Landlord EICR

[ericmark]

I think we've done that one to death. For a start the requirement is only to "take into account". However, no matter what the nature and extent of the concern of the IET/BSI, it is the way in which electricians seem to interpret it that I find difficult to understand - since most of them seem to interpret it as requiring the installation to have at least two RCDs, but do not seem to think that it 'requires' anything to be done to address such 'potential dangers' that can arise in the event of a power cut.

Your not the only one, although to be fair not really the electrician but the trade organisations who tell there members this is what it means.

I went to a fair few IET lecturers when I was a member, and often the speakers were not direct from IET but one of the schemes. It was at these lecturers I finally worked out where the 106 meters came from of 2.5 mm² in a ring final.

However where we use a single 30 mA RCD or two in series, for protection there is normally some back-up lighting, narrow boats and caravans, the Hobby it seems odd one out with no 12 volt lighting. But that is German and for a long time you could not officially tow them as too wide.

But the "take into account" means in real terms a risk assessment, the major question is if a RCD trips, how easy is it to reset, and if it will not reset, can the house still function without it? And this does not really need electrical knowledge to work out. So in my mothers case, RCD trip would result in her pressing her alarm pendent and telling the call centre the electrics had tripped, as she could not reach the consumer unit under the stairs, the call centre would have likely phoned me, and I would have driven 12 miles to reset it. In both of my houses this and last one, the CU was in the garage, last house garage same level as house, so need to get dressed and go outside, but even with heavy snow, not too much of a problem, this house garage under the house, so to reset means outside and down a set of steps, which in the snow could cause problems. Also problems in the dark, as no street light illumination.

Had my mother not been in a wheel chair it would have been no problem. But 1954 when house was built no one considered wheel chair access, and there is more involved to just resetting a RCD in making a home wheel chair friendly. Access ramps, oven height, hob height etc, so it seems in some ways daft to look at socket height and thermostat height when no one in the house is disabled. And in the main people can bend down, it is the upper height limit which is the problem. So around 1200 mm is eye height so any dial or other item needing viewing from above must be below 1200 mm, and 1600 mm is about the limit one can reach in a sitting position. So CU should not really be mounted high up, or in a crawl space (under stairs) but tradition puts CU where children can't play with it. So high up, or in a cupboard under stairs which can be locked is common.

RCD's do trip, and the number of times a RCD trips is far greater than a fuse blowing, so the big question is with a rented property how much should you do to reduce problems when a RCD trips? Easy in ones own house, not so easy when house used by others. It is hard to work out where to draw the line, some children are well behaved, and not down to just parents, as seen one child in a family which is a horror, but rest of children OK, clearly all taught by same parents, and we can assess the risk with our own family far easier than with some one else's family. But there has to be a limit, just like with wheel chair users, some homes are simply not wheel chair friendly and there is really little we can do to make them wheel chair friendly.

All well and good to say dentist has to be wheel chair friendly, but not really the private home. So the rental agreement will likely have clauses allowing for when medical conditions mean the tenant needs to leave, and if pictures can be put on the walls, etc. And if the tenant can't put a screw/nail/pin in the wall, then the safe zones really don't matter for the tenant.

You can get plug in RCD's, so is there really any need for a RCD in the CU? OK Emma Shaw yes, but as @JohnW2 points out these cases are rare, so an inspector is left with three questions.
1) Is it dangerous.
2) Is it potentially dangerous.
3) Is there room for reasonable improvement.
And to answer the questions he must 'take into account' the way the property is used, a wheel chair user who seems out of control bouncing off the walls means sockets at 350 mm are very vulnerable ban on the height a wheel will hit them, I don't care what Part M says. Been there and had to do the repairs.

 

[JohnW2]

Your not the only one, although to be fair not really the electrician but the trade organisations who tell there members this is what it means.

Well, whilst the trade organisations really ought to be sensible and consistent in their advice (i.e. recognising that any consequences of 'suddenly being plunged into darkness' are identical whether it results from a power cut or an RCD trip), I don't believe that it lets electricians off the hook, since they should be capable of thinking for themselves, and are responsible for their own actions and decisions (regardless of what any third party might say) and, in particular should not be daft enough to think that they must takes steps to reduce risks associated with 'being plunged into darkness' if it is due to an RCD trip but not if it is due to a power cut.

You talk a lot about 'risk assessments'. If you did one on my house, armed with records of my experiences, you would have to conclude that the risk of any part of my house being 'plunged into darkness' as a result of a (usually brief) power cut was far greater than of it happening because of an RCD trip, and therefore would hopefully conclude that (if you felt that any such 'protection' was required) priority should be given to the risk posed by power cuts, rather than that posed by RCD trips.

But the "take into account" means in real terms a risk assessment, the major question is if a RCD trips, how easy is it to reset, and if it will not reset, can the house still function without it?

That might be a reasonable view, but I don't think it's what the regulation you cited is talking about. What it says should be "taken into account" is any potential danger that could result from loss of, say, a lighting circuit. Even if an RCD is 'not easy to reset' (and I'm not sure what you mean by that) and/or the house 'cannot still function' if it cannot be reset, that would not really present a 'danger' in the normal sense (and, I suspect, the sense the reg has in mind).

