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Code-2 for non-fire-rated downlights installed in a 2nd floor flat kitchen ceiling with unoccupied/uninhabitable loft above

Tim Boler

Hello everyone,

I've recently had a EICR for my flat and I was told that the downlights in the kitchen would be a Code-2 because they are not fire rated. I can see how this would be the case if there was a flat above me but there is only the loft space that is accessible via a telescopic ladder and hatch. The flat is on the 2nd floor. Are fire rated downlights required in this instance?

Secondly, why is the following guidance so vague?

EICRs - Coding, and the link to the Electricity at Work Regulations 1989 webinar
"Fire-rated luminaires are required where the ceiling, in which they have been installed, is deemed to be a fire barrier. C2 would seem reasonable given that non-fire-rated luminaires have been recessed into a ceiling deemed to be a fire barrier."

One would have to be an expert in the Building Regulations and Approved Documents to be able to make this assessment. If the guidance can't be more prescriptive then I don't think it's worth giving.

Many thanks, Tim

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  • +1

    In my opinion they shouldn't even be coded if the area around them in the loft is clear. The nearest fire compartment is between you and the flat below.  Not sure what I would put if you have a lathe and plaster ceiling though. Possibly a C3 or a C2 if signs of excessive heat around them. Also the type of lamp could make a difference. The old 12v halogen lamps get very hot

    Gary

  • +1 in reply to aligarjon
    aligarjon said:
    Possibly a C3 or a C2 if signs of excessive heat around them. Also the type of lamp could make a difference. The old 12v halogen lamps get very hot

    I am inclined to agree.

    The reason for the C2 appears to be that the integrity of the ceiling has been breached. If the lamps were disconnected, they would no longer be part of the electrical installation, but the fire risk (if any) would be unchanged. So, another Part of the Building Regs may apply.

    By contrast, if there is any sign of significant overheating (perhaps made worse by being covered with insulation), the lamps could be a source of ignition, in which case C2 would be appropriate.

    If there is no sign of overheating, the situation could be improved, so C3 seems appropriate. I do not think that the inspector can disregard the risk entirely.

    Best of luck!

Reply
  • +1 in reply to aligarjon
    aligarjon said:
    Possibly a C3 or a C2 if signs of excessive heat around them. Also the type of lamp could make a difference. The old 12v halogen lamps get very hot

    I am inclined to agree.

    The reason for the C2 appears to be that the integrity of the ceiling has been breached. If the lamps were disconnected, they would no longer be part of the electrical installation, but the fire risk (if any) would be unchanged. So, another Part of the Building Regs may apply.

    By contrast, if there is any sign of significant overheating (perhaps made worse by being covered with insulation), the lamps could be a source of ignition, in which case C2 would be appropriate.

    If there is no sign of overheating, the situation could be improved, so C3 seems appropriate. I do not think that the inspector can disregard the risk entirely.

    Best of luck!

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