EICR - does bathroom lighting outside zone 2 need to conform with IP rating and additional rcd protection?

Hi, I have received an EICR certificate with 2 C2s on bathroom lighting 1) Bathroom lighting does not conform to IP rating (note the lighting outside the zone based on published zoning guidance (low voltage spot light) but inspector insisted on ignoring the zoning guidance) 2) Bathroom lighting circuit is not connected to an RCD also supplementary bonding is not visible. 

Questions- 1) Are the C2s legitimate? As a layman, I find it difficult to understand why the inspector insisted on ignoring the bathroom zoning regulation (my ceiling is actually higher than most of the newer flat) . 2) Also how do I find out whether there is supplemental bonding in the bathroom lighting circuit (nothing is visible outside) - does it really warrant a C2 if I cannot prove that there is supplemental bonding (the lighting in my bathroom is low voltage (I don’t know what is the voltage but it is very dim) and is located outside zone) . 3) If the C2s are legitimate, how can I fix the issue with minimal cost? 

many thanks for your time in advance.

  • Zone 0 is actually inside the bath or shower tray, I am sure that is not what you mean, and you intend to say the light is out of the zones.

    So, I am assuming the light is more than 2.25 metres off the floor above or within 0.60 metres of the shower or bath, is that correct?

  • Yes - there is no light above or near the bath/shower. Light is out of zone based on the published zoning guidance. Thanks 

  • Well C1 is immediate danger so exposed live metal in  a place you could touch perhaps.

    C2 is potentially dangerous, and is a bit open to interpretation in some quarters.
    Some folk are very nervous of liability and tend to fail things that are not that bad, and others are so laid back as to be near horizontal and leave things that really should be picked up...

    C3 is recommend improvement but not urgent.

    So

    1) Where are these lights in relation to the water and steam and so on, - ask yourself honestly if there is something that makes the lights or their location unsuitable - does it look like they get splashed, are they going rusty, or are they high and dry and well out of the region of concern ?

    'dim' does not guarantee extra low voltage, inadequate lights may also be mains powered sadly. But there may be a transformer in the ceiling void or loft above or something. If upstairs is someone elses flat it is harder to check.

     RCDs or bonding, well you need at least one, ideally both.

    2) bonding.

    To check for bonding the usual method is a check with an  ohm- meter for a low resistance between metal things like taps and radiators that you may find yourself holding while wet, that are connected to metal pipes that can carry a shock current in or out of the bathroom. Plastic pipes are not normally an issue unless very short - a metre or two  of water column in a plastic tube is quite a good current limit.

    The idea is that the bonding connects them solidly together, so that your wet body does not - or at least there is a low resistance path that most of the current will take that is not through you...

    3) RCD,

    This may be easy or hellish tricky depending how it was first done.

    Can you post a photo of your fuse board/ consumer unit that supplies the bathroom lights ? The detail of the design and if there are any free spaces or if it is rammed full make a difference. (Or space for a small box along side with an RCD in it..)

    Mike.

  • This is another poor EICR. Section 715 covers ELV lighting, and nothing special is required in Bathrooms, the items being fully isolated. The inspector was negligent in not determining the type of lighting, and could easily determine if it was mains or ELV. (-10 points). Assuming it was mains, then it is outside the zones so no risk to anyone, particularly the inspector, so the coding was not correct (-20 points). He failed to check if the circuit was actually RCD protected or not, or if he did he failed to code the other circuits affected (probably C3) (-10 points). He did not check for any REQUIRED supplementary bonding with an ohm meter, as bonding is only required if the items are actually not connected via a low resistance, and a good installation may well not have any bonding visible, and looking inside the light switch or fittings should have shown the extra G/Y(-10 points). The IP rating of fittings is dubious, as unless subject to direct splashing none is required, and out of zone this is very unlikely 701.512.2(-10 points).

    The conclusion can only be that this inspection is significantly defective, but unfortunately this is far from unusual. I think an improper degree of incompetence was involved. I wonder if a value for R1+R2, or Zs for the bathroom lighting circuit is on the test results, or whether this is even remotely correct? Were the terminal screws inspected? I rather doubt it.

