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

Question

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&rsquo;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.

mapj1 · Accepted Answer

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.

David Stone · Answer

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?

ebee · Answer

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)

mapj1 · Answer

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

Chris Pearson · Answer

It appears that a blanking piece in the lid of the CU is missing. There might be a 9 mm gap at either end, but that is really an 18 mm gap 'cos the pieces could easily be slid to one side. Assuming that a British Standard finger could reach the busbar (not visible in the photos), that's a C1.

mapj1 · Answer

RCD options. 
 1) as Chris P suggested, just move the lighting circuit to be under the protection of the RCD that is already there. The lighting breaker moves along the box a few places and the blanking plates (bits of plastic covering the un-used slots ) re-arrange.Cost is only labour, but it does mean if the sockets trip the RCD you lose lights as well, so cheap but not the finest. 
 2) An extra RCD is purchased and fitted in the box, there is room, and the labour is about the same as above. Now lights and power are not tripping the same one. 
 3) An RCBO is fitted in place of the lighting breaker (an RCBO is an RCD/breaker combo.) Takes up less space in the box and looks neater - is probably what you would do from new nowadays, Pricier than 1, or 2. 
 4) An RCD just for the lights is put in a new little box alongside. Ugly but useful if the existing box is full or you know that it will be changed soon anyway, or if parts that fit the original are unobtainium for some reason. 
 Bonding, should be verified by ohm meter. Standard process when it is boxed in. No need to see concealed wiring if it all measures OK. 
 The lights may be 15 years old but they are not any less safe than when put in, and many folk would not blink, a C3 perhaps, but a C2 seems OTT unless there is a good reason we cannot see from the pics.'do not like the look of it' is not the same as 'fails reg xyz because' 
 In your shoes I'd like to see the latter sort of justification - ask for the paragraph number of the reg it fails, and why. He is testing to BS7671, each paragraph has a no. for exactly this reason. There really should not be a lot of room for interpretation. 
 Mike. 
 edited for grammar typo

mapj1 · Answer

Oh dear. My opinion of the guy is falling. Silent fixes, did he suggest payment in used fivers as well ? 
 It should always be made very clear that unless you really know the guy well, that any remedials will not be done by the same outfit as the inspection. Otherwise there is a great temptation to make work by failing easy things to do, and not to bother to fail things that are really wrong and need doing, but are jobs that involve more effort as they are awkward and less profitable to actually do. 
 In other posts in this forum over the years we have read of some absolute corker examples of this sort of thing happening. 
 The agency that found him for you are missing a serious trick if they have not realised this is a temptation too far for some less scrupulous operators. 
 Costs. Hard to say how much someone would quote, As well as the job itself which may vary with things we cannot see like how hard the walls are and the lengths of slack in the cables, it will depend on how far they have to drive and how busy as well as area factors like how easy and much it costs to park nearby - time is money and if you have to walk in for hundreds of yards and up 3 flights of stairs 3 times lugging tool boxes only to look down out of the window and see someone scruffy type trying to break into the van it tends to put the prices up for that area next time. Some folk are wary of rented as not all tenants are actually reliably in or very welcoming even if the landlord has arranged it. 
 Parts wise &pound; 50-100 of bits and the bigger cost is perhaps half a day of actually being there at however many pounds an hour. Your best bet is to try and call a few local sparks and see what they say, but good ones will probably want to see it or at least know a lot more before fixing a price - others may just over estimate and pocket the difference. 
 Mike

David Stone · Answer

Perhaps you might like to post a link to the actual report supplied, that would be most interesting, or if you don't want to do that a copy to me at davezawadi(at)yahoo.co.uk, it would be seen by some of the right people. Looking at the pictures, it looks pretty much like a contractor job at build time, since then there have been some changes to the regulations, but it is very unlikely there is much wrong as it will be the same for all the flats. 
 I am interested that the management do not want to follow this up, as I personally consider this EICR inadequate as I have said above. If the same is happening to all the owners it certainly needs attention. 
 I am interested particularly in the measurements results sheet and tick list of the report. I expect that you were not present when the work was done, but I would also like to know what other inspections were carried out, particularly of the tightness of all connections, as I suspect this was way too much trouble for this Inspector. 
 You have verified that the lighting is ELV, so the C2 provided was false, as the non-compliance with 701 as I noted above.

