Is moving a light switch in the kitchen allowed/notifiable?

[JohnW2]

I use 230 as that is what I think is meant by Uo/Ze (or Zs).

That obviously is what is meant by U0/Ze (or U0/Zs) - but where does that expression for PFC/PSCC come from? Whatever, it seems that you are doing differently from at least some other electricians, who record the PFC/PSCC dsiplayed by their meter (which does not use U0)

I never have - that would mean a Ze of 0.03833Ω

It would, and I've certainly seen nothing like it, either - but the implication of all the regs and testing guidelines, and the existence of OPDs rated above 6kA, presumably implies that these very high PFCs/PSCCs must exist somewhere.

Yes, but as there is only provision for the value to be recorded once. It would seem to me that this figure should be regarded as having been used for the all readings on the certificate.

Are you perhaps reading too much into that provision on the form. You seems to be assuming it is a statement of the value which has been used for all calculations, but are you sure that it's not simply meant to be a statement of what the declared U0 actually is - i.e. to distinguish a 1-phase '230V' supply from other supplies?

I admit that MCBs do not appear to have been altered to allow for the change but, surely, the powers that be must have deemed this acceptable.

I'm not sure there would have been any need, would there? The only thing MCBs know about is the current flowing through them and, as we've discussed, the arbitrary change of U0 from 240V to 230V (without a change in supply voltage) obviously would not have changed the current flowing in response to an actual fault, even if some ('silly'!) calculations might think that it had changed

The current drawn by, say, a particular shower did not suddenly change on the day that 'political' change occurred but, per your views, the design current of the circuit did change on that day.

No it didn't because, as I have previously said, it is not necessary to calculate for a shower circuit because the MIs state what CPD to use.

You may not see a need to calculate design current, but if you did calculate it using your method, it would have changed with the change in U0. I still question the correctness of 'obeying the MIs' (right or wrong!) without determining design current for yourself and hence determining whether or not the circuit was compliant with 433.1.1(i).

I do not mean that I would ignore any regulations but it would seem, as is apparent in many topics which you raise, that house circuits in general are greatly over-engineered and very safe.

Of course, but we're into to areas of things that we would not want to discuss in public. I'm quite sure (and think you are as well) that, because of all the 'margins', one could go way into 'non-compliant' territory in relation to all sorts of things and still have a very safe domestic installation. However, as I said, we don't generally talk about such things - and certainly don't advocate/ suggest/ advise them!

Kind Regards, John

 

[SimonH2]

Hmm, puts popcorn aside Nothing like mention of Part P to get a discussion going !

My 2d worth ...

Back to the OPs question, which I struggled to remember. The drawing doesn't show where the sink is, or any dimensions. IIRC from another thread, the regs somewhere specify 3m from the sink as the boundary for "kitchen area" - so potentially the switch could be outside the special area if the kitchen is large. I'm certainly relying on this myself.

PrenticeBoyofDerry says he likes to notify stuff that some think isn't notifiable. Really, that's no problem when it only costs £1.50 - and if I was having some work done and it only cost that then I'd probably have it notified just so there's more bits of paper should I sell. Working on the basis that if there's a big wad of certificates, it's unlikely someone will go through them all and compare with what's actually in the property But, if I'm doing something myself, then I'll look very hard into whether it's is notifiable or not since the cost is about £150 for my LABC (it would be £225 if I didn't have the means to provide test results). If the law says I can save £150 (or £225) then am I wrong to take advantage of that, given that it won't make the slightest difference to whether the work is safe or not ?

And I agree with B-A-S, the law as written says certain things are not notifiable - until the law changes then it doesn't matter what LABC or the IEE say, that is what the law says. It says I can replace any item of equipment, and does not in any way even suggest that it should be "the same" or "in the same place" - so that means that yes, you can replace a bit of equipment, with something different, in a different location*, in a kitchen or bathroom.
* Subject to the existing cable reaching since a longer cable would invoke the "does not involve the provision of any new fixed cabling" clause (1(a)(i)).

In the example of fitting a bigger shower to replace a smaller one. The replacement itself would not be notifiable - but the necessary work to make it safe (and therefore legal) "might be" so lets look at that.
Replacing the supply cable with a larger is allowed by 1(b) which does not include any words along the lines of "with the same CSA or current carrying capacity. Ditto replacing the MCB with one of a higher rating (after upgrading the cable) which is allowed under 1(a).
So it looks to me that, as long as you make suitable provision for safety (ie use the right size of cable etc), then the shower upgrade is not notifiable according to what the law actually states - even though many believe it should be, and it was quite possibly intended that it should be by those that instigated the legislation.

 

[JohnW2]

My 2d worth ....

FWIW, I agree with everything you say.

Kind Regards, John.

 

[ban-all-sheds]

Hmm, puts popcorn aside Nothing like mention of Part P to get a discussion going !

I thought we were discussing Schedule 4, not Part P...

Back to the OPs question, which I struggled to remember. The drawing doesn't show where the sink is, or any dimensions. IIRC from another thread, the regs somewhere specify 3m from the sink as the boundary for "kitchen area"

No - the regulations say “kitchen” means a room or part of a room which contains a sink and food preparation facilities. No definition of the boundaries enclosing the "part of a room" which is a kitchen.