    As to fixing the alleged problem, I suggest adding an 30 mA RCD to at least this circuit if none is present, and this can be fitted anywhere outside the bathroom. I detect howls of complaint, but this is perfectly legitimate as a low cost solution. It is amazing that so many understand so little of the actual regulations, particularly those who claim to be Inspectors. How many will immediately want to fit a new CU full of RCBOs?

  • Many thanks for all your responses. The lighting is only 12 V and substantially away from the shower/bath or the water basin. The engineer argued that bathroom zoning guidance is not mandatory and that it is better to assume that an average height person can touch the light (and know what, no one of average height could because the ceiling is actually quite high!) Personally I won’t risk the safety of my tenant for this lighting but I really don’t think the lighting poses a C2 risk.

    The issue I have now is that the engineer said he cannot see visible supplemental bonding and hence he assumes  it doesn’t present and so the lighting needs a RCD protection. The fact was some other engineers did inspection on my friends flats in the same development and our flats have never been altered (ie similar lighting) and the supplemental bonding issue didn’t even arise (nor rcd protection).  My development has a lot of flats, if the supplemental bonding/rcd protection for bathroom lighting is really an issue, I can imagine that all flats will need to undertake repair work and this would have been highlighted by tenants to the management office and clearly this is not the case, I’m really at lost with this - the engineer was assigned to me from a landlord service provider and the vendor doesn’t seem to care about the quality of the inspection work and the resulting conclusions. Anyone has any idea on whom to take this matter up for further resolution? 

    Many thanks.

  • If the person carrying out the report is a member or approved entity of a scheme and if they are also listed as being competent to carry out inspection and test by that scheme then your first port of call might well be with that scheme (NICEIC, ECA, Napit etc etc) 

  • Hmm. Wiring regs are not generally mandatory. But for land lords to have an inspection  to them is.

    If the inspector is a member of a trade body (Niciec, Napit etc. you could suggest that you want a 2nd opinion from them.

    If he isn't (or anyway..) you could ask to see qualifications)

    But before going in guns ablaze, I'd suggest to give him a chance to ease out of this (avoid confrontation and/or give your adversary a golden bridge across which to retreat... ),  but ask what electrical test he did to verify the bonding missing and if not could he not just do that first ?- it should be ' needs investigation' not "potential danger" if he cannot find it, which is still not a pass but it is a bit sloppy.  You can look at the pipes under the sink etc and see if they are all plastic- if they are not metal then bonding makes no sense it is not needed.
    Are there RCDs covering other circuits - again a photo of the board would be good and maybe a photo of the lights and even the plumbing.

    If you are sure it is a 12V lighting system (the lamps will say) then really how did he miss that.?

    We have had disgruntled inspection reports posted on here with vary degrees of redaction to protect the innocent/ incompetant, and in some cases the efforts are quite poor.
    Sadly getting your money back is quite tricky - who paid him ?  you or the landlord services folk ?

    Mike

  • It does not help editing the original post or comments so that replies don't seem appropriate. 

  • I paid the landlord services and they paid the EICR inspector. Actually I have been in some discussions with the EICR inspector before they issued the report as they gave my tenant a heads up that there were some issues. However, the inspector was reluctant to provide support for their findings. They proceeded to issue the unsatisfactory report afterwards so I had no choice but to bring those up with the landlord certificate services who assigned them. After my last post, I received an email from the landlord services asking me to contact NICIE re the C2 observations - they said they would only get the engineers to change the result if NICIE said so. I'm actually in the midst of preparing the email to NICIE, but I really want to get to the bottom of this before I contact them.

    Re the light rating - the inspector told the landlord services folk it was 12v:) he admitted it could be a C3 but he would still classified as a C2 (I don't know why he insisted).

    Unfortunately I haven't been in UK for a few years, my recollection is that the pipes under sink may be chrome metal.  Meanwhile I will post same of the photos I had from the inspectors (he forwarded me a bunch of photos but didn't tell me what they are for and specific photos I asked they just ignored) . Thanks