Chris Pearson · Answer

Part 10. No. 8. RCD for low voltage circuits serving the location. "N/A" is not consistent with the C2 later on.

OlympusMons · Answer

Just a few observations from me; 
 page 2-Next inspection-1 month 
 this really winds me up. If all remedials are done, the report should give a reasonable time until next inspection. As it stands, another report is needed after the remedials are done 
 page 3 
 Agreed limitions- Agreed with no-one 
 Supply protective device is a switch 
 other sources of supply on page 7, which says N/A 
 prospective fault current 949kA is HUGE 
 rating/setting of device should be N/A as it is not settable 
 page 4 
 item 4.2 no mention elsewhere of loose CU 
 item 4.4 should be C3, plastic CU 
 item 4.15 should be N/A-plastic CU 
 item 4.16 should be N/A- not required for fault protection, not TT and Zs within limits all circuits 
 item 4.17 this is ticked but has given a C2 for no RCD in bathroom 
 page 5 
 item 5.11 e) shouldn't be N/A, should have a code 
 item 6.1 b) ticked, but bedroom light not working? 
 list of luminaires page 8, which says N/A so none inspected despite saying 20% in extent of sampling on page 3 
 item 7.7 all N/A-should include those in bathroom 
 item 8.1 a) says N/A, but has given C2 for this elsewhere 
 item 8.2 says N/A but lights are ELV 
 Note-his name hasn't been redacted at the bottom 
 page 6 
 live/live insulation resistance tests- should be N/A unless all loads disconnected. Lim on lighting circuit, "no access to spotlight connections" (page 3) , are all lights spotlights?

David Stone · Answer

I wonder if the eagle eyed have noticed something else? The incomer appears to be 3 core SWA (old colours) but where is the armour (see 5.16 on form)? This suggests that there is a central position with all the meters, and presumably the position of all the extraneous parts bonding (if any) and an easily accessed fuse whose rating is unlikely to be the 100A stated, providing protection of the submain which he says is 16mm2 (main Earth conductor, thus undersized! Now the hard question, would I expect this to be present within the flat too, as there is one 10mm2 in the CU Earth bar as far as I can see? How was this inspected because I would expect at least a note about it. The flat heating is also interesting, perhaps central, perhaps gas, or perhaps just a single heater or perhaps that is an immersion water heater? Then there are all the ticks on metering equipment and bonding all being present and the correct size, interesting. Yet he complains that the bathroom bonding cannot be verified! 
 This is definitely an inadequate EICR, with all the paperwork from a scheme. I wonder about the qualifications of the QS and the Inspector. It needs to be taken much further.

Sparkingchip · Answer

Kay76 
 Just get the lighting circuit moved onto the RCD side of the consumer unit and replace the two lights, insist on being supplied with an Electrical Minor Works Certificate to keep with the original EICR to show the required remedial work has been carried out. 
 Ideally the lights would be on a separate RCD, but just go for the easy option. RCBOs for these particular consumer units are expensive and not readily available. 
 Budget &pound;100.

Kay76 · Answer

I wrote to NICIE over the weekend - to clarify the basis in arriving at C2s(not formal complaint). They told me the EICR inspector need to follow the bathroom lighting guidance and told me to go back to them and ask them revise the code. If they refuse, then I can lodge a formal complaint against them. Similarly, they need to test the supplemental bonding with some prescribed method. I have gone back to the vendor who assigned them to me and requested for the same. Judging from their past reactions, they may just sit mum and do nothing but I think I will hold off from any remedial work until I hear back because I really don&rsquo;t want to mess up my current installation if nothing is wrong!

mapj1 · Answer

If it gets him off your back and a "pass" for now, let him do it, there are loads of flats and other small buildings with one RCD and the potential for the one-out all-out problem, and most of them are just fine without any tripping problems for intervals of many years. 
 It is not something to design into a new installation of course, not best practice, but it is not a show stopper. And it can be done right now. (it is at most an 'improvement recommended' level of comment on any report) 
 At some point in the next decade that consumer unit, or at least some of it, will probably be changed and it can all be addressed then, but that you can arrange in your time and on your terms. 
 If it is not causing a problem tripping on the sockets now, it won't cause a problem in the immediate future either by adding a few lamps to the same RCD. 
 Mike. 
 .

