have you need to bring your work upto current standards. Something depending upon the view of inspector you may be ask to bring that DB up to standard.

If you wire your circuit back to its own Consumer Unit you can fit your RCBO and claim your install is seperate to existing but you may need to bring earthing up to date.

Bit of a pain and not want somebody doing it as a government job would done, but the NICEIC logo comes at a cost
 
If you were able to change your 60898 to an rcbo at this job would you then have to change your mwc to an eic or stick with the mwc?
 
rapier said:
If you were able to change your 60898 to an rcbo at this job would you then have to change your mwc to an eic or stick with the mwc?
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Technically an EIC as the characteristics of the whole circuit have been altered.

I'd argue against an EIC for an rcd spur feeding the additional wiring.
 
There's no real argument when it comes to RCD protection on socket outlets in domestic premises imo. Even under the 16th, any socket with potential out door use would of needed RCD protection, so that's a major non compliance to the NICEIC on an assessment.
 
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A couple of points.
Departures are not actually defects in the existing installation, they are intended departures by the designer, and must offer the same degree of safety as would be obtained by compliance with the Regulations.
With the requirement to RCD protect the socket-outlets, you could have installed RCD socket-outlets, or as has been suggested an RCD FCU. This would not have altered the CPD characteristics.
As for the existing bonding, the requirement used to be that the earthing and bonding arrangements had to be adequate. Now they only have to be adequate for the safety measure applied for the addition or alteration. Adequate doesn't necessarily mean compliance with current Regulations.
 
As spinlondon has said Departures are not just non-compliances but the use of say new innovations which had not been considered when the Regulations were published but which must afford an equivalent degree of safety as would compliance with the Regulations.
 
Even though you are only doing a 'minor works' job, that circuit you worked upon must be fully compliant with the 17th edition. (1st amendment after 1st Jan 2012). According to Regulation 120.3 of BS7671 'The resulting degree of safety of the installation shall be not less than that obtained by compliance with the Regulations'. By not fitting an RCD to the circuit, the circuit is less safe than full compliance with the Regulations (ie. fitting an RCD). Departures like use of old colours does not affect the safety of the circuit. To pass that minor works assessment, I believe you should have fitted an RCD protected socket outlet to every socket on that circuit but at almost £30 per socket it would work out quite expensive for the customer. Sounds crazy, but the regulations are regulations and non-compliance with the regulations means non compliance with the EWR 1989 which is statutory.
 
An interesting thread and as usual its obvious that we sparkies don't have a consistent view on the regs.

How for gods sake do the people who write the regs expect Joe Public to understand them if they make NO attempt to market and advertise these MOST COMMON situations. Its left to us to try and get things done to the regs and then the bloke down the pub comes and does what the client wants ignoring the regs all together.

Rant over.
 
kill the witch said:
Even though you are only doing a 'minor works' job, that circuit you worked upon must be fully compliant with the 17th edition. (1st amendment after 1st Jan 2012). According to Regulation 120.3 of BS7671 'The resulting degree of safety of the installation shall be not less than that obtained by compliance with the Regulations'. By not fitting an RCD to the circuit, the circuit is less safe than full compliance with the Regulations (ie. fitting an RCD). Departures like use of old colours does not affect the safety of the circuit. To pass that minor works assessment, I believe you should have fitted an RCD protected socket outlet to every socket on that circuit but at almost £30 per socket it would work out quite expensive for the customer. Sounds crazy, but the regulations are regulations and non-compliance with the regulations means non compliance with the EWR 1989 which is statutory.
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Don't forget that this is a domestic installation so is not covered by EAWR 1989.
 
Bit of an old thread being dragged up but the new Contactum CP range RCBOs are compatible with the older boards by the use of an adaptor that TLC sells. There's only just enough room at the top for cabling on the larger main units, I think not enough room on the garage size units.
 
A couple of interesting points have been raised here but there are obviously some conflicting views that need clarification.

Some have said that compliance can be attained by fitting a RCD FCU and spuring the socket off that, one person said that you would need to add RCD protection to all the existing sockets on the ring (via changing the sockets themselves to the type that incorporates an RCD) but what is most interesting, is that neither or those proposed solutions was suggested by the NICEIC bloke who was doing the assessment.

I guess what it boils down to is whether or not you interpret the rules to mean that if you add a socket to a cct, then you have to bring the entire cct up to current standards. It seems from what this particular assessor has stated that he falls squarely in that camp.

