Would this be a C3 rather than C2

In a light industrial environment (dry food packaging factory) we use an external company to carry our EICR inspections on substations and associated sub distribution and fixed wiring every three years. 
The EICR has identified that there is no evidence of 6 monthly RCD/RCBO functional tests (there are labels stating last RCD instrument test about 2 years ago) and marked this down as a C2, surely this would only be a C3? 
Industrial EICR frequency is recommended between 3-5 years dependent on environment, risk assessment etc. I would accept a C2 if there was no evidence of testing within last 5 years, but surely is a C3 within this period?

  • Interesting one. BS 7671 recommends biannual RCD testing (by user test button) but as far as I recall doesn't require any written records of such to be created or retained. From a wider H&S perspective it's likely to be  very good idea to keep records (if only to cover one's back with the HSE should anything nasty occur) - but I can see an argument that it's not a BS 7671 issue and therefore not something that's even within scope of an ECIR let alone codeable.

       - Andy.

  • Thank you for your response. We don’t keep records of the functional test, but we record the trip time at 1xI∆n currently within three years but we are looking to test every year. Just don’t agree that undocumented biannual function testing and an instrument test 18-24 months ago is coded as a C2.

  • How bizarre!

    The EICR determines the state of the installation on the day, not whether it passed or not previously. No C anything from me.

  • It is not at all clear what the potential danger to life is - if an RCD was actually faulty and failed to trip on the day when the test button was pressed, then that's a C3 or a C2, depending on what role the RCD is providing.

    Note  it is not a C1 unless when the button is pressed the cover falls off and exposes live metal to the touch .

    Not being clear what the RCD protects due to absent labels maybe warrants a C3 as well, and a recommendation to re-label things I suppose 

     However, just "not able to find previous test results" is the normal condition on very many sites I suspect - On that basis the inspector must go around awarding C2s to everyone they visit.

    As described it sounds to be something of a bit of a jobsworth matter

    ( i,e someone over enthusiastically (mis)using their modicum of authority in a way to make their role become more important than it really is, usually to the inconvenience and irritation of others)



  • From my understanding the six monthly test of the "Test" button is actually a "User" check. Now many on here will start saying cant have unskilled people accessing switch rooms and start pressing buttons that could affect sensitive supplies and cause more say production or financial issues.

    But thats down to the Duty Holder to determine along with the helpful advice of an electrical practitioner.

    So if somebody has been shown how to press the test button and the RCD/RCBO "Trips" to the off position then thats it, job done.

    My understanding is all positive successful tests dont need to be recorded, it is only the RCD/RCBO units that failed to trip that would then be recorded, and unique company procedure would be to then call in a maintenance technician/electrical contractor to do some further investigation and likley use of a RCD tester.

    I personally dont think it warrants comment or certainly a coded comment on a EICR. As long as the appropriate BS7671 label is present indicating Button pressed etc etc then thats compliant, A good contractor/inspector could have a conversation to ask perhaps because they can tell the six monthly test isnt being carried out, he has that conversation or sends a letter/report indicating buttons should be tested.

    Of course if there is a simple log book/file same as testing the fire alarm weekly, that who, when, date, time the test was acrried out  and a signature then to me thats it, they could write "All Ok" and only ever then add what unit failed to work, and that then is followed up to persons who can action a electrically skileld person to further investigate.

    I wouldnt code the button test isnt being carried out on a EICR.

    If during a EICR the electrical inspector found a RCD/RCBO not working of course thats coded I would say a C2, if label for six monthly test missing a C3.

    For a point of interest to people in my area of work on filling stations in our technical publications the test button on RCD/RCBO's should be pressed Monthly!! for all Haz area circuits simply because of the greater risk. So that means we have a modified BS7671 RCD Test button label applied that says monthly test not six months.

    Frequency of formal testing during an EICR, unless the manufacturer of the RCD/RCBO stated in their instructions a more frequent pressing of the button or indeed formal RCD tests then thats what should be programmed in by Duty Holder and their electrical inspector/contractor.

    BS7671 indicates the designer dictates frequency to the first EICR and thereafter its the actual electrical inspector carrying out the EICR that dictates the period to the next inspection.

