Schedule4-How to rewire most of your house without notifying

[Paul_C]

As I asked Electrifying last night, am I missing something, because all that hassle and 'contriving' looks unnecessary to me. Why can't one simply replace all of the accessories and fittings under 1(a) and all of the ('damaged') cable, one-at-a-time under 1(b) - neither of which works appear to cease to be non-notifiable in a kitchen or special location?

That would be fine if you just wanted to replace what was there. If you wanted to add extra sockets, lights, etc. in the kitchen or bathroom then 1(a) & 1(b) wouldn't cover it.

I'm sure one could argue that lamps are not 'fixed'

In which case surely they wouldn't be covered by the building regulations anyway? Do you notify the local authority when you buy a new bedside lamp and plug it into an existing socket?

P.S. Actually, better make that a portable lamp in a kitchen, otherwise it would be covered by 2(c) anyway!

 

[JohnW2]

As I asked Electrifying last night, am I missing something, because all that hassle and 'contriving' looks unnecessary to me. Why can't one simply replace all of the accessories and fittings under 1(a) and all of the ('damaged') cable, one-at-a-time under 1(b) - neither of which works appear to cease to be non-notifiable in a kitchen or special location?

That would be fine if you just wanted to replace what was there. If you wanted to add extra sockets, lights, etc. in the kitchen or bathroom then 1(a) & 1(b) wouldn't cover it.

Yes, of course, but if you simply wanted to replace (not necessarily 'like-for-like', as we've often discussed), you could completely 're-wire' all of the house (apart perhasp from replacing the CU - see below) without needing to notify. That may well be feasible in a bathroom, but less likley in a kitchen if the existing installation is old.

As for the CU change, common sense (apart from anything else!) suggests that it ought to be notifiable, and 1(a)(ii) of Schedule 4 would appear to be saying that. However, given that there are those around here who have been insistent that we have to work to 'the word, the whole word and nothoing by the word' of the law, the question of the definition/meaning of 'a Consumer Unit' has to be considered. If the interpreters of the law decided to adopt the BS7671 definition, a Consumer Unit is a particular type of type-tested (when populated) distribution board. Hence, those 'word of the law' people might say that if one didn't use a type-tested unit (e.g.bought an empty enclosure and populated it oneself, maybe with 'non-recommended' devices), it would not count as a Consumer Unit and therefore would not be denied 'non-notifiability' under 1(a)

There is seemingly no limit to how silly this can get, given how badly the law has been written (virtually devoid of definitions).

Kind Regards, John

 

[Paul_C]

1. Work consisting of—

(a)replacing any fixed electrical equipment which does not include the provision of—.
(i)any new fixed cabling, or.
(ii)a consumer unit;.

There's good old Schedule 4 defining that new fixed cabling or a consumer unit ARE notifiable.

To be pedantic, it's not saying that they're notifiable. It's saying that they are not covered by the exemption for replacing fixed electrical equipment.

But while looking at 1(a)(ii), how about that consumer unit?

This has been hinted at before, but if you replace an existing consumer unit with a separate main switch and fuse/MCB distribution board (without a main switch), is that non notifiable? You haven't provided a new consumer unit as such.

 

[Paul_C]

Yes, of course, but if you simply wanted to replace (not necessarily 'like-for-like', as we've often discussed), you could completely 're-wire' all of the house (apart perhasp from replacing the CU - see below) without needing to notify.

Certainly. To simply replace everything which is there already (bar the consumer unit) with new is entirely possible under 1(b) for the cables and 1(a) for everything else.

As for the CU change {.....}

You beat me to it while I was typing!

There is seemingly no limit to how silly this can get, given how badly the law has been written (virtually devoid of definitions).

Indeed, that is one of the big problems.

As I mentioned above for a kitchen, what exactly is "food preparation facilities" supposed to mean? A stove or oven is used to cook food, so I think we'd probably all agree that they count. But what else?

 

[JohnW2]

As for the CU change {.....}

You beat me to it while I was typing!

Great minds

As I mentioned above for a kitchen, what exactly is "food preparation facilities" suppose to mean? A stove or oven is used to cook food, so I think we'd probably all agree that they count. But what else?

I'm not so sure that everyone would agree with that - look at commercial food preparation (restaurants etc.) where 'food preparation' is considered as a totally different activity from 'cooking', and often happens in a different room. As you say, goodness only knows what the writers of the legislation had in mind - I've always assumed that they probably meant 'worksurfaces' etc., but it could really mean anything. If one tries to bring some electrical common sense into it, one can only really understand their concern about the sink (water, and possibly a metal sink, in an area where 'portable' electrical devices are commonly used), and maybe also the fact that kitchens are often the place in the house where there is likely to be the greatest concentration of high-power 'fixed appliances' (a lot of which are 'electricity+water' appliances).

