Notifiable work ??

[ban-all-sheds]

I have been doing a few alterations - extra sockets lights etc, now the customer wants power reinstating to a detached shed, there is a cable already trenched to the shed but has poor IR readings, so if I replace it, is it classed as a like for like which I believe is not notifiable but with all the changes to part p I have lost track of what is what. I do not normally do much domestic work mainly industrial/commercial

Despite the frequency with which we see it mentioned "like for like" is not a concept mentioned in any rules, regulations or laws!

Nor has Part P changed for several years.

 

[JohnW2]

Nor has Part P changed for several years.

Indeed it hasn't (I don't think it has ever changed, has it?), but I'm not sure I understand the relevance of that to this discussion about 'notifiability'. As I need not tell you, Part P has never said anything about notifiability.

Kind Regards, John

 

[ban-all-sheds]

Indeed it hasn't (I don't think it has ever changed, has it?)

Yes - in the first, and so far only, change, not long after it was introduced, they dropped P2, which made testing a requirement.

]but I'm not sure I understand the relevance of that to this discussion about 'notifiability'. As I need not tell you, Part P has never said anything about notifiability.

but with all the changes to part p I have lost track of what is what.

 

[JohnW2]

Yes - in the first, and so far only, change, not long after it was introduced, they dropped P2, which made testing a requirement.

Ah, I wasn't aware of that.

but with all the changes to part p I have lost track of what is what.

Ah, I see - I thought the comment was directed at me!

Kind Regards, John

 

[PBC_1966]

For reference:

As has been debated before, the problem is with defining what exactly constitutes "the installation of a new circuit" and "the replacement of a consumer unit."

Personally, I would say that taking the wording literally, "replacement of a consumer unit" means that a consumer unit (however defined) is removed and replaced with something else, which may or may not be a consumer unit. The earlier version of the regulations referred specifically to the "provision of a new consumer unit" being notifiable.

The whole wording of what's notifiable was a mess in the draft proposal (which would have made the installation of a battery powered doorbell notifiable work!), it was an ambiguous mess in the original legislated version, and this new version, while greatly simplified and removing many questions of notifiable vs. non-notifiable which existed before, is still badly written.

 

[JohnW2]

Personally, I would say that taking the wording literally, "replacement of a consumer unit" means that a consumer unit (however defined) is removed and replaced with something else, which may or may not be a consumer unit.

Agreed. However, if one removes a CU and essentially replaces it with 'nothing' (wiring sockets directly from incoming supply and with an FCU for lighting, I would not regard that as "replacing the CU with something else", and would therefore not regard it as notifiable.

The whole wording of what's notifiable was a mess in the draft proposal (which would have made the installation of a battery powered doorbell notifiable work!), it was an ambiguous mess in the original legislated version, and this new version, while greatly simplified and removing many questions of notifiable vs. non-notifiable which existed before, is still badly written.

Agreed, particularly in relation to the absence of clarity as to what constitutes a 'new circuit'. Furthermore, I cannot believe that they really intended that the installation of a new CU (where there was not one present before, hence no a 'replacement') should not be notifiable! Admittedly, that situation would probably nearly always be caught by 'new circuits', but that still doesn't excuse the wording they used!

Kind Regards, John

 

[PBC_1966]

However, if one removes a CU and essentially replaces it with 'nothing' (wiring sockets directly from incoming supply and with an FCU for lighting, I would not regard that as "replacing the CU with something else", and would therefore not regard it as notifiable.

Good point. I suppose it depends upon whether you could really achieve that by replacing the existing CU with "nothing," not even a junction box and a new length of cable to connect from the existing incoming supply cable to the existing sockets. Of course, if you could replace the CU with absolutely nothing to achieve it and that would be non-notifiable, but replacing the CU with a junction box etc. would make it notifiable, that would be ridiculous, since adding those same things to an existing circuit is not notifiable.

Then there's the whole issue we've debated before about what constitutes a "new circuit" if some or all of the branch circuit wiring is already there but currently unused. Could you do the same with the consumer unit? Removal of electrical equipment is never notifiable. If you remove an existing CU as one job, then go back later and install another CU as a separate job, would that be replacement, or merely removal followed by a later installation? How long would have to elapse between taking out the old and installing the new for it not to be considered a replacement? Of course, the time interval argument could then apply to the circuits being connected to the new unit - Would they be new circuits or merely old ones being reused?

The whole thing is so ambiguous that I don't think anyone can really be expected to know for certain what it means.