Clearly though, some people don't believe this is the case and just fit an RCD FCU and spur.

I'd just like to know the definitive answer.

Cheers
 
I guess it's open to interpretation.
In the introduction of BS7671, the second chapter states:
"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."
How would you interpret this chapter?
Then there are Regulations 632.4:
"Defects or ommissions revealed during inspection and testing of the installation work covered by the Certificate shall be made good before the Certificate is issued"
and 633.2:
"The contractor or other person responsible for the new work, or a person authorized to act on their behalf, shall record on the Electrical Installation Certificate or the Minor Electrical Installation Worcks Certificate, any defects found, so far as is reasonably practicable, in the existing installation."
If we are required to upgrade the existing installation, why would there be a requirement to record any defects found?

Why would we be required to record defects or ommissions in the existing installation, if we are required to upgrade the existing installation?
Especially as we are required to make good any defects or ommissions before issuing the Certificate.
 
You're spot on Spin, but in this case the OPs interpretation has cost him an additional £450, ouch.
I guess this proves you just need to be real careful with any jobs that you use as examples of workmanship, come assessment time.

So which camp to you fall in... Do you believe that adding an additional socket to a cct means you need to bring the entire cct up to regs, or only the socket you are presently installing?

Cheers
 
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One problem you have here is the use of the words "installation work" as a means of putting things in place and "installation" as the electrical system for the property (or the circuit).

When installing an additional spur socket you are only installing a length of cable, back box and socket face plate. One could then say that this is the installation to which the certificate refers and so only defects or omissions in the bit you installed (e.g. wrong polarity at that socket) must be put right.

However in order to test and inspect this section that you have installed, your testing must cover the rest of that circuit, at the minimum. It would not really be possible to only inspect that new cable and socket and state that it was compliant as you may have a broken ring etc. in the rest of the circuit.
So you may then find defects or omissions in the rest of the circuit, which, as they were determined during inspection and testing, should be put right.

Again if you are looking at the CU and see there are no RCDs and there is another domestic socket circuit, ahh is this part of an inspection? should it be put right! I think here this is not an inspection just an observation and would not need upgrading only noting as a defect of the existing installation on the certificate.

Overall I tend to think that any installation work done involves the whole circuit which has been modified and that this circuit should be to the standard of the current regulations. But practicality may intervene and say it is only the small section on which I am working that needs compliance, but may be difficult to justify.
 
Spin, This was just an example; but if you had a non continuous ring then you would have installed a spur on a series of spurs, as it is not designed as a radial circuit, and you would then be in non compliance with the regulations as a non fused spur must only have one socket outlet and you could have many (although I would say that that socket would be safe you could well overload the cable for the whole circuit depending on where the break was.)
 
When I test rings I always test L and N on the figure of eight right after L and CPC. It's a bit belt and braces but the risks involved in broken ring finals scares the hell out of me.
 
Richard Burns said:
Spin, This was just an example; but if you had a non continuous ring then you would have installed a spur on a series of spurs, as it is not designed as a radial circuit, and you would then be in non compliance with the regulations as a non fused spur must only have one socket outlet and you could have many (although I would say that that socket would be safe you could well overload the cable for the whole circuit depending on where the break was.)
Click to expand...
So the addition itself, would not comply, and you would either have to fix the Ring, or down rate the CPD.
Would lack of RCD protection to existing socket-outlets, or existing cables concealed in walls affect the safety of the spur, or whether the spur complied?
 
spinlondon said:
"The contractor or other person responsible for the new work, or a person authorized to act on their behalf, shall record on the Electrical Installation Certificate or the Minor Electrical Installation Worcks Certificate, any defects found, so far as is reasonably practicable, in the existing installation."
If we are required to upgrade the existing installation, why would there be a requirement to record any defects found?
Click to expand...

To me I would read that as the circuit which you are certifying by means of a Minor Electrical Installation Works Certificate must comply with the Regulations as they currently stand. You are also required to note any defects which you have noticed during the course of the installation work. These defects therefore will not apply to the circuit you are certifying but to other parts of the installation. You don't need to go out of your way looking for defects but if you notice them then there is a duty of care to report that to the client.

That's my reading of it anyway.
 
Would you be certifying the circuit, or would you just be certifying the addition?
If you were for instance to change a socket-outlet for whatever reason, would you then have to ensure the rest of the circuit complied with current Regulations?
 
