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?

Parents
  • 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

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

    JP

  • 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.

    GTB

  • 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.

    GTB

  • Thank you, this echoes my thoughts on the matter. 
    Photos for example evidence of test in 2018 and 2020, EICR gave a C2 for absence of evidence of RCBO testing.

    Second image shows, tested recently and indicates trip time.

  • That's fine, but where is the notice please?

    ETA: Don't RCDs come with a copy of the notice, so there shouldn't be any difficulty installing one.

    Incidentally, they used call for testing the test button quarterly.

  • The notice is on the outside of the door as there isn’t any suitable place inside/around the breakers. The C2 wasn’t about lack of labelling (which would be C3)

    On the EICR it was stated that there is no evidence of periodic testing of RCD/RCBOs and thus was recorded as a C2.

  • What then is the remedial action that must be taken to rectify this potential danger?

  • Taken word for word from EICR:- 

    “Introduce recorded maintenance test and inspection programme”

    We have started recording trip times every three years and recording function tests every 6 months on a spread sheet. We have about 500 RCD/RCBOs on site. Not counting RCD socket outlets in control panels for programming use. 

    I have no issue with recording trip times and functional tests, I just don’t think the absence of them is a C2, I doubt anyone would give a domestic EICR a C2 if there was no evidence of functional tests being carried out. 

  • But why would a "User Test" be coded as you listed in your comments?

    I suspect you and JP are at cross purposes with the words and are actually in agreement. I think JP actually said "the user test device" rather than "user test" - i.e. he was referring to the T button - operation of which should be checked as part of ordinary BS 7671 RCD testing (col 29 of the schedule of test results).

      - Andy.

  • A very good point!

    Press the test button and record the result, but hang on - you just did that as part of your EICR. :-)

Reply Children
  • The instrument tested at I delta n is the softer test than the test button. The user test facility tests the RCD at 2 x I delta n so should be done after the instrument test. If it passes the instrument test but fails the T button test then a C3 as the user cannot carry out the regular user test. Not unknown as the test resistor or sometimes goes open circuit but the RCD operates on a test with a test instrument.

    JP

  • The user test facility tests the RCD at 2 x I delta n so should be done after the instrument test.

    The current 2022 9th Edition of GN3 (Section 2.6.18) recommends the user test button is pressed before instrument test. It provides a reason why.

    Basically, the test button uses "RCD test method 2" where a fault current is not returned to the protective conductor, but to one of the upstream live conductors. No-one else will be put at risk when the test button is pressed.

    However, if RCD test method 1 is used, a voltage is present on the protective conductors of the installation until the RCD operates ... or the test instrument terminates the test. The voltage on the protective conductors may be limited by a test instrument to BS EN 61557, but:

    • This is not guaranteed to protect everyone; and
    • The voltage is not present when the test button is pressed (because it's 'Test method 2').

    In addition, 'Test method 1' isn't possible for IT systems that use RCDs, for example.

  • Hi, if the test button fails to operate the RCD should you not proceed with the instrument test ? 

  • The test button is a zig-zag test, bridging between outbound live and inbound neutral or vice versa, and does not verify or requite  a CPC. However, being a higher test current than the minimum it may 'unstick' a mechanical RCD that would otherwise have failed a low current test.

    If nothing happens when you press the 'T' button or equivalent, then your next act is to order up a replacement RCD/RCBO

    You can still do a metered test if you like, but only on a modern meter that stops the test current before the test has run long enough to be dangerous to anyone downstream,

    As the RCD has to be changed the test result is a bit academic.

    Mike

  • Hi Mike. This is exactly what I do if the test button doesn’t operate. I have always marked it down as a fail and recommend it’s replaced without carrying out any further tests.

    Andrew

  • Hi, if the test button fails to operate the RCD should you not proceed with the instrument test ? 

    I wouldn't proceed with an "RCD test method 1" (fault current returned to cpc) test ... the RCD needs to be replaced anyway if the built-in test button doesn't operate it. If it's an internal electronics fault with the RCD, testing further could cause thermal damage (something might go "pop" or worse).