So on the one hand if you had a large room which was a kitchen, and you put a dining table and chairs in it, I'd say that the whole room was still a kitchen.

But OTHO if you had a truly open-plan living space it's quite possible you could point to an area less than 3m from the sink and justifiably claim that it was not in any way part of the kitchen area - anybody with a current Ikea catalogue can turn to p22 or 52 and see examples.

Replacing the supply cable with a larger is allowed by 1(b) which does not include any words along the lines of "with the same CSA or current carrying capacity.

If it's damaged...

So it looks to me that, as long as you make suitable provision for safety (ie use the right size of cable etc), then the shower upgrade is not notifiable according to what the law actually states - even though many believe it should be, and it was quite possibly intended that it should be by those that instigated the legislation.

We come back to the point I made a few months ago.

The only time when such an interpretation is going to matter, really matter, is if you should end up having to defend/justify it in court.

At which point the willingness of courts to consider what was intended by legislation could leave you on very thin ice, had you any legs left to stand on.

 

[SimonH2]

I thought we were discussing Schedule 4, not Part P...

You can't discuss them in isolation. But you are correct

No - the regulations say “kitchen” means a room or part of a room which contains a sink and food preparation facilities. No definition of the boundaries enclosing the "part of a room" which is a kitchen.

Well it specifically says "room or part of a room", thus the wording is there for part of a room to not be a kitchen. So the law as written does not require all of a room to be the kitchen just because it has a sink and food preparation facilities. Since it doesn't define when each definition should be used, it just shows yet another area where the law is deficient.

The 2006 version of the building regs said As a guide only, in open plan areas the zone of the kitchen may be considered to extend from the edge of the sink to a distance of 3m or to a nearer dividing wall.
So clearly at some point the people writing the documents intended that a large room with sink at one end wouldn't automatically all be kitchen. So the law as written simply isn't clear one way or the other The 2006 version gave "guidance", the 2010 version doesn't.

Replacing the supply cable with a larger is allowed by 1(b) which does not include any words along the lines of "with the same CSA or current carrying capacity.

If it's damaged...

Doesn't say how it got damaged. Oops, just missed with the hammer

At which point the willingness of courts to consider what was intended by legislation could leave you on very thin ice, had you any legs left to stand on.

The courts have to consider what was written in the law. There have indeed been cases where the judge has effectively said the law is a crock of manure, but he's powerless to change it. Where the judge does have discretion is in how things are interpreted. There's not much interpretation needed for much of this - if the law says "you can do X without notifying", then that's what the law says. The fact that some of it is stupid, and in cases not consistent with other bits of the same act doesn't come into it.

 

[scousespark]

That's got nothing to do with Part P. If somebody did as you said, they would be doing something beyond their level of capabilities. Your example feeds the argument for the scheme operators, when they say that only qualified electricians should be able to work in the domestic field.

It does, indeed, feed the argument that all electrical work should be notifiable, and either self-certified (ideally with some checks) or certified by LABC inspectors or their appointees.

However, I think my point has got everything to do with Part P as it is. That point was that even a job which most/all people would agree is not notifiable under Part P (as it is) could be done badly/dangerously - so whether or not something could be done dangerously is not a helpful criterion in relation to trying to interpret what is notifiable under the present Part P.

Kind Regards, John.

Are you for real? Do you really think changing a faceplate should become notifiable under Part-P? How many inspectors do you think the country would need, if Schedule 4 was removed and every job became notifiable?

 

[JohnW2]

That point was that even a job which most/all people would agree is not notifiable under Part P (as it is) could be done badly/dangerously - so whether or not something could be done dangerously is not a helpful criterion in relation to trying to interpret what is notifiable under the present Part P.

Are you for real? Do you really think changing a faceplate should become notifiable under Part-P? How many inspectors do you think the country would need, if Schedule 4 was removed and every job became notifiable?

I don't think you can have properly read what I wrote (and you quoted), since I was implicitly agreeing with what you've just written.

I wasn't saying that anything should or should not become notifiable. What I said was that, since even the smallest/simplest of jobs can be done badly/dangerously, that criterion cannot be used to decide what is and isn't notifiable. The implicit bit I didn't add, since I presumed it would be obvious to all readers (although seemingly not you) was "...since that would obviously result in any work, no matter how small, becoming notifiable".

There are, of course, a good few people (probably all of them electricians) who do believe that all electrical work should be notifiable, or even that all 'DIY' electrical work should be outlawed. However, I certainly don't subscribe to that view, not the least because it would shoot me in the foot in a big way!

In trying to think how the system might be improved (and I think most of us agree that it needs some improvement), one could observe that, in what you write, you seem to be assuming that 'notifiability' implies the need for some sort of certification (self-certification or LABC inspection/ certification). However, that's not necessarily the case. One could have a situation in which all work was notifiable, but LABC had discretion to decide what needed to be inspected, possibly with inspection of a random sample of works, both minor works undertaken by 'DIYers' and also work self-certified by electricians. Just a thoiught!

Kind Regards, John.

