Why "No RCD protection on lighting circuit"?

[PBC_1966]

As a matter of interest, what would you feel in the case of a "registered third-party-certifier' (there apparently now are a few!) who was, as required, undertaking an EICR within 5 days of completion of work that (s)he had been supervising? In that case, there would be no doubt that the work was 'new work' - and I can but presume that the work would 'fail' the inspection, such that (s)he would not issue a Compliance Certificate, if the work was not BS7671-compliant.

I'm not familiar with the "registered third-party certifier" arrangement. But if the inspection is being done as a BS7671 inspection, I can't see it would make any difference. The inspection is done according to the current vesion of BS7671, so no RCD on the cables clearly is not in compliance with that current standard. But as I see it, it shouldn't make any difference to the code given just because the person carrying out the inspection knows that it was only just installed.

That can certainly be argued. However, it doesn't alter the fact that, with the regs as they are, someone could honestly sign the declaration on an EIC or MWC for such 'new work' without documenting the deviation

How so? If the current version of BS7671 requires RCD protection and you don't provide it, surely you need to note that as a departure on the certificate? (Unless one wishes to specify that it complies, specifically, with BS7671:2001 instead of BS7671:2008 or some such thing.)

 

[EFLImpudence]

A 'Third Party Inspector" is in charge of the work and must ensure that it complies.
He will not inspect the rest of the installation for an EICR.

I don't know why this is still going.
There may be some anomalies available if you want to fiddle the system but the rules are quite clear.

New work must comply.
Would you rather, when wanting an extra socket, the rules said you must update everything else as well?

 

[ban-all-sheds]

However, it doesn't alter the fact that, with the regs as they are, someone could not honestly sign the declaration on an EIC or MWC for such 'new work' without documenting the deviation

?

 

[PBC_1966]

There may be some anomalies available if you want to fiddle the system but the rules are quite clear.

New work must comply.

But the rules are not that clear. And comply with what? With BS7671 or just with the legal requirements of the building regulations? They're not the same thing, which is the whole point.

 

[JohnW2]

That can certainly be argued. However, it doesn't alter the fact that, with the regs as they are, someone could not honestly sign the declaration on an EIC or MWC for such 'new work' without documenting the deviation

How so? If the current version of BS7671 requires RCD protection and you don't provide it, surely you need to note that as a departure on the certificate? (Unless one wishes to specify that it complies, specifically, with BS7671:2001 instead of BS7671:2008 or some such thing.)

As BAS has pointed out, I omitted a crucial "not"! (now edited).

Kind Regards, John

 

[JohnW2]

A 'Third Party Inspector" is in charge of the work and must ensure that it complies.

Indeed.

He will not inspect the rest of the installation for an EICR.

You say that, but ...

Within 5 days of completing the work, the installer must notify the registered third-party certifier who, subject to the results and inspection being satisfactory, should then complete an electrical installation condition report and give it to the person ordering the work.
NOTE: The electrical installation condition report should be the model BS7671 form or one developed specifically for Part P purposes.

... I would say that, at the least, that is ambiguous.

Would you rather, when wanting an extra socket, the rules said you must update everything else as well?

I think the point being is made that neither of these extremes seems to be particularly reasonable.

Kind Regards, John

 

[JohnW2]

However, it doesn't alter the fact that, with the regs as they are, someone could not honestly sign the declaration on an EIC or MWC for such 'new work' without documenting the deviation

?

Indeed so - now corrected. My apologies.

Kind Regards, John

 

[JohnW2]

... But if the inspection is being done as a BS7671 inspection, I can't see it would make any difference. The inspection is done according to the current vesion of BS7671, so no RCD on the cables clearly is not in compliance with that current standard. But as I see it, it shouldn't make any difference to the code given just because the person carrying out the inspection knows that it was only just installed.

Agreed - but the more uncertain issue, certainly open to debate, is to whether you are right in your assumption that the coding of a non-compliance as C3 on an EICR necessarily means that the Part P requirement for "reasonable provisions ..." has been satisfied.

Kind Regards, John

 

[PBC_1966]

As BAS has pointed out, I omitted a crucial "not"! (now edited).

Ah, thanks!

I think the point being is made that neither of these extremes seems to be particularly reasonable.