Kind Regards, John.

 

[Paul_C]

[I'm not so sure that everyone would agree with that - look at commercial food preparation (restaurants etc.) where 'food preparation' is considered as a totally different activity from 'cooking', and often happens in a different room.

O.K., I hadn't thought of that way of looking at it!

I've always assumed that they probably meant 'worksurfaces' etc., but it could really mean anything.

So if I have a utility room with a sink and a countertop alongside, normally used for laundry and similar things, but one day, say while adding a socket in the room, I stop and happen to use that work surface to make a sandwich, does that mean that the room has suddenly become a kitchen? Should I then stop work and notify before continuing with the additon of the socket?

 

[JohnW2]

So if I have a utility room with a sink and a countertop alongside, normally used for laundry and similar things, but one day, say while adding a socket in the room, I stop and happen to use that work surface to make a sandwich, does that mean that the room has suddenly become a kitchen? Should I then stop work and notify before continuing with the additon of the socket?

Who knows. If 'worksurfaces' was their intent, then I suppsoe they would have been thinking (and, if so, should have defined as) 'surfaces designed/intended for use in food preparation'. But it seems that they decided not to 'do definitions'!

Kind Regards, John

 

[Electrifying]

John and Paul - the problem with your suggestions (i.e. the making a kitchen not a kitchen, while you fit the electrics and John's 'replacing a damaged cable...one at a time), is that you are doing what BAS is complaining about - you are trying to make the law fit what you want to do.

What I was trying to show with my scenario is that you can do an awfull lot of DIY electrical work simply by following Schedule 4 to the letter........I have only added sockets and lights to existing circuits, and then removed some circuits.....but it's scary, isn't it.

here's how to rewire it youself, without notifying, and save yourself possibly thousands.

Bit of a statement.

This was a 'tongue in cheek' statement and a bit of a p**s take, if you like, at some of the DIYers who constantly look for loopholes and other possible ways of not notifying.

A bit like when the adverts say "Become an electrician in 5 days and earn £47,000 per year" - it can't happen!

Anyone who takes what I have suggested literally is mad.

As I said above, the point of the thread was to show how ridiculous it could be if you took Schedule 4 as it's worded..........rather than interpreting what the 'Building Regs' and the allowance of non-notifiable work was aiming to achieve.

In my opinion, they were trying to allow Mr un-qualified homeowner to do some minor electrical work without having to fork out loads of his hard earned cash - and that's what should be kept in mind when reading Schedule 4 - otherwise, as I've tried to show, it gets silly.

The guidance notes, provided by the secretary of state (Document P), the IEE, (EGTTBR) and other documents from the LABC and scheme providers are written to try and make understanding the Building Regs easier.
They try to explain the ways in which to comply.
But apparently, as they aren't 'The Law', we should ignore these.

I do agree, the whole thing could have been written a lot better, but it's pretty clear to me what the intention was - I'm just glad I don't have to worry about it.

 

[ebee]

Pointless!

Reminds me of the chappy who was NOT selling Lamps (Light Bulbs as some might call them) .

As the filament ones are being phased out in preference to energy saving types he was not selling lamps.

He was selling miniature room heaters that plug into lampholders.

As a by product of this heating up process then the units incidentally produced some light because the heating element glowed.

"But he was not selling filament lamps!"

Yer right!

 

[bernardgreen]

He was selling miniature room heaters that plug into lampholders.

There may be a market for miniature heaters to warm up lamp fittings which since being fitted with cold running CFLs have developed a condensation problem.

 

[ebee]

 

[Paul_C]

the problem with your suggestions (i.e. the making a kitchen not a kitchen, while you fit the electrics and John's 'replacing a damaged cable...one at a time), is that you are doing what BAS is complaining about - you are trying to make the law fit what you want to do.

It's not a case of "making it fit," it's just following the exemption rules of schedule 4 to the letter in the same way as the things you suggested.

The definition of a kitchen in schedule 4:

4. For the purposes of this Schedule—

“kitchen” means a room or part of a room which contains a sink and food preparation facilities;

So leaving aside the question of what "food preparation facilities" is supposed to mean, clearly if the room does not contain a sink then it is not a kitchen for the purposes of schedule 4. The definition doesn't say anything about whether the room was a kitchen, or whether it will be a kitchen when all works have been completed, or even whether there is any intent for it to be converted to a kitchen at some future date. It refers only to the present condition, so if there is no sink fitted in the room, then it isn't a kitchen at that precise moment in time, so the condition in 2(a) is satisfied. That is what the letter of schedule 4 says, just in the same way as the letter of schedule 4 allows one to replace every single socket, light, and light switch in the house under 1(a) and every single length of cable under 1(b) in your hypothetical example.