RCD's do trip, and the number of times a RCD trips is far greater than a fuse blowing, so the big question is with a rented property how much should you do to reduce problems when a RCD trips?

I don't think that's primarily a question that BS7671 addresses, or needs to address. In any event, I would imagine that the great majority of tenants are as capable as you and I of 'resetting an RCD' - and if it won't reset, then the vast majority (and/or the landlord) will need to seek the assistance of an electrician

... so an inspector is left with three questions.
1) Is it dangerous.
2) Is it potentially dangerous.
3) Is there room for reasonable improvement.
And to answer the questions he must 'take into account' the way the property is used, a wheel chair user who seems out of control bouncing off the walls means sockets at 350 mm are very vulnerable ban on the height a wheel will hit them,...

C1s/C2s invariably relate to non-compliances with safety-related requirements of BS7671, and would become no less 'dangerous' (or less 'potentially dangerous') on the basis of "the way the property is used". I agree that there are some circumstances (such as you mention) which would render some things 'potentially dangerous' when they wouldn't be under 'ordinary circumstances', so I suppose that could be taken into account by an inspector is such 'circumstances' existed at the time of the inspection.

However, more generally, if such circumstances do not exist at the time of the inspection, there is no guarantee that that will not change 'the next day' - and one cannot expect an inspector to work on the basis that a wheelchair-bound, blind, or otherwise disabled occupier might move in 'tomorrow', can one?

Kind Regards, John

 

[ericmark]

We use BS7671 to help us assess what is dangerous and what is it potentially dangerous. We also tend to use the regulations to support our classification, but the problem is different scheme providers advise their members in different ways, so there has never been a fixed demarcation line between C1, C2 and C3. Nor is the a definitive rule as to how much or what is tested.

I was reading one the other day where it said no ceiling lights removed as it would damage decoration, 20% only tested, and line - neutral insulation not tested due to how much plugged in. And there is no law to say that is wrong.

With any inspection and testing it is down to the tester, and it does not matter what we say it is what the guy doing the test and inspect says.

 

[JohnW2]

We use BS7671 to help us assess what is dangerous and what is it potentially dangerous.

Eh? I thought we were agreed that (particularly important in relation to 'landlord EICRs') one of the big problems with EICRs is that BS7671 gives absolutely no guidance, let alone any 'instruction', as to what should be considered 'dangerous' (C1), what should be considered 'potentially dangerous' (C2) and what comes into neither of those categories (C3 or no code) (the one and only exception being the guidance that absence of required RCD protection should be given 'at least a C3'), aren't we?

Kind Regards, John

 

[ericmark]

I agree the BS7671 does not list degrees of danger, but it does still give some guidance like "supplementary equipotential bonding may be omitted where all of the following conditions are met" and it also 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." So it actually says you don't need to follow the latest edition.

Since 1882 clearly there have been many changes, and to say if it complies with any edition it's OK would be going a step too far, but since BS7671:1992 i.e. when it became a British standard we have had reasonably safe homes when installed to the regulations. There have been changes, like bathroom bonding which means earlier homes may no longer be safe, as can't really mix and match, and also other changes, however words like "Additional" show not really important unless some basic protection fails. So really if all basic protection is good we should not need additional protection.

I really should have studied English, as with BS7671 it is as much what it does not say as to what it says. I assume this is why never translated into Welsh, where rule of thumb is changed to historically, they are so fixated with how it is worded they clearly expect people to try and miss read the requirements.

 

[JohnW2]

I agree the BS7671 does not list degrees of danger, but it does still give some guidance like "supplementary equipotential bonding may be omitted where all of the following conditions are met" ...

That is an explicit statement as to when the requirement of the regulation in question does not apply, not 'guidance', isn't it?

.... and it also 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."....

It does say that, but ....

.... So it actually says you don't need to follow the latest edition.

That's not what it "actually says". As you have quoted, it says that the fact that installations are compliant with a previous edition (but not compliant with the latest edition) "does not necessarily mean that they are unsafe" which clearly means that, in the view of the authors, such things may "be unsafe".

In any event, EICRs are undertaken with reference to the actual requirements of current regulations at the time of the inspection (i.e. as if it were a new installation) - although that does not mean that the inspector has to 'code' all non-compliances with current regs (or code them 'higher' than C3) if he/she does not consider that they present danger or 'potential danger'.

Anyway, my only point was (with which you now seem to be agreeing) that it was not really correct when you wrote ...

We use BS7671 to help us assess what is dangerous and what is it potentially dangerous.

... since, as I think we are now agreed, BS7671 says nothing about what things are, and are not, considered to be 'dangerous' or 'potentially dangerous'. That judgement/decision is left to the individual inspector.

Kind Regards, John

 

[mointainwalker]

Forgive me butting in, but you seem to have finished and it is also EICR- related, plus saves another post.

Is the 225 cm height in bathroom measured to any part of the luminaire e.g. any part of the decorative globe, or the actual electrical connection ?