Spin
"So the addition itself, would not comply, and you would either have to fix the Ring, or down rate the CPD." Yes
If you were to install the spur as an RCD socket, then the socket would comply, but if the cable you installed were in the wall, then that cable would not comply, easiest to provide an RCD at the origin of the circuit, though presumably if you were considering it was just the bit you did that needed to comply then you could install an RCD at the point were you took the spur out of the ring!
 
post 33 I would say you would be certifying the design and construction and inspection of the addition were OK and the testing of the circuit was OK. Because I would not expect to fully assess the existing wiring for safe zones, etc. only to perform the testing on the circuit and ensure that complies.
 
spinlondon said:
If you were for instance to change a socket-outlet for whatever reason, would you then have to ensure the rest of the circuit complied with current Regulations?
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Presuming you are referring to a like-for-like change then this would be maintenance work, and a Minor Electrical Installation Works Certificate would not be required, and as such you would not be required to certify compliance with BS 7671 in its current form.
 
Seems the thread is getting a going off in different tangents.
I'll try to put my point of view, and cover all the tangents.
The introduction indicates that existing installations do not have to be upgraded if they complied with earlier editions.
We are required to assess the installation before making any addition or alteration, to ensure that the rating and condition of existing equipment is adequate for the altered circumstances. To my mind, adequate does not mean 'comply with current Regulations'.
We are required during construction and on completion of an addition or alteration, to inspect and test to verify that the requirements of the Regulation have been met.
We are further required to issue appropriate certification. I am not aware that maintenance is excluded from these requirements.
We are required when certifying an addition or alteration, to note any defects (where reasonably practicable) in the existing installation.
The existing cables and accessories of a circuit would to my mind be part of the existing installation.
We are required to rectify any defects or omissions found in the work that the certificate relates to, before issuing the certification.
I do not see that this requires us to rectify any defects in the existing circuit, especially as we are required to note any defects on the certificate.
 
Fair enough, and I'm certainly not suggesting that you are wrong. Simply that I would interpret the requirements differently. Must have a look over the Guidance Notes etc. to see if they shed any light on the intentions of JPEL/64 (whilst acknowledging, of course, that they are simply an opinion and do not take the place of BS 7671).
 
spinlondon said:
Seems the thread is getting a going off in different tangents.
I'll try to put my point of view, and cover all the tangents.
The introduction indicates that existing installations do not have to be upgraded if they complied with earlier editions. Yes no problem
We are required to assess the installation before making any addition or alteration, to ensure that the rating and condition of existing equipment is adequate for the altered circumstances. To my mind, adequate does not mean 'comply with current Regulations'. I would agree with this
We are required during construction and on completion of an addition or alteration, to inspect and test to verify that the requirements of the Regulation have been met. Yes
We are further required to issue appropriate certification. I am not aware that maintenance is excluded from these requirements. Need the certification. I agree that BS7671 does not exclude this for maintenance (the word "may" is a bit unclear) however Part P guidance specifically states BS7671 does not require this only recommends.
We are required when certifying an addition or alteration, to note any defects (where reasonably practicable) in the existing installation. Yes
The existing cables and accessories of a circuit would to my mind be part of the existing installation.
Initially certainly, and certainly not designed or installed by you only modified.
We are required to rectify any defects or omissions found in the work that the certificate relates to, before issuing the certification. Yes for the work to which the certificate relates (but how do you separate an addition from the circuit it is attached to, particularly in testing?)
I do not see that this requires us to rectify any defects in the existing circuit, especially as we are required to note any defects on the certificate. Ah hmm Need to rectify defects in the existing circuit that would cause the addition to fail compliance and need to ensure existing circuit is adequate.
Click to expand...

You raise some interesting points there and have made me re read the regulations (I am currently referring to AMD1 because it is available). I think that you are right there, to comply with the requirements of the regulations you would need to ensure that the circuit containing the modification was adequate for the intended use of the modification and that the circuit allowed the modification to comply with BS7671 (current) but I would normally try to rectify any defects in a circuit that I have added to, where practicable. Although I would not route cables or change cables (for csa) so I would not necessarily be making the existing circuit up to BS7671.
Oh, I have changed my view on this!, I am quite surprised!
 
Do you not think the RCD situation is kinda unique? The regs are not retroactive, everyone knows that, but the case of providing RCD protection almost seems to be an exception to that.

As adding sockets to existing circuits is quite a common job, this is a situation that everyone is going to be faced with. As I said earlier, in the case of the OP, his assessor gave advice that indicated he considered that the whole cct needed to be protected, not just the new spur.