I cannot believe that they really intended that the installation of a new CU (where there was not one present before, hence no a 'replacement') should not be notifiable! Admittedly, that situation would probably nearly always be caught by 'new circuits', but that still doesn't excuse the wording they used!

If I recall correctly, the original rules made the "provision of a new consumer unit" notifiable. So why was that changed to just "replacement" of a consumer unit?

 

[EFLImpudence]

I don't think it is possible to replace a CU with nothing.

That would be removing it which is not notifiable.





This may be a daft question but do newbuilds actually have to notify the electrical installation?
If not, could that be why provision of a new CU was altered?

 

[crystal ball]

If the old CU was removed by the fairies ...... another thing I thought kitchens were special locations originally and then they were not or is that not a change to part p, when I say part p I mean anything connected to the whole shambles

 

[JohnW2]

Good point. I suppose it depends upon whether you could really achieve that by replacing the existing CU with "nothing," not even a junction box and a new length of cable to connect from the existing incoming supply cable to the existing sockets. Of course, if you could replace the CU with absolutely nothing to achieve it and that would be non-notifiable, but replacing the CU with a junction box etc. would make it notifiable, that would be ridiculous, since adding those same things to an existing circuit is not notifiable.

Quite. I would not regard 'replacing a CU' with JBs, and even FCUs as replacing it with more than "nothing" - since, as you say, I could have happily have added such things to the existing circuit (with the CU) without it being notifiable. Indeed, I would say the same if one of the 'new items' was a standalone RCD.

Removal of electrical equipment is never notifiable. If you remove an existing CU as one job, then go back later and install another CU as a separate job, would that be replacement, or merely removal followed by a later installation?

Indeed - the wording has not been thought through at all. I think we all have a pretty good idea of what they probably 'intended', but the words they wrote don't really properly (and clearly) reflect that intention.

How long would have to elapse between taking out the old and installing the new for it not to be considered a replacement? Of course, the time interval argument could then apply to the circuits being connected to the new unit - Would they be new circuits or merely old ones being reused?

I suspect that many people would probably say (not all that logically, IMO) that if circuits come to originate in a new CU, then they are 'new circuits', even if those circuits previously existed and were protected (in a different CU) by identical OPDs.

... and then, of course, what about replacing all the functional components (MCBs/RCBOs, RCDs, Main Switches etc.) in a CU - is that "replacing a CU"? It's easy to argue that it's not (replacing individual components certainly wouldn't be), but it would be plain daft if whether or not the work were notifiable depended only on whether or not the enclosure had been replaced!

If I recall correctly, the original rules made the "provision of a new consumer unit" notifiable. So why was that changed to just "replacement" of a consumer unit?

An extraordinarily good question. At least vthe old version was relatively (but not totally) clear!

Kind Regards, John

 

[PBC_1966]

This may be a daft question but do newbuilds actually have to notify the electrical installation?

It would be included with the notification for the whole kit and caboodle.

 

[PBC_1966]

I thought kitchens were special locations originally and then they were not or is that not a change to part p, when I say part p I mean anything connected to the whole shambles

Yes, that was a change in the notification rules - Under the earlier scheme certain work in a kitchen was notifiable, now it's not, unless it falls under the general category of a "new circuit" etc.

 

[JohnW2]

I don't think it is possible to replace a CU with nothing. That would be removing it which is not notifiable.

See what I've just written to PBC - in this context, I regard JBs and FCUs (and probably even a standalone RCD) as "nothing" - particular given that adding any of those things to the existing installation (with the CU) would not be notifiable.

This may be a daft question but do newbuilds actually have to notify the electrical installation? If not, could that be why provision of a new CU was altered?

The entire build, including its electrical installation will surely have to be notified to LABC (or whoever)??

Kind Regards, John

 

[EFLImpudence]

another thing I thought kitchens were special locations originally and then they were not

Kitchens were never actually "special locations"; some work in them was notifiable; now it is not.

 

[JohnW2]

If the old CU was removed by the fairies ......

If the fairies removed it, I don't think there would be any problem (and certainly no problem that anyone would ever discover ). However, as I've said, my personal opinion is that for you to 'openly' remove a CU and 'replace' it with items (JBs, FCUs etc.) that you would have been allowed to add to the circuit (without notification), anyway, would not be notifiable. IMO, for it to be otherwise would not be within 'the spirit' of the notification rules!

Kind Regards, John