Is the primary concern the lack of fire-rated downlights with rooms above (527.1.2)

AMK said:

Is the primary concern the lack of fire-rated downlights with rooms above (527.1.2)

That regulation is a bit of a catch-all but it has to be considered in terms of what the Building Regulations require. For a two storey dwelling, the first floor needs to have a fire resistance of 30/15/15 REI (sometimes referred to as 30minute modified). Where certain minimum parameters are met for each element of the floor construction, downlights with a specific fire rating may not be required. That is not to say that benefit would not be had by installing them.

See Appendix C Best Practice Guide 5 issued by Electrical Safety First. In this case the floor construction is much more than those parameters demand.

But considering fire barriers, sealing arrangements, and protection against thermal effects, the absence of fire hoods on open-back downlights would not comply with regulations 537.1.2. 

I take it you mean 527.1.2 which refers to "wiring systems". A luminaire would not be part of a wiring system.

I am not being argumentative. I acknowledge that 7671 and, indeed, the Building Regulations, provide for minimum standards which can be augmented at the discretion of the person applying them. However, I must return a report that is technically correct with regards to the requirements of the standards being quoted in it rather than being prejudiced to individual preference. 

Sorry, yes 527.1.2.

I understand that you are not being argumentative, and I am here to assist as best as I can. In my experience, I have consistently referred to Regulation 527.1.2 when conducting EICRs for installations where ceiling fire barriers are penetrated by downlighters, particularly if there are rooms above. 

Sorry, yes 527.1.2.

I understand that you are not being argumentative, and I am here to assist as best as I can. In my experience, I have consistently referred to Regulation 527.1.2 when conducting EICRs for installations where ceiling fire barriers are penetrated by downlighters, particularly if there are rooms above.