EICR Coding Opinions

[JohnW2]

C3 is only 'improvement recommended', i.e. bring up to current regulations.

I personally think that one should get rid of the non-discretionary link implied by that "i.e.". In other words, I think that "improvement recommended" (as an expert judgement/opinion by a qualified and experienced electrician) and "to bring up to current regulations" ought to be separate matters, indicated separately to whoever commissioned the EICR.

For example, would you really 'recommend' that cables be dug out of walls and re-routed because they obviously were not in safe zones, even though that would be necessary "to bring up to current regulations"?

Kind Regards, John

 

[EFLImpudence]

C3 is only 'improvement recommended', i.e. bring up to current regulations.

I personally think that one should get rid of the non-discretionary link implied by that "i.e.". In other words, I think that "improvement recommended" (as an expert judgement/opinion by a qualified and experienced electrician) and "to bring up to current regulations" ought to be separate matters, indicated separately to whoever commissioned the EICR.

You may be right but that is the requirement of an EICR - to compare with the latest regulations and advise.

For example, would you really 'recommend' that cables be dug out of walls and re-routed because they obviously were not in safe zones, even though that would be necessary "to bring up to current regulations"?

Well, you would but there is no obligation for it to be done.

Your example, I think, is not a very good one as normally cable routes would not be known.
If it were so obvious (then it may be classed as visible) why would it not be recommended to improve - the same as if there were no RCD protection for that cable (if not visible).

In a lot of cases considered hazards or dangers are only due to changes in the regulations which is your point but how it is.

 

[JohnW2]

I personally think that one should get rid of the non-discretionary link implied by that "i.e.". In other words, I think that "improvement recommended" (as an expert judgement/opinion by a qualified and experienced electrician) and "to bring up to current regulations" ought to be separate matters, indicated separately to whoever commissioned the EICR.

You may be right but that is the requirement of an EICR - to compare with the latest regulations and advise.

I realise that. However, I would like to think that professionalism should come into the equation, even if that has to be in terms of advice/recommendations made 'outside of (i.e. separate from) the EICR' in order to please BS7671. A 'monkey' or robot armed will I&T information about an installation and a copy of the regs could tick boxes indicating what aspects of the installation are not compliant with current regulations - but only a trained and experienced professional electrician could give 'recommendations' based on professional judgements and opinions.

For example, would you really 'recommend' that cables be dug out of walls and re-routed because they obviously were not in safe zones, even though that would be necessary "to bring up to current regulations"?

Well, you would but there is no obligation for it to be done.

You really would? I can fully understand that you would and should indicate that the situation was not compliant with current regs, but would you really 'personally recommend' that the cables should be ripped out of the walls and re-routed?

In a lot of cases considered hazards or dangers are only due to changes in the regulations which is your point but that is how it is.

Indeed. Are you saying that no electrician is going to be comfortable/prepared to make personal 'recommendations', based on professional judgement and opinion, if they would result in something less than 'updating to full compliance with current regulations' - and, perhaps worse, that they all would feel obliged to 'recommend' upgrading to current regs, regardless of their personal professional opinion?

Kind Regards, John

 

[EFLImpudence]

A 'monkey' or robot armed will I&T information about an installation and a copy of the regs could tick boxes indicating what aspects of the installation are not compliant with current regulations -

The monkey reference is somewhat fatuous as obviously not true as is a robot at present.

but only a trained and experienced professional electrician could give 'recommendations' based on professional judgements and opinions.

Is that not the same thing?
I am not sure what you consider to be against the regulations yet should not be noted or mentioned.
'Improvement recommended' is hardly an unbearable threat.

For example, would you really 'recommend' that cables be dug out of walls and re-routed because they obviously were not in safe zones, even though that would be necessary "to bring up to current regulations"?

Well, you would but there is no obligation for it to be done.

You really would? I can fully understand that you would and should indicate that the situation was not compliant with current regs, but would you really 'personally recommend' that the cables should be ripped out of the walls and re-routed?

