EICR - tester exceeding remit and the regs?

[JohnW2]

An EICR is carried out to the most recent edition of BS 7671. It is entirely irrelevant to what ever previous standard the installation may or may not have complied with. ... If you find a plastic consumer unit or red and black wiring then it doesn’t comply with the current edition of BS 7671 and needs to be noted on the EICR.

Writing my recent reply to eric has made me wonder, specifically about C3s ....

The introduction to BS7671 says ...

Existing installations that have been installed in accordance with earlier editions of the Regulations may not comply with this edition in every respect. This does not necessarily mean that they are unsafe for continued use or require upgrading.

BS7671 itself does not actually seem to say anything about the 'coding' of non-compliances on an EICR, but refers one to the ("Informative, for guidance") Appendix 6, and the only reference to coding there seems to be in the specimen EICR form.

As you know, that form says that C3 means "Improvement recommended". If something was compliant with regs when installed, but not with current regs then IF (as the above quote acknowledges may be the case) the expert judgement of the person undertaking the inspection is that 'upgrading' is not required, then is it appropriate to give a code which means "Improvement recommended"?

Indeed, if an electrician whose expert opinion is that something does not require upgrading 'recommends that it should be improved', then I imagine that at least some people would suspect that this represented 'touting for unnecessary business'. It's even conceivable that Trading Standards might be unhappy with a qualified electrician 'recommending' work that, in their expert judgement, was not necessary/required.

In fact, I wonder if those undertaking EICRs even really think about this when coding things as C3. You say that, for example, red and black wiring should be "noted" on an EICR. If you mean that you would give it a C3 code, would you really be intending to 'recommend' a total re-wire?

Kind Regards, John

 

[EFLImpudence]

That might be a good point regarding C3s but what word word you like to replace 'recommended'?
Perhaps "C3, not to current requirements but satisfactory or acceptable".

As for the red and black cable, all the regulations require is that conductors are identified, which they are.
If one thought it necessary, then all it would need is for the red and black to be sleeved or otherwise marked.

 

[JohnW2]

That might be a good point regarding C3s but what word word you like to replace 'recommended'? Perhaps "C3, not to current requirements but satisfactory or acceptable".

I guess it 'depends' (on the electrician's expert judgement), and hence really requires four codes (like we used to have).

I would certainly agree with the first part of your suggestion "C3, not to current requirements ...". What follows that will depend on the electrician's judgement, given that "not necessarily ... require upgrading" means that, in some cases, the electrician's judgement might lead him/to to feel that 'recommending improvement' is appropriate. I can't remember for sure, but I think I may be suggesting a return to the old system, with the choice between C3 and C4 depending upon judgement, something like ...

"C3, not to current requirements but acceptable" (or some similar word).
"C4, not to current requirements, improvement recommended"

As for the red and black cable, all the regulations require is that conductors are identified, which they are. If one thought it necessary, then all it would need is for the red and black to be sleeved or otherwise marked.

True, but even sleeving both ends of every conductor in an installation (and heaven forbid there be any 'inaccessible' ends!) would be a seriously non-trivial exercise, particularly if unnecessary.

As I said, I strongly suspect that many electricians do not think about the fact that, with the current definition, they are 'recommending' action (which they might not feel is actually necessary) when they give a C3. If you undertook and EICR and coded red and black wiring (throughout) as C3, you wouldn't really be intending to be 'recommending' either over-sleeving everything or a re-wire, would you? - but that is actually what you would be doing with the present definition of 'C3'.

Kind Regards, John

 

[EFLImpudence]

If you undertook and EICR and coded red and black wiring (throughout) as C3, you wouldn't really be intending to be 'recommending' either over-sleeving everything or a re-wire, would you? - but that is actually what you would be doing with the present definition of 'C3'.

I don't think it requires mentioning if the two-colour label is present.

 

[JohnW2]

I don't think it requires mentioning if the two-colour label is present.

I think you probably need to take that up with RF, who wrote ...

If you find a plastic consumer unit or red and black wiring then it doesn’t comply with the current edition of BS 7671 and needs to be noted on the EICR.

Kind Regards, John

 

[EFLImpudence]

I would note the plastic CU as C3 but inform the customer that they did not have to replace it.

However, with red and black wiring, the only issue today is that the conductors are not identified correctly (not the fact that they are red and black) according to the modern regulations, but the two-colour label must mean that it is allowed; and as long as they are correctly identified by those colours, nothing need be done.

 

[EFLImpudence]

The problem with the "landlord's certificate" - if people think it must be to the latest regulations - is that something is likely to need updating every five years.

That is clearly unreasonable.

What if they bring in a regulation that CUs are not allowed in under-stairs cupboards?

 

[JohnW2]

However, with red and black wiring, the only issue today is that the conductors are not identified correctly (not the fact that they are red and black) according to the modern regulations, but the two-colour label must mean that it is allowed; and as long as they are correctly identified by those colours, nothing need be done.

I can't disagree with that, but some people (maybe RF?) might argue that, regardless of the label, there is a regulation which explicitly requires conductor identification (by insulation or sleeving colour) using harmonised colours - so that if there in non-compliance with that regulation (when looked at alone) it "has to be noted" on an EICR.

It all seems to be fairly silly!

Kind Regards, John

 

[JohnW2]

The problem with the "landlord's certificate" - if people think it must be to the latest regulations - is that something is likely to need updating every five years. ... That is clearly unreasonable.

The current legislation explicitly talks about BS7671:2018, so they would have to change it if they wanted people to comply with any future editions.

However, I think we are agreed that to require literal compliance with everything in 'current regulations' (i.e. as if it were a new-build or a complete re-wire) would not be reasonable.

Kind Regards, John

 

[EFLImpudence]

There is the clause in the identification regulation stating it is required "except where there is no possibility of confusion".

I would say that applies to nearly all of the conductors in normal settings.

 

[JohnW2]

There is the clause in the identification regulation stating it is required "except where there is no possibility of confusion". I would say that applies to nearly all of the conductors in normal settings.

I'm not sure what you mean. If, say, a socket were supplied by a red/red or brown/brown T+E (if one of high enough CSA existed), or, indeed, any colours other than red+black or brown+blue, how would/could there be "no possibility of confusion" (at least 'uncertainty') as to which was L and which was N (if, indeed, they were L & N)?

Kind Regards, John

 

[EFLImpudence]

I'm not sure what you mean. If, say, a socket were supplied by a red/red or brown/brown T+E (if one of high enough CSA existed), or, indeed, any colours other than red+black or brown+blue, how would/could there be "no possibility of confusion" (at least 'uncertainty') as to which was L and which was N (if, indeed, they were L & N)?

Well, I did say in normal settings but - the Line would be in L and the Neutral in N.

If you are going to say that the installer might have reversed the polarity, then likely any identification would be on the wrong conductor as well.

 

[SUNRAY]

Well, I did say in normal settings but - the Line would be in L and the Neutral in N.

If you are going to say that the installer might have reversed the polarity, then likely any identification would be on the wrong conductor as well.

 

[JohnW2]

Well, I did say in normal settings but - the Line would be in L and the Neutral in N. If you are going to say that the installer might have reversed the polarity, then likely any identification would be on the wrong conductor as well.

All true - but if you're going to say that there is "no possibility of confusion if everything has been done correctly, then, as you imply, the reg is pretty useless/meaningless.

Kind Regards, John

 

[EFLImpudence]

There are instances where it might not be obvious like junction boxes.