Backboards for consumer units now have to be non-flammable - correct ? My quote includes stripping particle-board back-board and replacing with metal.

My report is similar to the OP's and is being costed at £ 715 inc VAT in Grays, Essex; Any of you guys based there ?

I will take the advice given above and enquire about make of RCD to be supplied

P.S would you normally give a detailed quotation ? This is what I received

" Strip down the existing boards
Prepare the areas and connections for the new installations
Install a new metal 6 way split-load board with dual RCD protection
Install a second 5-way metal board with RCD protection
Remove the existing light
Install a new IP-rated bathroom light
Clear away all redundant materials

The cost to carry out this work will be £ 715 VAT inc. A free retest will be included in this price including notification to building control "

Thanks for reading

On reflection - and wanting to be fair - since these are supposedly all mandatory upgrades, it's not unreasonable to just give one price.

 

[ericmark]

They are not mandatory upgrades, they are what your inspector feels are required.

Once the council gets involved then mandatory.

We are looking at the English language and how the rules are interpreted and these pages are full of debates as to what the law calls for.

I have fitted all RCBO metal box in my house, but it had old wylex fuse box.

 

[EFLImpudence]

Is the 225 cm height in bathroom measured to any part of the luminaire e.g. any part of the decorative globe, or the actual electrical connection ?

I would say the electrical parts.

Backboards for consumer units now have to be non-flammable - correct ?

No.

My quote includes stripping particle-board back-board and replacing with metal.

It is new consumer units that must be 'non-combustible' and so deemed metal or in a 'non-combustible' enclosure; nothing to do with what they are screwed to.

 

[securespark]

I would say the electrical parts.

So, if the fitting was a pendant with a HO skirt (as was common in 14th and 15th Eds.), the measurement would be to the bottom of the lamp?

 

[EFLImpudence]

Yes. ???

 

[mointainwalker]

It is new consumer units that must be 'non-combustible' and so deemed metal or in a 'non-combustible' enclosure; nothing to do with what they are screwed to.

Thanks for your reply. Having read :

https://www.electricalsafetyfirst.o...es/technical-e-news/consumer-unit-mythbuster/

I am wondering if I have mis-interpreted the "Install a new metal 6 way split-load board " in my quote and when he says board, he means a full enclosure including the back (mounting-plate) which is why there is the need to strip down the boards.

The only problem I still have is that you say this applies to new consumer units but this quote below seems to suggest that current units also have to have the non-flammable enclosure.

"421.1.201 Within domestic (household) premises, consumer units and similar switchgear assemblies shall comply with BS EN 61439-3 and shall:

(i) have their enclosure manufactured from non-combustible material, "

If I am still not seeing things correctly, I'd be glad of you shining a light on my errors

Thanks again

 

[EFLImpudence]

Thanks for your reply. Having read :
https://www.electricalsafetyfirst.o...es/technical-e-news/consumer-unit-mythbuster/

I am wondering if I have mis-interpreted the "Install a new metal 6 way split-load board " in my quote and when he says board, he means a full enclosure including the back (mounting-plate) which is why there is the need to strip down the boards.

No - 'board' likely just means the consumer unit; old term 'fuse board'.

The only problem I still have is that you say this applies to new consumer units but this quote below seems to suggest that current units also have to have the non-flammable enclosure.

No, not both. Either non-combustible CU or an enclosure for the CU.

"421.1.201 Within domestic (household) premises, consumer units and similar switchgear assemblies shall comply with BS EN 61439-3 and shall:
(i) have their enclosure manufactured from non-combustible material, "

You have to read it all - in order.

"421.1.201 Within domestic (household) premises, consumer units and similar switchgear assemblies shall
comply with BS EN 61439-3 and shall:
(i) have their enclosure manufactured from non-combustible material, or
(ii) be enclosed in a cabinet or enclosure constructed of non-combustible material and complying with Regulation
132.12.
NOTE: Ferrous metal, e.g. steel, is deemed to be an example of a non-combustible material."

In (i) the enclosure means the outside of the CU.

The electrical trade is not good on clarity; I think they do it on purpose.
You may also note that nothing is non-combustible; whether you can make a CU out of nothing is another matter.

 

[mointainwalker]

The electrical trade is not good on clarity; I think they do it on purpose.

Well;let's try and get a clear answer here. From everything so far, it seems that this electrician is correct to say that my installation ( can't copy pictures ) needs a metal enclosure either to replace or cover the existing Wylex plastic enclosure. Agreed ? If it isn't please say simply why it isn't

 

[EFLImpudence]

Well;let's try and get a clear answer here. From everything so far, it seems that this electrician is correct to say that my installation ( can't copy pictures ) needs a metal enclosure either to replace or cover the existing Wylex plastic enclosure. Agreed ?

Have we been told why it is thought you need a new CU?

IF you do have to have a new one it merely has to be non-combustible - whatever that means - metal being the only kind that has ever been considered thanks to the note below the regulation. I am sure some plastic ones were at least flame-retardant but they seem to have disappeared.