mapj1 · Answer

If the tenant is in perhaps they can distract him with the offer of tea or coffee and then take some before and after pix of that consumer unit with covers off while he goes to the loo ;-) 
 He should use the machine that goes bing to test the RCD but at the least exercise the 'test' button before packing up. 
 I reckon about 30 mins max. 
 M.

ebee · Answer

Just a ditto on the RCD scenario. In an ideal situation you`d avoid a RCD tripping out too many circuits. 
 Some years ago you didn`t have much choice, an RCD might be fitted as a "Main Switch" thereby protecting all circuits. 
 Later some were taken back onto a plain "Mainswitch" (lighting for example) and the remainder (sockets for example) on RCD. 
 Later on again Dual RCDs each protecting a few MCB circuits offered the chance to just lose around half of the circuits per RCD trip situation (often called for some nonsensical reason as a "High Integrity" Board/consumer unit) 
 . Then additional plain ordinary MCB circuits or a few RCBO circuits added on (and RCBO is an MCB and an RCD combined just to protect only one circuit_ 
 . Or you could have One plain switch and all circuits RCBO (If you were gonna call any combo "High Integrity" then surely it would be this one. 
 One of our esteemed contributors did point out that with many/all RCD circuits on an installation you could have, in that installation, much leakage to earth and not be aware of it because not any one circuit would actually cause a trip, but the same could be said about the no RCD/RCBO only MCB/Fuse circuits anyway. 
 
 There are at least two of us on this forum who are "Front Enders" (One RCD covering all circuits) and not much in the way of nuisance trips over many years, however the chances of such are many more than by splitting down to increase the number of RCDs in an installation. 
 Believe me I have given the shortened version of what I wanted to explain

Sparkingchip · Answer

The Energy Performance Certificate will also recommend replacing this light with LED lighting, it is obsolete halogen lighting and quite possibly not suitable for the environment in which it is installed as it is not IP rated, also being open backed it does not have a fire rating which may be another issue. 
 Just replace the light with a dedicated IP65 SELV LED down light and save yourself, the letting agents, the electrician and the NICEIC unnecessary grief. 
 The light is not worth arguing about, the circuit supplying it should still be 30 mA RCD protected, but if that light is replaced, I would probably then go for a C3. Ideally the MCB would be swapped for a RCBO, but I don't think they are available for that consumer unit, so the lighting circuit could go onto the RCD with the sockets if push comes to shove.

Sparkingchip · Answer

Cheap and nasty down-lights like these are the bane of electricians life&rsquo;s, in my opinion they should never have been sold and installed in the first place. 
 The amount of time and effort they waste whilst doing EICRs trying to justify their use is ridiculous, as is the amount of time and effort put into prolonging this discussion on this forum. 
 Most people just accept they are #### and have them replaced with new modern LED IP65, fire and acoustic rated without all this ridiculous effort to prove there is nothing wrong with them. 
 Skimming through the discussion I think I was the only person to raise concerns about the probable lack fire rating, they may also lack there required acoustic rating and may also be potentially causing condensation issues within the fabric of the building. 
 Unless someone actually removes the lamp and has a look up into a fitting to see if it is open backed or an enclosed can and tells us what they are are we don&rsquo;t really know whether issues are, if I were doing the EICR I would definitely have removed the lamps and possibly removed the fittings from the ceiling, because in addition to assessing the suitability of the fitting in general and for use in that actual location, they have halogen lamps in them and they generally melt and burn the 12 volt cables to the lamp holders and in many cases the 230 volt circuit cables and transformers as well. 
 In addition the standard of installation needs to be assessed, many installers just used choc strip connectors and often failed to ensure they are enclosed and insulated as required, many put the fittings to close to timber joists and framing with some actually cutting into the timber to fit the lights, I have seen ceiling joists and the bottom chords of roof trusses completely cut out doing structural damage as well as clear and obvious fire risks. 
 Neither the lamps or the transformers should be covered with insulation with fire hoods or enclosures installed as required. 
 Regards that EICR, it is very lacking in so much that if I had completed it there would be a lot more observations and codes to what is on that one. 
 napitweb.azureedge.net/.../CP 1 07 P 24-25 Downlighters.pdf

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

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