This certainly seems to be one of those situations whereby the customer is going to think that they are being taken for a ride, especially if their current setup, ccu wise, precludes the addition of RCDs or RCBOs. What started out as a relatively minor addition, now looks like a board change is required.
 
No I don't believe so.
I think most of the problems stem from either people not understanding the requirements for RCD protection, or if I were cynical, an attempt to obtain extra work.
 
I'm of the same opinion as spin that it is only your work that you need to certify and comment on that certification about the existing installation.

RFC are always a challenge and if your doing a job that is associated with them on a lot of older installations then you most often as not have problem of interconnected rings, etc etc. and what turns out to be an hours job often can unearth all sorts of problems.

I have always certificated with a MEIWC the work that I have done and noted any comments on the installation as I found. I often though rather than fit a RCD FCU for the extra socket, tried to fit a piggy back enclosure next to the main CU, if space permitted, and disconnected the RFC from the MCB/Fuse and fed the enclosure from the now empty way in the CU and re terminate the RFC into the RCD, cost wise there is little difference between an enclosure, RCD and a normal FCU and a RCD FCU, it will obviously entail a little more time but it will leave the installation in a better condition.

Of course this would entail you making sure that you have the correct polarity especially between N-E along the ring as often there maybe a JB hidden where this is reversed, if that is the cast then you have to go back to the original FCU RCD, but every job is different of course, which makes this so much fun.
 
malcolmsanford said:
Of course this would entail you making sure that you have the correct polarity especially between N-E along the ring as often there maybe a JB hidden where this is reversed, if that is the cast then you have to go back to the original FCU RCD, but every job is different of course, which makes this so much fun.
Click to expand...

But according to the OPs assessor (by his omission of mentioning it) the FCU RCD is NOT an acceptable option in this instance.
 
spinlondon said:
No I don't believe so.
I think most of the problems stem from either people not understanding the requirements for RCD protection
Click to expand...

And is it any wonder. I'm still no closer to understanding if an additonal socket added to a ring, or even a radial for that matter can comply with the regs by use of the 'FCU RCD' option.
My gut feeling, given what happen to the OP is that this is not an acceptable method.
 
IQ Electrical said:
Technically an EIC as the characteristics of the whole circuit have been altered.

I'd argue against an EIC for an rcd spur feeding the additional wiring.
Click to expand...

I changed a 60898 for a 61009 as part of a minor works job but issued an EIC due to the change of protective device.

My assessor said that was not needed and just a MWC would be enough. He said although I'm adding 30ma protection I'm not actually changing the characteristics of the protective device, still the same 6A and 6ka so MWC is fine.

I was surprised because I'm sure I was told different when I did my 2391
 
Overall I feel that the easiest thing to do is replace the MCB with an RCBO, if possible (not in this case) or fit an external RCD into the circuit as it leaves the CU as Malcolm suggests.

I believe (now) that you could also fit an RCD at the point of the start of your addition, to RCD protect the cable (if required) and the socket and comply with the regulations. Similarly if you did not need to RCD protect the cable then you could fit an RCD S/O. The first would be a real nuisance to do, however and is not usually the easy option.

The NICEIC inspector did not give this as an option but did not exclude it either, he only suggested three options that are the easiest to do (and give maximum safety for the circuit; why not protect the whole circuit? especially if it is easiest to do).
 
Richard Burns said:
Overall I feel that the easiest thing to do is replace the MCB with an RCBO, if possible (not in this case) or fit an external RCD into the circuit as it leaves the CU as Malcolm suggests.

I believe (now) that you could also fit an RCD at the point of the start of your addition, to RCD protect the cable (if required) and the socket and comply with the regulations. Similarly if you did not need to RCD protect the cable then you could fit an RCD S/O. The first would be a real nuisance to do, however and is not usually the easy option.

The NICEIC inspector did not give this as an option but did not exclude it either, he only suggested three options that are the easiest to do (and give maximum safety for the circuit; why not protect the whole circuit? especially if it is easiest to do).
Click to expand...

Richard,

There's no way what the inspector suggested is simpler than just fitting a RCD socket combo, so I don't believe that to be the case. I believe he suggested those options because, in his opinion, they were the only options open that complied with the regs. Alas however, he is not here to ask so we will never really know.

Maybe you can tell me something I have never been 100% sure about... Is the point of an RCD protected cct to provide sole protection for the devices plugged into it, or is it also supposed to provide some protection to the wiring that it supplies.... i.e provide protection against persons drilling into it, sawing through it etc.