    Yes there are guidance documents and suggestions out there that indicate 3, 5 or whatever years, but its only guidance, so a high risk, wet  industry application with lots of unskilled people using electrical equipment, machinery, I would want frequency perhaps sooner than guidance indicates. Also age of the installation, would affect duration/frequency of EICR as a newer installation could in theory go longer between inspections than a 30 year old installation, but again thats something the EICR inspector should be taking into account when they make reccomendation to next EICR inspection.

    Cheers GTB

  • My view is that the installation should be inspected and tested for compliance with the current edition of BS 7671. Any defects or non-compliance discovered should be recorded and Coded.

    If the RCD is not of the correct type, fault current rating, does not meet the requirements for selectivity, or other BS 7671 requirement and does not meet the disconnection time when tested with and instrument or does not work on the user test device then that should be recorded and coded. 

    It is irrelevant if the user is not testing it in accordance with the manufacturers instructions or the requirements of BS 7671. That said RCDs should be user tested and a record kept in industrial, business premises or premises where the public is admitted or people work whether paid or not.

    If requested I could post my views on coding of RCD compliance? 


    PS Where can I get one of those "Jobs Worth" badges? Mine would need to be gold plated with oak leaf  clusters and laurel leaves!

  • As long as the appropriate BS7671 label is present indicating Button pressed etc etc then thats compliant,

    That I think is where the confusion lies. If there is no notice per 514.12.2, C3 would be appropriate.

    Whether anybody has ever read the notice, let alone complied with it, is not the concern of the inspector.

  • Absence of a regular RCD test label is a C3 for me.


  • Chris, I agree and thought that is what I had typed in my reply.

    I thought that the original question posed was, that the person carrying out the EICR had coded that EICR that no six monthly activation of the Test button on the RCD/RCBO's had been carried out. Personally I dont think that needs to be coded, but does need to be communicated in writing to the Duty Holder by the inspector doing the EICR.

    Of course the only way the Duty Holder can indicate that the Test Buttons have been pressed every Six Month Max is by having some kind of written record, so ever they are brought to task under Reg 4(2) of the EAWR they can demonstrate compliance. And that a more formal instrument testing of the RCD/RCBO's are carried out at appropriate intervals/during a EICR.


  • Morning John,

    "If the RCD is not of the correct type, fault current rating, does not meet the requirements for selectivity, or other BS 7671 requirement and does not meet the disconnection time when tested with and instrument or does not work on the user test device then that should be recorded and coded."

    In my reply I agreed with what you said, wrong type, current rating , selectivity or doesnt disconnect in time while being checked during a EICR inspection, without any doubt is coded appropriately to me a C2, If six monthly test label for the button test is missing I would code a C3.

    But why would a "User Test" be coded as you listed in your comments? I agree the actual six monthly or less user test of the buttons should be recorded and made availible by interested parties. But a "User" isnt going to Code anything, they are not doing the EICR, thats the point Im making, and as such the person carrying out a EICR shouldnt code that the six monthly test isnt been done by the user, it doesnt have a place on a EICR, but a competent inspector would in writing back to the Duty Holder highlight that requirement.

    So for example, I press all the RCD test buttons on my dist boards here at home and one fails the test button test, of course I would then use my RCD tester to check it or indeed replace it, but I dont record any C code on anything as Im not doing the EICR on my installation when I test the button, I actually get my installation at home inspected every five years by local SELECT contractor not 10 years for a domestic dwelling as per GN3 (Thats my Choice). Before you say its not a place of work my home? The small print of my home insurance dictates that the electrical installation must have a periodic EICR carried out, I also thru choice given I have client meetings here at my home based office and me being pedantic, see th ring main where clients plug in laptops etc as being "A place of Work". 

    The Test button check is aimed at the occupier/Duty Holder of the property, not necassarily a electrically skilled or trained person. As I mentioned, on a filling station where we can have over a 100 RCD/RCBO's and our technical requirement for a Monthly Check of the test button as we overule the BS7671 Six month period because of safety concerns for the flammable atmospheres and public using fuel dispensers. Its the retailers staff that check the test buttons, they only log and call if one doesnt work, or that is the plan anyway.