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EICR C2 on missing RCDs on existing installation

Sarah Howard

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

  • 0 in reply to Chris Pearson
    Chris Pearson said:
    Only if something gets damaged!

    Which is reasonably foreseeable, and a common occurrence.

  • 0 in reply to Simon Barker
    Simon Barker said:

    f the IET and BSI choose to release a 19th Edition, then the law will still only require inspection against the 18th, until the government decides to change the law.

    Your problem is that anything that was done pre-2018 is likely to be not strictly compliant. And it then comes down to the opinion of the inspecting electrician whether that's a C3 (doesn't strictly comply, but not unsafe) or C2 (doesn't comply, needs fixing).

    It would probably be best to get legal advice on the first point, as the below example of plugs demonstrates.

    Overall, it's not reasonable for an installation (or a version of a standard) to be considered safe indefinitely.

    In terms of the specific version of BS 7671 cited in the legislation, it is my understanding this doesn't mean you forever have to use that version of the standard in respect of the legislation, but it would be up to a court of law to decide that a later version ought not to be adopted for a particular case.

    Just as an example, the Plugs and Sockets (Safety) Regulations 1994 quote standards current at the time the legislation was enacted ... does that mean that plugs, socket-outlets and adaptors to the current versions of the standards fall foul of the legislation, and conversely it's OK to continue using standards from 1994 ... well, no !

    I agree that the second point could be considered either subjective, or dependent on circumstances, and overall there is no "rule" ... as I said above, there is industry guidance for reference, but it's down to an opinion at the end of the day.

  • 0

    Is it a ground floor flat or first floor. That will make a difference to the coding if you follow industry guidance BPG4 as socket outlets could be a C3 if not likely to be used outdoors. Also following BPG4 all of the other points quoted should be C3 other than the bathroom which is a little more complex as you have to have supplementary bonding in place or it is a C2 for lack of RCD and supplementary bonding + effective main bonding etc.

    The above aside even if they are C3, the upgrade has correctly been recommended by the electrician. If you choose to ignore that advice and there is a problem down the line where an RCD would have helped then the responsibility lies with you and not him.

    Gary

  • 0
    Sarah Howard said:
    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'm not sure how 701.512.2 comes into this. That reg is about using equipment with a suitable IP rating in zones 0, 1 and 2 - it had no direct relationship with need for RCDs. As others have said, the lack of additional protection by 30mA RCD for dry internal areas is typically a C3 rather than C2, but a C2 (and hence an overall 'unsatisfactory' outcome) would be reasonable for socket expected to supply equipment outdoors and for bathroom circuits if there was no (or inadequate) supplementary bonding in the bathroom (ditto for room containing a shower). So it might be a case of the detail being a bit muddled, but the overall conclusion (unsatisfactory) being accurate enough (all depending on the details of this particular case, which we can't see, of course).

    Understanding the details correctly would be helpful when it comes to decide on what remedial action is required or desirable - on one extreme it might be as simple as replacing a socket with an RCD version (in the perhaps unlikely event that only one socket was likely to be used for equipment outdoors), to a simple replacement of MCBs with RCBOs in the existing consumer unit, to (at the other extreme) a complete consumer unit replacement (e.g. if the existing unit is an older model that doesn't have RCBOs available for it) - with several other options in between. There will be quite a few factors to take into account, many of which won't appear on the EICR. A second opinion by someone who can see the installation, is always good for that sort of thing.

       - Andy.

  • 0 in reply to gkenyon
    gkenyon said:
    In terms of the specific version of BS 7671 cited in the legislation, it is my understanding this doesn't mean you forever have to use that version of the standard in respect of the legislation, but it would be up to a court of law to decide that a later version ought not to be adopted for a particular case.

    Courts interpret legislation and make judgments accordingly. They cannot change the law, so I agree with Simon that until (strictly speaking) Parliament decides to change it, Regulation 2 must be followed as written - i.e. the 18th Edn applies.

    What is arguable is whether corrigenda and amendments are to be included. Against is the principle that legislation is not ambulatory; in favour is the fact that the Big Brown Book has, "IET Wiring Regulations Eighteenth Edition" clearly written on the cover.

    The Regulations concerning plugs are rather different inasmuch as only, "BS 1363" is mentioned: e.g. Regulation 8 and Schedule 2. Oddly, the 1987 version specifies BS 1363:1984 (Regulation 5 and Schedule 3).

