EICR C2 on missing RCDs on existing installation

I had an EICR done on my property which I let and currently has tenants in it. The previous EICR in 2020 came back with no observations, so I was very surprised that this time I got C2 on missing RCDs on the distribution board (411.3.3; 415.1), final circuits for socket outlets up to 32 A (411.3.3), concealed cables in walls (522.6.202 and .203) and lighting circuits (411.3.4.), cables passing through zones 1/2 (701.411.3.3.) and for location which requires IP-rating (701.512.2.).

I of course absolutely want to ensure electrical safety and full compliance with the applicable laws and standards in my flat. However I am surprised, that the installation which at the time of completion in 2008 was certified safe and also passed the inspection in 2020, has now suddenly become unsafe due to missing RCD. To my understanding it is rare, that standard updates are applied to existing installations to this extent, and in a manner that requires immediate and extensive updates carried out within 28 days (deadline given on the report). Would anybody be able to confirm if this interpretation made by the engineer is correct, and indeed all landlords in the UK are now required to update electrical systems in their properties, if the RCDs are not present? 

Thank you

Parents
  • As an example of industry guidance, you could look at https://niceic.com/getmedia/1acf8e45-b5a1-40ed-b066-d5f18674f99e/best-practice-guide-4-issue-7.pdf

    It is complex, and far from definitive - a socket not covered by an RCD unlikley to be used for outdoor kit might be a C3 but one serving a room with a shower might be C2 for example.  Is a socket by a door 'likely to be used' for say a lawnmower?

    I can see how two experts can reach differing conclusions. And not all inspectors of rented property are experts. Some very much not...

    It is perfectly reasonable to seek quotes from someone not doing the inspection, and I'd be very wary indeed of an inspector insisting that only they can do the work involved...

    Equally how old is the installation? Wiring that is nearly 20 years old and heavily used  may also have other things wrong with it, and there may be a tendency to suggest a complete refit, when perhaps a piecemeal method may be less disruptive. Or of course it may be in spit spot condition and good for the next half a century - from here we cannot see.

    Mike.

  • Installation is from 2008 when the flat was built. It's been in residential use, I lived there myself for the first 11 years and after that it's been let, always a couple, however not sure how heavy the use would have been - domestic appliances only. It's at the 4th floor, so none of the sockets are meant for anything external. Even using them from the balcony would require an extension lead of several meters. 

    I think I am going to get the RCDs done, but not by this guy who did the inspection. I asked him on Thursday to break down is lump sum quote into detailed line items & cost, and he hasn't got back to me yet. The level of detail on the work he quoted was in lines of "bathroom lights not IP rated, replace with IP-rated ones." I would certainly like to know the IP rating he is proposing to install, and also claiming 'not IP-rated' (as if they were fully exposed) when talking about LED-spots integrated within the ceiling is not professional. I understand it's the easy way when speaking with people who understand the context, but absolutely not a proper way to communicate to your customer what the current status is and how it needs to be upgraded. 

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  • Installation is from 2008 when the flat was built. It's been in residential use, I lived there myself for the first 11 years and after that it's been let, always a couple, however not sure how heavy the use would have been - domestic appliances only. It's at the 4th floor, so none of the sockets are meant for anything external. Even using them from the balcony would require an extension lead of several meters. 

    I think I am going to get the RCDs done, but not by this guy who did the inspection. I asked him on Thursday to break down is lump sum quote into detailed line items & cost, and he hasn't got back to me yet. The level of detail on the work he quoted was in lines of "bathroom lights not IP rated, replace with IP-rated ones." I would certainly like to know the IP rating he is proposing to install, and also claiming 'not IP-rated' (as if they were fully exposed) when talking about LED-spots integrated within the ceiling is not professional. I understand it's the easy way when speaking with people who understand the context, but absolutely not a proper way to communicate to your customer what the current status is and how it needs to be upgraded. 

Children
  • going to get the RCDs done, but not by this guy who did the inspection.

    That is more or less what I might do in your shoes (if I was not the sort who would install the RCDs myself, and of course if my feet fitted your shoes - they may not) 

    However for the purposes of this, you may want whoever does the RCDs to  do the extra tests needed to create an inspection report at the same time - so you have the option to be be fully decoupled from the original inspection.

    It would be quite an odd installation for 2008 that has no RCD at all though at that point in time they were more expensive relative to labour.

    Thinking back, the tendency in small bedsits and so on was to have one RCD as the main switch so it all tripped off together - which was a nuisance if you lost the lights at night, but the thinking was that a torch or an emergency light could mitigate that.

    The half-way house that was also popular at that time in larger house sized installations was the so called 'split load' arrangement, with a single RCD covering several breakers for sockets, shower and any other things the installers felt to be at higher risk, and then anther group of breakers with no RCD for things like lights and fire alarms where it was felt the risk of tripping outweighed the additional safety advantage.

    RCDs are cheaper now, and appliances are less trippy, as makers are more aware of the problems. 
    Most installations are now either converting to RCBOs - that is a combined breaker and RCD device (the " RCBO" ) per circuit, or two or more RCDs, covering smaller  circuit groups that all have RCD coverage and a trip of any one group does not lose too much at once to be a problem.

    It is the way of things that what level is cost-effective protection changes, and the regs have gently tightened in that "may" becomes "should" has become "must". Although RCDs for sockets supplying circuits for outdoor use have needed an RCD since about 1983 or so , to have RCDs for all sockets at least has been the preferred option for years, long before 2008..
    Any way, do let us know how it goes, and if you want to post a pic of the consumer unit (breaker board) for a slightly more informed opinion and less waffle, please feel free.

    Mike

  • The level of detail on the work he quoted was in lines of "bathroom lights not IP rated, replace with IP-rated ones." I would certainly like to know the IP rating he is proposing to install, and also claiming 'not IP-rated' (as if they were fully exposed) when talking about LED-spots integrated within the ceiling is not professional.

    Now that we know more about the flat, this sounds very dodgy.

    701.512.2 says, Installed electrical equipment shall have at least the following degrees of protection: (i) In zone 0: IPX7 (ii) In zones 1 and 2: IPX4.

    Had the flat been in the attics of a Victorian conversion, the observations would have been more credible, but not in purpose-built blocks. I assume that the ceilings are higher than 2.25 m and that the shower outlet is below the ceiling, in which case the luminaire is outside the zones.

    It would not surprise me if RCD protection has been installed.