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BS7671 Amendment 2 transition period on existing projects

My question relates to the latest amendment to the wiring regulations; BS7671:2018:A2:2022 and the transition period on live projects.

I am currently working on multiple large residential projects that have been designed upto Stage 3 and tendered, but will not commence on-site until after the 27/09/22 which is the withdrawal date of AMD 1. The new regulations state that electrical installation commencing after the withdrawal date (27/09/22) must comply with AMD 2. 

We now have an issue of the developer coming back to us shouting about additional costs  due to the addition of AFDDs, which are required as part of AMD 2 but only 'recommended' as part of AMD 1, so have not been included in the original design. 

Has anyone had any issues with this on their projects? As the design is complete and tendered can we not install to AMD 1?

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  • Thankyou for the replies gents. 

    I contacted the IET in which they have responded in a similar way to  and   in which they stated the below:

    "If this is a single new build development that you are looking at, which had all of the unit designs completed and documented before the implementation date of AMD 2 then it would have been acceptable to complete the dwellings to the earlier version.

    The electrical documentation must reflect that the design was completed to the earlier version

    Thus, the construction, along with the inspection and testing, would also be to AMD 1.

    The completion documentation must then be to AMD 1.

    The design section of the EIC must be completed indicating a date before the Date of Withdrawal of AMD 1.

    If the documentation indicates that the design, construction, inspection & testing is to AMD 2, then the installation must comply with AMD 2 in full.

    If the design documentation is dated after the implementation date of AMD 2 but is to AMD 1, then that would not be acceptable.

    So, in summary:

    • Design dated before AMD 2 released, complete to AMD 1, on AMD 1 documentation.
    • Design dated after the AMD 1 withdrawal, complete to AMD 2, on AMD 2 documentation."

    Basically, if all parties contractually agree (Building control, warranty provider, main contractor, sub-contractor), then the design and installation can be to AMD 1 if design is dated before withdrawal. However, the insurance and warranty provider are pushing back and saying that the installation will commence after the withdrawal date, therefore must comply with AMD 2. Seems like a grey area to me.. 

  • Seems like a grey area to me.

    Agreed, and whatever BS 7671 says, can't over-ride contractual or legal decisions, hence needs to be addressed using the correct contractual variations procedure or the similar procedure in the tender process.

  • However, the insurance and warranty provider are pushing back and saying that the installation will commence after the withdrawal date, therefore must comply with AMD 2. Seems like a grey area to me.. 

    No, I don't think that it is a grey area. Whose insurers, and whose warranty provider? 

    I suspect that the developers are going to have to swallow hard, otherwise it will just be a bean feast for the lawyers.

  • otherwise it will just be a bean feast for the lawyers.

    Perhaps the truth.

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