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PROPOSED ELECTRICAL LEGISLATION

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?
Parents
  • It does seem like a flawed piece of legislation to me. Fundamentally it seems to completely confuse a satisfactory EICR with meeting BS 7671 requirements. As I'm sure we all (here) know, you can have a perfectly satisfactory EICR for an installation that doesn't meet current BS 7671 requirements in many ways - whether it be use of red/black core colours, or lack of SPDs, or use of plastic cable clips where a fallen cable would cause no hazard, or a hundred-and-one other issues. Likewise, in my opinion, is entirely unreasonable to expect a landlord to update a complete installation every time BS 7671 is amended - even if it's only a principle that the same legislation is incapable of enforcing in practice. It is fundamentally bad legislation and can only be of value to those interested in malicious legal action.


    To my mind:

    3.—(1) A private landlord... must—
    (a)ensure that the electrical safety standards are met



    should read something more like


    3.—(1) A private landlord... must—
    (a)ensure that the electrical installation is in a satisfactory condition for continued service



    - i.e. align with what a BS 7671 EICR assures.


    Presumably there should also be some provision for accepting and EIR rather than an EICR if the installation is new (or combinations of EICs/MWCs/EICRs for existing installations with alterations/additions)


    I also dislike the direct reference to a specific version of BS 7671 - ideally yes they'd update all the legislation every time BS 7671 changes, but experience with the building regulations strongly suggests that parliament isn't capable of reliably doing so. Far simpler and more satisfactory to my mind simply to demand the EICR is carried out according to the version of BS 7671 that's current at the time of the inspection.


    As for the competent/qualified issue. I suspect a problem in that the government won't want to make things dependent on some non-government body - even if they're as big and famous as the C&G. They'd have to setup some government body to oversee suitable training providers and/or examination bodies (either on the model that the DVSA do for driving tests or the MHCLG for part P schemes) - all of which would cost money and no doubt political argument, which is probably out of proportion to the problem they're trying to solve.


      - Andy.
Reply
  • It does seem like a flawed piece of legislation to me. Fundamentally it seems to completely confuse a satisfactory EICR with meeting BS 7671 requirements. As I'm sure we all (here) know, you can have a perfectly satisfactory EICR for an installation that doesn't meet current BS 7671 requirements in many ways - whether it be use of red/black core colours, or lack of SPDs, or use of plastic cable clips where a fallen cable would cause no hazard, or a hundred-and-one other issues. Likewise, in my opinion, is entirely unreasonable to expect a landlord to update a complete installation every time BS 7671 is amended - even if it's only a principle that the same legislation is incapable of enforcing in practice. It is fundamentally bad legislation and can only be of value to those interested in malicious legal action.


    To my mind:

    3.—(1) A private landlord... must—
    (a)ensure that the electrical safety standards are met



    should read something more like


    3.—(1) A private landlord... must—
    (a)ensure that the electrical installation is in a satisfactory condition for continued service



    - i.e. align with what a BS 7671 EICR assures.


    Presumably there should also be some provision for accepting and EIR rather than an EICR if the installation is new (or combinations of EICs/MWCs/EICRs for existing installations with alterations/additions)


    I also dislike the direct reference to a specific version of BS 7671 - ideally yes they'd update all the legislation every time BS 7671 changes, but experience with the building regulations strongly suggests that parliament isn't capable of reliably doing so. Far simpler and more satisfactory to my mind simply to demand the EICR is carried out according to the version of BS 7671 that's current at the time of the inspection.


    As for the competent/qualified issue. I suspect a problem in that the government won't want to make things dependent on some non-government body - even if they're as big and famous as the C&G. They'd have to setup some government body to oversee suitable training providers and/or examination bodies (either on the model that the DVSA do for driving tests or the MHCLG for part P schemes) - all of which would cost money and no doubt political argument, which is probably out of proportion to the problem they're trying to solve.


      - Andy.
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