  • 0 in reply to gkenyon
    gkenyon said:
    Chris Pearson said:
    Only if something gets damaged!

    Which is reasonably foreseeable, and a common occurrence.

    Definitely foreseeable, but how common? Perhaps Mrs P and I are just lucky.

  • 0 in reply to AJJewsbury

    Sarah

    There has been a requirment for socket oulets to be RCD protected where thaey could be used to supply equipment outdoors for decades before your flat was completed. 

    Is you flat on an upper floor?

    It is irrelevant  when your flat was completed, the inspectopr should inspect and test your electrical installation and compared it to the current edition of the IET Wiring Regulations not a previous withdrawn standard.

    For me sockets that could be used to supply equipment outdoors is a C2, sockets for general use C3, circuits in a bathroom or other room containing a fixed bath or shower with no supplementaty protection and no RCD protection C2, cables in a wall without mecachanical protection C3, domestic lighting circuit no RCD protection C3.

    I would be interested to see the inspection and test report in 2020?

    I would strogly recomend you get a qualified and comptent electrican to upgrade your installtion to a satisfactory condition so you can comply with the law, sleep soundly at night and not have to face me across a court room! It will probaly cost you less than one months rent.

    JP

  • 0 in reply to gkenyon
    gkenyon said:
    It's the legislation that requires defects of C1, C2 or FI to be rectified in 28 days, not the standards and guidance.

    Taking a step back, I am not sure that is correct. C3 is a non-compliance, albeit not immediately dangerous. On reflection, I do not think that the law distinguishes between C2 and C3. The question is not satisfactory/unsatisfactory, but compliant/non-compliant. C1, C2, C3, or FI requires action within 28 days.

    I do not think that anybody in here would make no observation for the absence of RCD protection, so the installation has to be brought up to the 18th Edn standard.

    Sarah, if you are still looking in, could we see a photo of the consumer unit please? I find it difficult to believe that no RCD protection was installed in 2008, but my interest in electrickery post-dates that, so perhaps it was permissible then.

  • 0 in reply to Chris Pearson
    Chris Pearson said:
    Courts interpret legislation and make judgments accordingly. They cannot change the law, so I agree with Simon that until (strictly speaking) Parliament decides to change it, Regulation 2 must be followed as written - i.e. the 18th Edn applies.

    Is that view the accepted legal practice, though (i.e. by case law)? I'm not a legal professional, so I won't make that statement (or advise of one contrary, without suitable disclaimer).

    If you are correct, then all plugs, for example, would have to comply with standards back in 1994 ... None of the standards supported in the legislation acknowledged what we now know as "ISODs" ... insulated shutter operating devices, or "plastic earth pin".

    But ... we have ISODs ...

    Similarly, if the installation contains generators that operate in parallel with the grid ... or as a switched alternative, the ESQCR mandates the installation to conform to the 'British Standard Requirements' which is defined in Regulation 1 as BS 7671:2008 (17th Edition).

    Hence, PRS would be in conflict with ESQCR (and vice-versa) if your interpretation were correct ? In fact, any installation to later Amendments or versions of BS 7671 than BS 7671:2008 would also conflict with ESQCR ?

    This clearly can't be the case ...

    Hence, I would ask a legal professional for their opinion on this issue, as to case-law and how this is really dealt with in real legal cases, rather than trying to interpret or theorise oneself.

  • 0 in reply to gkenyon

    PRS would be in conflict with ESQCR

    The standards referenced might be in conflict, but surely, in the vast majority of cases, it's possible to design an installation that complies with both (or more) versions? It's rare that an update to a standard exactly contradicts a previous version on some particular point - e.g. making something mandatory that was prohibited before, or vice versa - but rather introducing some new options or closing off others - so most of the time the designer can readily choose something that complies with both.

    Certainly it would be better if the politicians and mandarins could get their act together and keep everything simple and consistent, but they seem incapable of that, as a result many laws/regulations having differing requirements - we just have to find a way of complying with all of them at the same time.  II may be tedious and unwieldy at times, but usually it's possible.

    If you are correct, then all plugs, for example, would have to comply with standards back in 1994 ... None of the standards supported in the legislation acknowledged what we now know as "ISODs" ... insulated shutter operating devices, or "plastic earth pin".

    The earlier standard may not have considered or mentioned an ISOD, but unless it prohibited it in some way, couldn't current devices be said to effectively comply with both versions of the standard?

       - Andy.

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