In my opinion, they were trying to allow Mr un-qualified homeowner to do some minor electrical work without having to fork out loads of his hard earned cash - and that's what should be kept in mind when reading Schedule 4 - otherwise, as I've tried to show, it gets silly.

But isn't that a case of trying to "make it fit" to what you think should have been said, or what you think the basic intent was?

To cite an example I mentioned here recently, a few months ago I installed a new ceiling fan in a living room which involved adding a joint box to an existing lighting circuit in the attic and running all of about 6 ft. of cable. Had it been a new light fitting, then I'm sure you will agree that it would have been exempt from notification by way of 2(c)(i), and in fact I could have added a switch and run the switch loop cable as well and it would still have been exempt. But because it's a fan and not a light, 2(c)(i) doesn't apply. Clearly the job was as minor as if it were a new light (more minor in fact, if the light had involved extra switch wiring). But there's no exemption for adding that ceiling fan in schedule 4.

The guidance notes, provided by the secretary of state (Document P), the IEE, (EGTTBR) and other documents from the LABC and scheme providers are written to try and make understanding the Building Regs easier.
They try to explain the ways in which to comply.
But apparently, as they aren't 'The Law', we should ignore these.

When things in those documents clearly contradict what the actual legislation says, then yes. As John has pointed out several times in other threads, if anything ever got to court, the court is supposed to look only at what the legislation actually says and means as written, not try to "make it fit" what it thinks the politicians and civil servants intended it to mean, or what it thinks it should say.

Leaving aside NICEIC, NAPIT etc. guidance, it doesn't take too long to realize that the officially issued guidance in the approved document for Part P contains things which contradict what the actual regulations say.

Look at table 1, which is supposedly a summary of the various exempt works as set out by schedule 4. It mentions the exemption for replacing a damaged cable for a single circuit, and even gives specific examples of how it might come to be damaged. But it also links to a footnote:

Replacing the cable for a single circuit only, where damaged, for example by fire, rodent, or impact. (a)

(a) On the condition that the replacement cable has the same current-carrying capacity and follows the same route.

Can you find where that condition is imposed by schedule 4? I certainly can't. The applicable part of schedule 4 says simply:

1. Work consisting of—

(b) replacing a damaged cable for a single circuit only;

There's nothing about the same current-carrying capacity or the same route in there.

Continuing down the table, it adds a footnote to the exemptions for adding socket outlets and lights:

(f) Only if the existing circuit protective device is suitable and provides protection for the modified circuit, and other relevant safety provisions are satisfactory.

Can you find where that condition is imposed by schedule 4?

There is plenty more, but you get the idea.

I'm just glad I don't have to worry about it.

Neither do those of us who just operate on the "Carry On Regardless" principle.

 

[JohnW2]

John and Paul - the problem with your suggestions (i.e. the making a kitchen not a kitchen, while you fit the electrics and John's 'replacing a damaged cable...one at a time), is that you are doing what BAS is complaining about - you are trying to make the law fit what you want to do. What I was trying to show with my scenario is that you can do an awfull lot of DIY electrical work simply by following Schedule 4 to the letter........I have only added sockets and lights to existing circuits, and then removed some circuits.....

As Paul has subsequently said, I think that his and my intention has been exactly the same as yours - to show what can be done without notification by following Schedule 4 'to the letter'. I agree that Paul' making a kitchen not a kitchen' is 'contrived' (even if probably still within 'the letter of the law'), but I don't think that anything else is.

In particular, you may have misunderstood what I meant by 'replacing damaging cable'. I was not, as others have hinted in the past, suggesting that cables should be deliberately damaged to make their replacement without notification lawful, per Schedule 4. Rather, I was considering the fact that cables become progressively damaged, by exposure to environmental and operational conditions, from the moment they have been put into service. By the time one is considering a re-wire, probably at least 2 or 3 decades down the road, there can be no doubt that the cable will have suffered some damage. Sure, the extent of that damage may not actually represent an electrical problem - but Schedule 4 says nothing about how damaged a cable has to be.

As I said above, the point of the thread was to show how ridiculous it could be if you took Schedule 4 as it's worded..........rather than interpreting what the 'Building Regs' and the allowance of non-notifiable work was aiming to achieve.

Indeed, and I (and I assume also Paul) have continued to pursue that very point. All our opinions of what the regs 'were trying to achieve' are obviously very different from the Devil's Advocate scenarios you presented and we are discussing.

In my opinion, they were trying to allow Mr un-qualified homeowner to do some minor electrical work without having to fork out loads of his hard earned cash - and that's what should be kept in mind when reading Schedule 4 - otherwise, as I've tried to show, it gets silly.

