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PROPOSED ELECTRICAL LEGISLATION

John Peckham
The government have produced draft regulations on the periodic inspection and testing of domestic installations.


It can be found here http://www.legislation.gov.uk/ukdsi/2020/9780111191934


I have serious concerns with the proposed definition of "qualified" as it does not require anyone to have any qualifications whatsoever , so it does not do what it says on the tin. It perpetuates the current practice of any knuckle scraping half whit who does not know their amp from the elbow carrying out inspection and testing. Without setting out defined required qualifications it becomes unenforceable.


Unless an MP makes an objection as Secondary it will become law without debate. I have written to my recently Knighted MP this morning to explain my views on the proposed legislation and in particular the definition of "Qualified" that contains no requirement to have any qualifications. 


Unless the government gets any objections these Regulations will become law. Only an MP can get proposed secondary legislation changed.


You may wish to join me in writing to your MP?
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    The proposed legislation requires the safety standard to be met. The safety standard is BS 7671:2018 as defined in the legislation.


    When we carry out inspection and testing, at least those of us who are competent and have working knowledge on BS 7671 should do, comply with the general rules and in particular Chapter 65.. The Chapter 65 requirement requires the inspector to record "details of any damage, , deterioration,,defects or dangerous conditions" (651.4). Also in 651.2 "The identification of installation defects and non-compliance with the requirements of BS 7671, that may give rise to danger". There is no requirement in the Regulations to record non-compliances that do not give rise to danger. In the model forms in Appendix 6 (and we know other than Appendix 1 are not regulations only guidance) it introduces the Code C3 for non-compliances that are not dangerous or potentially dangerous.


    So back we go to 651.1 which sets out the the purpose of the inspection and test "to determine, so far as reasonably practicable, whether the installation is in a satisfactory condition for continued service". So although we are not required to record C3 non-compliances we do as they are mentioned in Appendix 6. If we record a C1, C2 or FI, again following the guidance in Appendix 6, we conclude and state on the EICR the installation is "Unsatisfactory". If we record on C3 non-compliance we would record the installation as being "satisfactory".


    Now here is the rub, with the new legislation it is an absolute requirement for the installation to fully comply with the safety standard which is defined as BS 7671:2018. So if we have a single C3 non-compliance the safety standard set out in the legislation is not met and remedial action has to be taken.


    I would be interested in other forum members views?
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  • 0
    The proposed legislation requires the safety standard to be met. The safety standard is BS 7671:2018 as defined in the legislation.


    When we carry out inspection and testing, at least those of us who are competent and have working knowledge on BS 7671 should do, comply with the general rules and in particular Chapter 65.. The Chapter 65 requirement requires the inspector to record "details of any damage, , deterioration,,defects or dangerous conditions" (651.4). Also in 651.2 "The identification of installation defects and non-compliance with the requirements of BS 7671, that may give rise to danger". There is no requirement in the Regulations to record non-compliances that do not give rise to danger. In the model forms in Appendix 6 (and we know other than Appendix 1 are not regulations only guidance) it introduces the Code C3 for non-compliances that are not dangerous or potentially dangerous.


    So back we go to 651.1 which sets out the the purpose of the inspection and test "to determine, so far as reasonably practicable, whether the installation is in a satisfactory condition for continued service". So although we are not required to record C3 non-compliances we do as they are mentioned in Appendix 6. If we record a C1, C2 or FI, again following the guidance in Appendix 6, we conclude and state on the EICR the installation is "Unsatisfactory". If we record on C3 non-compliance we would record the installation as being "satisfactory".


    Now here is the rub, with the new legislation it is an absolute requirement for the installation to fully comply with the safety standard which is defined as BS 7671:2018. So if we have a single C3 non-compliance the safety standard set out in the legislation is not met and remedial action has to be taken.


    I would be interested in other forum members views?
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