I do not see why you are so opposed to this as, surely, it is the same as anything else which is badly installed.
It would be advised and recommended that it be put right.
What is so remarkable about that?

If it were not noted I suspect a charge of negligence from you would ensue.
Would you rather we advised and put in writing 'it should be put right but my grand-parents survived so don't bother'.

In a lot of cases considered hazards or dangers are only due to changes in the regulations which is your point but that is how it is.

Indeed. Are you saying that no electrician is going to be comfortable/prepared to make personal 'recommendations', based on professional judgement and opinion, if they would result in something less than 'updating to full compliance with current regulations' - and, perhaps worse, that they all would feel obliged to 'recommend' upgrading to current regs, regardless of their personal professional opinion?

I do not see the difference.
That is all that can be done because that is what we are doing.
The alternative is ignoring the regulations.

It is no different than saying that 'this is not actually dangerous but would not be done/allowed today' - the same as an old car without seat-belts.

A shower without an RCD is no more dangerous than it used to be but not acceptable today,

 

[ericmark]

C3 is only 'improvement recommended', i.e. bring up to current regulations.

Providing the observation 'gives rise to danger' that is.

This is the real point as clearly with a caravan to have all circuits through a single RCD is OK.

So I ask what is different between a caravan or boat and a house. In the main it is natural light and extra low voltage battery backed lighting.

So in my house with an emergency lamp over stair well to give a C3 would likely be wrong. The "(iv) reduce the possibility of unwanted tripping of RCDs due to excessive protective conductor currents produced by equipment in normal operation" is the question. And even with two RCD's it may not for fill that requirement. So can't see how one can award a C3 for that unless you measure the leakage and have some threshold at which you consider it needs further splitting.

Therefore only "(iii) take account of danger that may arise from the failure of a single circuit such as a lighting circuit." can really raise the possibility of issuing a C3. A simple battery operated lantern would mean it was same as the caravan or boat and the fact they could be removed or replaced at any time means it is near impossible to say if any danger exists.

Do we add up the wattage of light fittings and say if all lights were left on it would trip the 6A MCB so we must give a C3? If not then we can hardly give a C3 for single RCD as the danger is the same.

With a two room flat there is likely no difference to using a single RCD to using a single RCD in a caravan however with a 6 bedroom house then clearly there is. I suppose we should do a risk assessment but in real terms what we a looking for is a clearly defined cut off point and there is no such thing.

So since there is no cut off point (Well 60 m² for Em lighting) then can't really see how we can code it? OK stairs could be considered as requiring Em lighting but to me testing Em lighting is outside the remit for doing a EICR.

So although I would include notes as to possible violation of 314 DIVISION OF INSTALLATION can't really see how I could code it! The same would apply to single MCB controlling all lighting. Much would depend on size of premises and with a 10 bedroom house then clearly one would have to consider if it needs a code but question really has to be at what point does one code. And should we really be doing risk assessments as part of a EICR?

I have noted with interest some of the points made on the ESC website and to me an extension lead is not part of my remit when doing a EICR but they list use of extensions in a dangerous way as one of the items to be coded. I have a plug in rechargeable touch which will auto light on a power failure. Having one of these clearly could remove the danger but to have items which can be plugged in or unplugged making the EICR show satisfactory or failure seems flawed as often the EICR is done before new occupants move in so any plug in items would not be present while inspecting.

 

[JohnW2]

I am not sure what you consider to be against the regulations yet should not be noted or mentioned.

Nothing. The main purposes of an EICR is to identify and report ('note or mention') anything and everything which is not compliant with current regs.

'Improvement recommended' is hardly an unbearable threat.

I'm not suggesting that it is an 'unbearable threat', but I am, indeed, saying that I personally feel that 'mentioing or noting' a non-compliance with current regs probably should not automatically invoke a 'recommendation' to bring it up to current standards. Even BS7671 itself admits that work complinat with previous, but not current, regs is 'not necessarily unsafe' and does not require all non-compliances with current regs to be rectified.

