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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
  • The above comments are worthy, but what is a suitable level of training and why is the current version of BS7671 a "Gold" standard for safety? As we keep issuing amendments every few years, often for items which are not going to significantly change safety of users, this is just an expensive bureaucratic measure which will not make any measurable difference. The whole concept of an EICR needs to be discussed, with aims and outcomes defined, before something like this is implemented.  As to the qualifications and experience of the tester / inspector, we see from discussions on the forum that there are wide differences in assessment of  various electrical installation matters, particularly in relation to danger. We also get the "what if, and what if" syndrome, even the discussion is about something compliant with the letter of BS7671, for example the "shower circuit and possible extra loads from ovens" I commented on recently. Some of the posts were most surprising and far from the letter of BS7671, presumably because of the careless reading of various parts, and convenience being as important to the posters as safety, or perhaps the requirements for safety are not clear.


    My own experience of training for the 18th exam as tutor are quite revealing, as are the wide range of scores achieved, from 100% to bad failure. The exam is not difficult to pass, and there is probably time for a competent electrician to look up most of the answers. However knowing what to look up is not trivial in a few questions, and the people who had difficulties passing  (around the pass mark, say +- 10%) were simply not familiar with the BBB, and could certainly not be inspectors doing EICRs. Whether their work was otherwise satisfactory I cannot tell, but it is safe to wonder.


    2391 is considerably more difficult and needs much more understanding of electrical theory than an open book BS7671 exam. The practical test ensures that one knows how to make tests and diagnose faults at a reasonable speed on simple circuits nicely laid out on boards. It can be much more difficult in real premises, particularly if they are large and unfamiliar. The theory section probably should be changed with real test / inspection problems laid out, perhaps with readings and photographs, to test experience properly.


    2391 should be the minimum qualification for domestic EICRs, and the rules should be changed so that the inspector (or the same company or anyone financially connected) CANNOT do any reparations, because EICR fraud is in my experience rife. It may be caused by cash or lack of knowledge, which is not important. The inspector is responsible for the installation safety, and so should check and certify the installation after any repairs are complete.You will notice that this is the same condition as a new installation certificate, which I feel is fair enough. Hopefully this would cure the "drive by" EICR and probably put off most of those issuing reports which are not correct, as the inspector is personally responsible. Clearly these arrangements should be statutory with suitable penalties for deviations.


    Why there should be different arrangements for rented properties is unclear. The answer is to make the landlord statutorily responsible to the tenants for electrical safety, although the owner occupier should be left alone to take care of their own safety, if they wish by getting EICRs to hold the inspector in the position defined above. You will see that this puts electricians in a similar position to gas fitters, where basically similar rules apply.


    I would like much more notice be taken of accident statistics in forming changes to BS7671, although this is difficult because of international harmonisation, and more care be taken when a change is made which could cause difficulties with inspection of older installations. I see no reason not to add clauses like:

    Older consumer units which are not made of non-inflammable materials may continue in use provided that the terminals are all checked for tightness and no other damage is observed.


    Fun eh?

    David CEng etc.


Reply
  • The above comments are worthy, but what is a suitable level of training and why is the current version of BS7671 a "Gold" standard for safety? As we keep issuing amendments every few years, often for items which are not going to significantly change safety of users, this is just an expensive bureaucratic measure which will not make any measurable difference. The whole concept of an EICR needs to be discussed, with aims and outcomes defined, before something like this is implemented.  As to the qualifications and experience of the tester / inspector, we see from discussions on the forum that there are wide differences in assessment of  various electrical installation matters, particularly in relation to danger. We also get the "what if, and what if" syndrome, even the discussion is about something compliant with the letter of BS7671, for example the "shower circuit and possible extra loads from ovens" I commented on recently. Some of the posts were most surprising and far from the letter of BS7671, presumably because of the careless reading of various parts, and convenience being as important to the posters as safety, or perhaps the requirements for safety are not clear.


    My own experience of training for the 18th exam as tutor are quite revealing, as are the wide range of scores achieved, from 100% to bad failure. The exam is not difficult to pass, and there is probably time for a competent electrician to look up most of the answers. However knowing what to look up is not trivial in a few questions, and the people who had difficulties passing  (around the pass mark, say +- 10%) were simply not familiar with the BBB, and could certainly not be inspectors doing EICRs. Whether their work was otherwise satisfactory I cannot tell, but it is safe to wonder.


    2391 is considerably more difficult and needs much more understanding of electrical theory than an open book BS7671 exam. The practical test ensures that one knows how to make tests and diagnose faults at a reasonable speed on simple circuits nicely laid out on boards. It can be much more difficult in real premises, particularly if they are large and unfamiliar. The theory section probably should be changed with real test / inspection problems laid out, perhaps with readings and photographs, to test experience properly.


    2391 should be the minimum qualification for domestic EICRs, and the rules should be changed so that the inspector (or the same company or anyone financially connected) CANNOT do any reparations, because EICR fraud is in my experience rife. It may be caused by cash or lack of knowledge, which is not important. The inspector is responsible for the installation safety, and so should check and certify the installation after any repairs are complete.You will notice that this is the same condition as a new installation certificate, which I feel is fair enough. Hopefully this would cure the "drive by" EICR and probably put off most of those issuing reports which are not correct, as the inspector is personally responsible. Clearly these arrangements should be statutory with suitable penalties for deviations.


    Why there should be different arrangements for rented properties is unclear. The answer is to make the landlord statutorily responsible to the tenants for electrical safety, although the owner occupier should be left alone to take care of their own safety, if they wish by getting EICRs to hold the inspector in the position defined above. You will see that this puts electricians in a similar position to gas fitters, where basically similar rules apply.


    I would like much more notice be taken of accident statistics in forming changes to BS7671, although this is difficult because of international harmonisation, and more care be taken when a change is made which could cause difficulties with inspection of older installations. I see no reason not to add clauses like:

    Older consumer units which are not made of non-inflammable materials may continue in use provided that the terminals are all checked for tightness and no other damage is observed.


    Fun eh?

    David CEng etc.


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