Obviously if the former, then it could be argued that the RCD Socket combo addresses this, if it is the latter, then this would explain why the need to bring the whole circuit under RCD/RCBO protection.

Cheers
 
JamesBrownLive

An RCD S/O would not cover the cable feeding the socket so would not be an option if the cable is in the wall at <50mm. The RCDFCU at the start of the modification would protect the whole of the addition but would mean cutting out a socket box; more work than fitting an RCD at the CU.
The best method is to enhance the safety of the whole circuit.

30mA RCDs (ignoring larger current RCDs) are for Additional Protection only it provides this additional protection by disconnecting quickly at low (hopefully non fatal) current (rather than low (touch) voltage). It is there to protect against electric shock.

The RCD requirement is used in cases where there is enhanced risk of shock due to external conditions or inexperienced users. In the case of a fault or careless use, whether in the attached device or in the supply cable, the RCD will provide this additional protection.

I think it is considered that where the cable is visible no one is going to nail through it so lower risk and RCD not required. For S/O <=20A (general use) or S/O <=32A likely to be used outside or power supplied in wet conditions there is an increased risk of electric shock so RCD protection required.
 
James.
The introduction of the requirement to RCD protect socket-outlets was not brought in as a whim, it was originally to protect persons using portable equipment outdoors.
At the time, there had been a noticable increase to the number of injuries and fatalities due to the increased use of the new fangled electric mowers and hedge trimmers.
The original requirement was that all socket-outlets that may reasonably be used to supply portable equipment outdoors must have RCD protection.
Since that requirement was introduced, it has been found that many designers, inspectors and electrical installers have been over-zealous in applying this requirement, to such an extent that they include socket-outlets that would not reasonably be expected to be used to supply portable equipment outdoors. Such as those used to supply integrated appliances etc.

It was decided with the introduction of the 17th edition, to clarify the requiremnts to RCD protect socket-outlets, and to not only require that those used to supply portable equipment outdoors, but to include portable equipment used by unskilled persons indoors as well.
To this end two requirements were introduced, one requiring any socket-outlet intended for general use by ordinary persons to be RCD protected, and the other requiring specifically any socket-outlet that is used for mobile equipment outdoors should also be RCD protected.
As such, if you have a socket-outlet that could be used to supply mobile equipment outdoors, but you don't use it for that purpose, there is no requirement for it to be RCD protected.
However if that socket-outlet is used for a hoover, for charging laptops or any of the other myriad of new fangled items we now have, it must also have RCD protection.
Socket-outlets intended for specific use, such as to supply integrated appliances, boilers etc. do not require RCD protection, as it is unlikely that someone will be lugging such applances around and the likely hood of someone recieving a shock is slim.

It has also been determined that ordinary persons are quite thick, and will now indulge in DIY (especially when there is a bank holiday).
These people will insist on drilling and nailing where any reasonable person would not.
So the requirement to additionally protect cables concealed in walls has been extended to include RCD protection.

For some reason (which is a mystery to me) it has been decided to allow these people to have socket-outlets in their bathrooms.
I have seen an installation, where a 42" flat screen TV was installed into a stud wall of a bathroom. The TV was sealed off from the bathroom by some acrylic plastic, and the socket-outlet was outside the bathroom. Apparently it is possible now to obtain a TV that can be tiled into a bathroom or shower, and that when it is not on, doubles up as a mirror.
So you can now watch TV whilst showering, then quickly squeeze your pimples during the commercial breaks.
As such these socket-outlets also require RCD protection, along with them being 3.6m from the bath or shower. Perhaps it has been decided that these people will not have long extension leads.

It was decided that sensible or skilled persons would not be too thick to just start putting pictures, shelving and flat screen TVs up willy nilly without first determining whether there were concealed cables in the way, and that they would not use mobile equipment indoors with damaged cables. So exceptions were made for these persons to the requirements for RCD protection. Not that sensible that any exceptions for RCD protection in bathrooms or for mobile equipment used outdoors to be allowed.

Obviously, the easiest way to protect the socket-outlets that do need RCD protection, and at the same time cables concealed in walls, is to protect the whole circuit.
However to accomodate such installations where cables are not concealed in walls, where other aditional protection is used and where some socket-outlets are required whithout RCD protection, RCD protection for circuits other than in special locations is not required.
 
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Reply to Minor Works Certificate – Details of Departures from BS7671? in the Electrical Wiring, Theories and Regulations area at ElectriciansForums.net

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