If it were not noted I suspect a charge of negligence from you would ensue.

Indeed - as above, I would expect all non-compliances with current regs to be 'noted/'mentioned'.

Would you rather we advised and put in writing 'it should be put right but my grand-parents survived so don't bother'.

Not quite. However, given that BS7671 itself does not impose any requirement for bringing existing installations into compliance with current regs, I might expect a professional, having identified and noted/mentioned/reported all non-compliances, to give me a personal recommendation, based on professional judgement, as regards what remedial work (s)he actually advised. To simply 'recommend' that every non-compliance with current regs should be remedied would just make it difficult for me to see the wood for the trees.

If one talks to a surveyor about an older property, they will usually be able to provide a long list of things that would not be compliant with various regulations for a new build today, many of which relate to 'safety' in one sense or another. However, they will then give professional recommendations, based on their skill, experience and judgement, as to which of those issues ought to be (or, in some cases, must be) addressed - they certainly don't simply 'recommend' that everything be brought up to the standards that would be required of a new house today.

The difference between us seems to be in our understandings of what a 'professional recommendation' should be. Maybe, particularly given the BS7671-imposed codings of EICRs, electricians feel constrained to simply 'recommend' that every non-compliance with current regs should be remedied, despite the fact that even the regs themselves do not seem to necessarily call for that.

Kind Regards, John

 

[ericmark]

Interesting argument. If the regulations state existing installations do not require updating to current regulations then that means the installation still complies!

To my mind there are two parts to the EICR.
The first is all points of non compliant are noted. (Although ESC does not agree)
The second is recommendations are made in the notes.

Where there are multi non compliant items are found there is a problem in that some sort of order is required to guide as to what should be corrected first and with just 3 codes now one can end up with so many code C3's that non are corrected.

To reduce the number of C3's and to instead include lesser items in the notes does make some sense so the more important items are corrected first.

Improvement recommended it says should be issued when it would result in significant enhancement of the safety of the electrical installation.

The Best Practice Guide also states:-

Amendment 1 to BS 7671: 2008 no longer requires departures from the requirements of the current edition of BS 7671 that do not give rise to danger or need improvement to be recorded in condition reports.

I do question some of the items it says "The main RCD or voltage-operated earth- leakage circuit-breaker on a TT system fails to operate when tested with an instrument or integral test button" is a reason for C2. However I have seen many times where the ELCB-v is left in circuit as an isolator and a ELCB-c added and there is no danger at all from the fact that the ELCB-v fails to trip.

There seems to be a lack of detail in the guide for example referring to a plastic water tank rather than a thermal plastic water tank there are plastic water tanks designed for solid fuel water heaters which can take boiling water and where solid fuel water heating is employed then the over temp on an immersion heater needs to be resettable.

The point is of course it is only a Guide and one should not be following it blindly. However it would seem reading the ESC best practice guide that we are NOT looking for non compliant but looking for items which present a danger.

It would also seem that although we don't have to quote which regulation number is breached there should be a regulation number within BS7671 breached before we can include it in the report.

Yet it still refers to water tank types and emergency lighting requirements which are not actually part of BS7671 there are regulations covering them but not in the BS7671 so again the guide seems to wander from it's own guide lines.

To me in the same way as with PAT testing missing guards for mechanical parts do not mean it fails the electrical test with a EICR if it's not electrical and it's not part of the installation then it should not be in the report.

 

[RMS]

Completely agree with ericmark.

I suppose the next question to consider is when advising the client about this observation (for those who would issue a code 3) do the benefits of replacing the consumer unit outweigh this risks?

In terms of a risk based approach, is it reasonably practicable to carry the above out?

I am still of the opinion that no code would be assigned to this and a comment within the report is completely acceptable.

 

[ban-all-sheds]

If it was me, I would issue no observation code and make a comment only as this complied with an earlier edition of the regulations. It was fine all those years ago.