Would you consider it more reasonable if the regulations contained something along the lines of saying that a new circuit, complete rewire, or replacement distribution panel necessitated the provision of RCD protection, but that changes and extensions of an existing circuit did not?

Agreed - but the more uncertain issue, certainly open to debate, is to whether you are right in your assumption that the coding of a non-compliance as C3 on an EICR necessarily means that the Part P requirement for "reasonable provisions ..." has been satisfied.

Well, I'm not sure what the consensus on the coding would be anyway, since I've seen some people, apparently in all seriousness, claim that they would give something more than a C3 to trivial things like no earth sleeving! So this is all on the assumption that the reasonable consensus is that it's C3 anyway.

That said, if no RCD protection is C3, then how can it not be reasonably safe? Surely if something were not reasonably safe, one could not justify giving a simple "Improvement recommended" code but should actually code it to indicate that there is potential danger?

In my mind, if you're not saying that something is potentially dangerous, then it must be reasonably safe.

 

[JohnW2]

I think the point being is made that neither of these extremes seems to be particularly reasonable.

Would you consider it more reasonable if the regulations contained something along the lines of saying that a new circuit, complete rewire, or replacement distribution panel necessitated the provision of RCD protection, but that changes and extensions of an existing circuit did not?

In a word, yes - but, as I'm been discussing with BAS, drafting, let alone implementing and policing any such (IMO 'reasonable') middle-of-the-road regulations might well prove to be next-to-impossible. For example, as BAS has pointed out, unless the regs could prevent it (which would be exceedingly difficult) some would 'wriggle' by making repeated 'changes and extensions' to existing circuits until they ended up with what was effectively a re-wire.

That said, if no RCD protection is C3, then how can it not be reasonably safe? Surely if something were not reasonably safe, one could not justify giving a simple "Improvement recommended" code but should actually code it to indicate that there is potential danger? In my mind, if you're not saying that something is potentially dangerous, then it must be reasonably safe.

Indeed - but the problem is that anything involving the concept of "reasonable" necessarily invokes a lot of judgement and inevitable differences of opinion. What is judged to be "reasonably safe" in terms of EICR coding (in the eyes of the IET/BSI, and electricians who make the on-the-spot judgement) may not be regarded as the application of "reasonable provisions ... for safety" to satisfy Part P (the ultimate arbiter being the Courts), or vice versa.

Kind Regards, John

 

[JohnW2]

deleted - I managed to 'do it again'!!

 

[EFLImpudence]

He will not inspect the rest of the installation for an EICR.

You say that, but ...

Within 5 days of completing the work, the installer must notify the registered third-party certifier who, subject to the results and inspection being satisfactory, should then complete an electrical installation condition report and give it to the person ordering the work.
NOTE: The electrical installation condition report should be the model BS7671 form or one developed specifically for Part P purposes.

... I would say that, at the least, that is ambiguous.

I would say it is wrong.
Even if that is correct, it is only going to cover the new work.
Please put ADP with OSG in bin. No wonder no one knows what to do.

If the Inspector does not have to supervise the work - as it states on the below website - and all you are going to get is a part EICR then why bother telling anyone the work has been done?

https://www.tradeskills4u.co.uk/posts/3rd-party-register
The certifier must be notified by the installer in advance, and the certifier involved throughout the installation, not just at the end. The third party certifier will complete a DCLG agreed third party certification report (an EICR is not acceptable) subject to satisfactory completion of inspection and testing, and give this to the person ordering the work. Electrical work must be notified by the certifier to their scheme within 5 days of completion, and this information will be forwarded to local authorities in accordance with the Regulations.

That could all be wrong as well I suppose.

 

[JohnW2]

... I would say that, at the least, that is ambiguous.

I would say it is wrong. Even if that is correct, it is only going to cover the new work. Please put ADP with OSG in bin. No wonder no one knows what to do.

It may be 'wrong', but ADP is surely the nearest we have to any 'official' statement of what is required of a registered third-party certifier to satisfy the law's requirement for notification.

If the Inspector does not have to supervise the work - as it states on the below website - and all you are going to get is a part EICR then why bother telling anyone the work has been done?

A 'part EICR' is not all one is going to get. If you believe ADP, the TPC's scheme will issue a Compliance Certificate to the occupier within 30 days.

Kind Regards, John