As above, I'm sure we understand the general intent. Some compassionate thoughts about DIYers 'hard earned cash' may have been part of it, but I imagine their underlying actual thought was probably that there were some minor works that they felt they could 'usually' trust a DIYer to do reasonably safely (both in 'design' and execution) without the need for that compliance with Part P to be certified by a qualified electrician. ... hence, for example, my recently expressed belief that their intent probably was that burying any cable underground should be notifiable (because of the many design/execution errors the untrained might make).

The guidance notes, provided by the secretary of state (Document P), the IEE, (EGTTBR) and other documents from the LABC and scheme providers are written to try and make understanding the Building Regs easier. They try to explain the ways in which to comply. But apparently, as they aren't 'The Law', we should ignore these. .... I do agree, the whole thing could have been written a lot better, but it's pretty clear to me what the intention was

I think you're being unnecessarily kind to the 'legislators'. Yes, we all have our own, I suspect very similar, ideas of what the intent of the legislation was. However, that's no excuse for legislation which (as you and others of us have shown) is so full of potential 'loopholes' that one is reliant on all these other documents, which do not come with the force of law, to explain to Joe Public (it doesn't really matter to self-certifying electricians) what the authors believe the intent of the law to be. Whilst the conclusions of the 'letter of the law' people around here do offend against common sense (and also against what we believe the 'intent' behind those words probably to be), no-one can deny that we live in a society in which we are not obliged to adhere with anything beyond the letter of the law.

Kind Regards, John.

 

[ban-all-sheds]

if the room does not contain a sink then it is not a kitchen for the purposes of schedule 4. The definition doesn't say anything about whether the room was a kitchen, or whether it will be a kitchen when all works have been completed, or even whether there is any intent for it to be converted to a kitchen at some future date. It refers only to the present condition, so if there is no sink fitted in the room, then it isn't a kitchen at that precise moment in time, so the condition in 2(a) is satisfied.

Here's another thought - not in keeping with the spirit of Part P, but...

If you're doing a major kitchen renovation, once you've removed the sink and the food preparation facilities, it's no longer a kitchen..

But there's no exemption for adding that ceiling fan in schedule 4.

Easily sorted - add the light and then replace it with the fan.

(a) On the condition that the replacement cable has the same current-carrying capacity and follows the same route.

Can you find where that condition is imposed by schedule 4? I certainly can't.

And if the cable had been damaged because it was too small, and got overloaded, or because it was concealed in the wrong place and was drilled into, it would be illegal to replace it with the same size or in the same place.

 

[Paul_C]

I was not, as others have hinted in the past, suggesting that cables should be deliberately damaged to make their replacement without notification lawful, per Schedule 4. Rather, I was considering the fact that cables become progressively damaged, by exposure to environmental and operational conditions, from the moment they have been put into service.

But deliberately damaging a cable is still within the letter of schedule 4 anyway. It just says that you may replace a damaged cable; it doesn't qualify that with anything about how or why the cable was damaged. So as long as the cable is "for a single circuit only," whatever we take that to mean as discussed before, simply taking your side cutters to it is sufficient to satisfy the condition in 1(b) for replacement without notification. So in effect, any cable (for a single circuit only) can be replaced without notification, since the only condition attached is easily satisfied.

Some compassionate thoughts about DIYers 'hard earned cash' may have been part of it, but I imagine their underlying actual thought was probably that there were some minor works that they felt they could 'usually' trust a DIYer to do reasonably safely (both in 'design' and execution) without the need for that compliance with Part P to be certified by a qualified electrician.

I'm going to be less generous. I would say that the concessions from notification were mostly just an attempt to stave off any backlash from a proposal to make just about everything electrical notifiable, except perhaps simple light fitting, socket, and switch replacements.

Whilst the conclusions of the 'letter of the law' people around here do offend against common sense (and also against what we believe the 'intent' behind those words probably to be), no-one can deny that we live in a society in which we are not obliged to adhere with anything beyond the letter of the law.

The thing is that the regulations in schedule 4 offend against common sense to a large degree even over matters upon which I think we would all be agreed as to the actual meaning.

Adding a socket (not in a kitchen etc.) which happens to be conveniently near the CU to just run the cable back to the existing MCB is exempt from notification under 2(c). But if you want to drop a new MCB in and connect that socket on its own new, dedicated circuit, then it becomes notifiable. Does that make much sense?

Adding a two dozen extra sockets around the house in the living room, dining room, bedrooms and hallways is exempt. But run 6 feet of cable to a new socket within a kitchen, and it's notifiable. Does that make much sense? (I'm talking from the point of view of what the average DIYer can, apparently, be trusted to do; it makes much more sense when we consider why the kitchen restrictions were actually put in place, as BAS has outlined recently in the other thread.)

But there's no exemption for adding that ceiling fan in schedule 4.

Easily sorted - add the light and then replace it with the fan.

Good point. Again, back to that "like for like" replacement which is often mentioned in some of the council guidance, but which doesn't actually appear anywhere in the regulations.