So were 2 pin sockets and fused neutrals...

And bare conductors.

 

[RMS]

If it was me, I would issue no observation code and make a comment only as this complied with an earlier edition of the regulations. It was fine all those years ago.

So were 2 pin sockets and fused neutrals...

And bare conductors.

Along with many other things............that points been made

 

[JohnW2]

To my mind there are two parts to the EICR.
The first is all points of non compliant are noted. (Although ESC does not agree)
The second is recommendations are made in the notes.

That's precisely what I've been suggesting. However, the regs somewhat confuse and 'spoil' that by defining a C3 code (the one which would naturally be used to indicate non-compliances) as meaning "improve recommended" - thereby potentially muddling up the two issues.

With C3 defined as it is, one either has to be selective in which non-compliances one gives a C3 (thereby not 'noting' all non-compliances) or, if one does give a C3 to all non-compliances, imply that one is 'recommending' improvement for all of them.

I know that EFLI (and probably others) doesn't agree, but I still personally think that reporting (all) non-compliances with current regs and 'giving recommendations' should be two separate things. It may be that most/all electricians do not feel comfortable (and/or confident) enough to take the responsibilty of 'recommending' anything less than that all non-compliances should be addressed ('improved').

Kind Regards, John

 

[JohnW2]

If it was me, I would issue no observation code and make a comment only as this complied with an earlier edition of the regulations. It was fine all those years ago.

So were 2 pin sockets and fused neutrals...

And bare conductors.

Along with many other things............that points been made

Indeed - and, as I've been saying, this is where I would have hoped that professional electricians would be able/prepared to make a judgment, based on knowledge and experience, and hence 'give recommendations', as to which of those 'previously compliant but no longer compliant' things were such that 'improvement' (bringing up to current standards) would result in a 'significant' improvement in safety.

Kind Regards, John

 

[RMS]

The old code 4 'does not comply with BS7671' is not included in the new EICR. A C3 is an observation (that gives rise to danger) whereby improvement is recommended. Noting all non compliances with the current edition of BS 7671 is no longer required. So a judgement is required on what is deemed to give rise to danger.

 

[JohnW2]

However it would seem reading the ESC best practice guide that we are NOT looking for non compliant but looking for items which present a danger.

It obviously makes sense that looking for 'dangers' should be the highest priority, regardless of 'compliance'.

It seems that there are even a few situations in which 'compliance' and 'avoiding/removing dangers' are in conflict with another - and one hopes than an electrician would, in such circumstances, apply common sense and consider danger, even if removing the danger would result in technical non-compliance ...

... in another recent thread, I highlighted what I think is an example of this. We were shown a photo of a long length of incoming gas pipe (pre-meter) which passed within about 6 inches of a bare metal adaptable box which was (necessarily) earthed to the installations earth. Main bonding had been applied to this gas pipe (pre-meter) but someone raised the point that this was 'non-compliant', since at least one interpretation of the regs says that main bonding must be connected on the consumer's side of the meter.

If one followed that interpretation of the regs and bonded on the consumer's side of the meter, and if there were no electrical continuity across the meter, then I personally believe that an unacceptable potentially dangerous situation would have been created (the very situation than main bonding seeks to prevent) - and would hope that an electrictian would identify and report this danger, even though it arose because of 'compliance with the regs'.

Kind Regards, John

 

[JohnW2]

Noting all non compliances with the current edition of BS 7671 is no longer required. So a judgement is required on what is deemed to give rise to danger.

Exactly - but, as I've said, it seems that at least some electricians are not comfortable and/or confident enough to make a judgement that some non-compliances do not "give rise to ('significant') danger".

I would also add that, as I've also said, as a person who had commissioned an EICR, I think I would like to be informed of all non-compliances (i.e. the old C4) as well as those non-compliances (or even compliances!!) which were deemed (judged) to give rise to ('significant') danger - but I suppose that's a personal thing.

Kind Regards, John