PROPOSED ELECTRICAL LEGISLATION

There is no denying that there is a huge number of private rented houses and flats that need some significant upgrading that is long overdue. 


The next eighteen months is potentially going to be a busy time for builders, maintenance guys, plumbers, window and insulation installers as well as electricians.


I had a look at the Energy Performance Certificate online for that flat and it's not just new storage heaters it needs.


I have done a lot of work for this landlord over the last ten years and when we have tidied flats up I made a point of replacing all the lighting with LED. This flat was tidied up eighteen months ago, but someone else did the electrical work as I was too busy,  the landlord commented this morning that the flat did not even get five stars on the EPC for low energy lighting as the other electrician didn't swap the lighting to LED.


Five stars for low energy lighting is not hard to achieve,  but it didn't happen here.


The EPC gives the estimated electric bills for this one bed flat as three years as over £7500 and says it could potentially be brought down to £3500. The performance rating is about as bad as it gets.


So a major refurbishment with new storage heaters and a satisfactory EICR in the next eighteen months are required to be able rent the flat out legally.  Otherwise it has to stay empty or be sold to an owner occupier. 


Andy Betteridge 

It is, whether the landlords at the lower end of the market are on the ball is another matter.


Andy Betteridge

I sent a similar letter to my MP, Kwasi Kwateng, Minister of State for Business and Energy, and have just received his reply.  He says that the regulations were prepared following "extensive consultation"  and goes on to say:


"With regard to Para 3, section 4, my reading of the regulations is that EICRs will now specify if certain remedial work is necessary.  It will be up to the relevant qualified person undergoing the investigation to decide where and sometimes when this work will be necessary.  It will be up to the local housing authority decide (sic) if a private landlord is in breach of the duty this imposes, and not all the recommendations typically contained in an EICR will be classified as necessary remedial actions."


He also adds that he will pass the letter to the Minister for Housing, Communities and Local Government  for confirmation.


David

Does the legislation actually say that?


Andy Betteridge

not yet, but maybe it will soon if we keep pointing it out.

After all  there is already

  a first errata.     

That cryptic ISBN13 number  ISBN-13: 978-1- 78561-170-4 is the same as the one in the regs by the way,

so now it is really referring to our friend  BS7671, just by the ISBN number...doh..

oh there is also

  a delay so they can have another round of meetings. 

someone or something is having an effect it seems.

The IET have published some guidance


I believe the author is a IET Engineer I was stood talking to with John Peckham on the IET stand at the Coventry Elex show last September.


I think the references to information on EICR Codes leaves a bit to be desired, which is not particularly the authors fault because there’s not much available other than the NAPIT Codebreakers.


There is one reference that raises an eyebrow, the PAT COP doesn’t seem to be directly relevant:

Guidance on classification codes can be found in the IET On-Site Guide and Best Practice Guide (BPG) 4 on the Electrical Safety First (ESF) website. Some trade associations also provide guidance on the coding of observations made during EICR inspections.

Model EICR forms for reporting on the condition of an existing electrical installation can be found in Appendix 6 of BS 7671:2018+AMD1:2020. These can be downloaded from the IET website. Further guidance on inspection and testing can be found in Guidance on maintaining electrical equipment can be found in the IET Code of Practice for In-service Inspection and Testing of Electrical Equipment.”


Andy Betteridge 

I am surprised to see that any "competent Inspector" requires a guidance note as to the code for deviations from BS7671. If you are competent you know what is dangerous, could become dangerous, or simply would be best improved! If you don't know that you are NBG immediately! You also need to know all the regulations properly, and can find the relevant bits in the book if needed, and can read properly. The 18th exam makes some attempt at this but probably anything less than 90% should get a code 1 on the Inspector, and that is most people who passed! The number of passes at 90% or more is quite small, and 60% is useless for inspection, it says you will miss 40% of defects. So great improvement is needed by many people, and the Electrical Safety First book or whatever is not the way to get improvement, it is to make it possible for inadequate inspectors to carry out domestic inspections of fairly dubious quality.


When one sees many of the items on EICRs and the codes given, it seems that the last thing of interest is the danger, it is the possible money to be made! Take a comment above, "all the plastic CUs need to be changed". Really, and why? If all the terminals are checked and the tails secured, why is it even potentially dangerous? If we are not careful the legislators will make the words in the book more important than the intent for safe installations, probably because they simply don't understand what is safe or what safe means. It is a hugely overused term, everything on earth now seems to say something about this is safer than before. How do you know, the only way to tell is experience, and that is what is missing from these regulations. I assume that the Government discussions with Industry did not include the IET, and was probably only NICEIC. Their vested interest in their members is obvious to keep the status quo, yet the most effective change would be to make the Inspection and reparation stages entirely separate, in that they CANNOT be the same contractor, and an Inspecting contractor is separately assessed every year. This is the normal way with inspection in most safety critical industries, and it does work very reliably, from experience.