PROPOSED ELECTRICAL LEGISLATION

That clause 12.10 must have scheme providers and training centres alike rubbing their hands with glee. Clearly someone has convinced them that deciding if a flat is a deathtrap or not requires more than 4 years of training, plus a special course to create a special kind of super-inspector, and a special scheme to join.

I suggest that it doesn't. What it does require is a normal inspector, of exactly the same sort who may be trusted to inspect factory or commercial wiring, with a solid grasp of the basics and some professional integrity, and perhaps most importantly, some real world experience. The problems arise with the more nuanced decisions beyond 'is it a deathtrap' to 'it is not to current standards, but in this case it is OK.' and these require experience and good judgement to get right.

I also suggest that nearly every old and quite a few new examples of electrical installations do not meet every clause of the latest BS7671, or could be interpreted as not doing so. Most are not dangerous because of that.

I have emailed my MP

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.

To anyone who intends to Email their MP but has not done so, it is worthwhile to include Luke Spanton at the Ministry of Housing, Communities and Local Government (his Email at the end of the MEMORANDUM   as he is  the as the civil servant charged with getting it through comittee.  He will not appreciate insults, after all he is only doing his job as requested, but constructively worded  'how to make this work in a better way ' advice seems to be favourably received, even at this regrettably late stage, and misses out the delay while your own MP gets round reading the post and then to forwarding it to his boss and then in turn at some time even later it gets forwarded on to him. You always have to contact via your MP, or your comment/observsation is void, but doing so in a way that fast tracks it the final recipient cannot be a bad thing ( !! well it worked for me, I was staggered to get a phone call this morning thanking me for indicating my concerns - sounded like others maybe have not yet reached his desk).


Our conversation covered the fact that there is a problem with 'ambulatory legislation ' (civil service legal speak, not mine) in that they cannot refer to documents that do not yet exist, or at least not without changes to the legal framework that are beyond the current exercise, so they are stuck with the 18th.

But he seemed open to the idea that proposing a better way of handing older installations may be worthy of consideration, and even the scandandalous suggestion that NICEC/ESF and NAPIT may not be without a degree of vested interest in getting work in for their own members.

If I had thought about quick enough it some clarification of C1/2 3 may have been in order...

Anyway if it helps others.

davezawadi:

2391 is considerably more difficult ...

2391 should be the minimum qualification for domestic EICRs ...

Seems reasonable to me.


I didn't find 2394/5 easy. It is certainly a level above a domestic electrical installation course. Theory and practice during the day and homework in the evenings. The hardest part was having to test an installation against the clock whilst being observed - no time for a cuppa there!

Chris Pearson:

davezawadi:

2391 is considerably more difficult ...

2391 should be the minimum qualification for domestic EICRs ...

Seems reasonable to me.


I didn't find 2394/5 easy. It is certainly a level above a domestic electrical installation course. Theory and practice during the day and homework in the evenings. The hardest part was having to test an installation against the clock whilst being observed - no time for a cuppa there!

BS7671 is a British Standard, C&G2391, or in fact the 2394/5 are City and Guilds qualifications, unlikely to become representive of a statutory regulation. although, I can see a case for these qualifications to be used as part of the accredition process within a CPS scheme.


So in my opinion, these qualifications are the basis for a life of inspection and testing and not an authoritive entitlement.to start assessing even less with the C&G2382-18.  Experience of the inspector is probably the most important aspect here.


Somebody tell if I'm barking ..... lol  ....up the wrong tree


Legh

The great thing about this new scheme Is that established electricians will be able to perform the function without being forced to join a trade association. There are many long established guys and ladies with years of experience of electrical installation testing. And hopefully they wont have to pay £999 + vat for a 3 day course every couple of years to line the pocket of yet another bandwagon of the IET.

As regards "complying" with the BS7671 guide book,  the publication itself says installations to previous editions are not necessarily unsafe, so the landlord is covered there. if his/her property was wired to the 14th ed even.


Regards, UKPN

I have recently been working on an electrical installed to14th Edition Wiring Regulations, over the last fifty odd years there have been various alterations and additions.


There is more way I would have signed it off as fit to use by tenants renting the house, but the homeowners have been using it without any concerns.


The new consumer unit has a label on it saying that metal lights and switches that require an earth connection cannot be installed and those that were installed have been stripped out and replaced with plastic fittings.


The general standard of electrical installations in England is far lower than most people think they are, the requirement that every tenanted home is going to be certified as being up to a minimum standard in fifteen months from now with any remedial work completed is very ambitious.


Andy Betteridge.

the requirement that every tenanted home is going to be certified as being up to a minimum standard in fifteen months from now with any remedial work simply requires the bar fpr that minimum standard to be set suitably low.... That is not at BS7671 18th edition, and all non compliances fixed, which is how the proposal looks currently, so old colours, plastic boxes overhead cables of unknown clipping, buried joints and all the stuff that might be C3 or no comment in some cases and not others,  all is still in scope.  Indeed as noted the IET themselves do go to the trouble to  point out that installations to older versions of the regs may well be OK for continued use - but there is no such provision in this draft legislation,  - so it really needs changing or it will be laughed out.


Equally  "all live parts are OK behind not less than one layer of insulation tape" may be nearer the aspirations of some at the shallow end  and that needs bucking up too.

However, I'm not sure that is quite the right intention of the legislation either.


I'm very much with DZ here, that there are many strictly 'non compliant' things that if they are not giving trouble can just be  checked over see if they can be allowed to continue in service.