 

[scousespark]

That point was that even a job which most/all people would agree is not notifiable under Part P (as it is) could be done badly/dangerously - so whether or not something could be done dangerously is not a helpful criterion in relation to trying to interpret what is notifiable under the present Part P.

Are you for real? Do you really think changing a faceplate should become notifiable under Part-P? How many inspectors do you think the country would need, if Schedule 4 was removed and every job became notifiable?

I don't think you can have properly read what I wrote (and you quoted), since I was implicitly agreeing with what you've just written.

I wasn't saying that anything should or should not become notifiable. What I said was that, since even the smallest/simplest of jobs can be done badly/dangerously, that criterion cannot be used to decide what is and isn't notifiable. The implicit bit I didn't add, since I presumed it would be obvious to all readers (although seemingly not you) was "...since that would obviously result in any work, no matter how small, becoming notifiable".

There are, of course, a good few people (probably all of them electricians) who do believe that all electrical work should be notifiable, or even that all 'DIY' electrical work should be outlawed. However, I certainly don't subscribe to that view, not the least because it would shoot me in the foot in a big way!

In trying to think how the system might be improved (and I think most of us agree that it needs some improvement), one could observe that, in what you write, you seem to be assuming that 'notifiability' implies the need for some sort of certification (self-certification or LABC inspection/ certification). However, that's not necessarily the case. One could have a situation in which all work was notifiable, but LABC had discretion to decide what needed to be inspected, possibly with inspection of a random sample of works, both minor works undertaken by 'DIYers' and also work self-certified by electricians. Just a thoiught!

Kind Regards, John.

Okay John, I see your point now. On your follow up points/

I don't know any electricians who would want to take on loads of small jobs (which are currently non-notifiable). I believe that it's the scheme providers who want that change to Part-P and there is an e-petition from an ECA director, who wants to maintain part-P on the basis it has made domestics so much safer .

Also, I'd hate it to be left to the LABC to decide which jobs they want to cover and which they don't. It's bad enough the differences between them when taking qualifications into account. You can have 2 adjacent properties, in different council area. One can accept a set of C&G quals and the other demands payment to get a job checked by a 'competent' electrician. One would see it a licence to print money and another wouldn't be bothered.

 

[JohnW2]

Okay John, I see your point now. On your follow up points/ .... I don't know any electricians who would want to take on loads of small jobs (which are currently non-notifiable).

Of course not, and the provision for some small jobs being non-notifiable probably was at least partially based on that. If electricians do tiny jobs, it's difficult to see how it could be financially sensible for both them and the customer.

I believe that it's the scheme providers who want that change to Part-P and there is an e-petition from an ECA director, who wants to maintain part-P on the basis it has made domestics so much safer .

As we've discussed to death quite recently, any argument for Part P based on safety (avoidance of deaths/serious injuries) is fatally flawed, since, statistically speaking, even before Part P domestic electrical installations were incredibly 'safe' - compared with many of the othe risks faced by people every day.

Also, I'd hate it to be left to the LABC to decide which jobs they want to cover and which they don't. It's bad enough the differences between them when taking qualifications into account. ... One would see it a licence to print money and another wouldn't be bothered.

There certainly would be problems, but I suspect that some such system could be made to work (sensibly) if people really wanted it to. I would certainly welcome some system which facilitated some random 'checking' (by whoever, not necessarily LABC) of any electrical work (whether currently notifiable or not) whether or not undertaken by self-certifying electricians.

Kind Regards, John

 

[D4dog]

This is a fascinating topic, but it is all rendered useless when you try to put part p into action. I did all the wiring, sockets, switches, boiler controls, shower controls etc for my extension ( I am a systems engineer - but I cannot self certfiy). Building control was informed, and correct procedures androutine inspections followed. However, when it came to final inspection, the building control Officer admitted that:

Nobody in the building control team was qualified to do a final inspection;
No local electrician will sign off somebody else's work.

THe council also tried to make me pay for an independent test of the entire proeprty - I pointed out that such tests are not at the householders expense (iaw part P!)

In the end, the buidling conttrol officer, accompanied by an electrician, tested the earth continuity, inspected one socket and signed off the entire installation. And that was for a new kitchen, 2 bathrooms and 2 bedrooms.

So much for Part P.

 

[EFLImpudence]

Well done.

I keep telling people -

Never assume those in charge know what they are doing.

 

[JohnW2]

Nobody in the building control team was qualified to do a final inspection;
No local electrician will sign off somebody else's work.
In the end, the buidling conttrol officer, accompanied by an electrician, tested the earth continuity, inspected one socket and signed off the entire installation. And that was for a new kitchen, 2 bathrooms and 2 bedrooms.

That's the problem, but it obviously does not have to be like that. Would we tolerate a situation in which, because there were not enough people qualified to certify the airworthiness of aircraft, some such certification was done half-heartedly by inadequately qualified personnel and some was allowed to slip through loopholes and not be done at all?

So much for Part P.

Well, as many people,including myself, keep saying, there's nothing wrong with Part P, per se. That merely requires that anyone (DIYer, self-certifying electrician or other electrician) undertaking any electrical work (whether currently notifiable or not) to make reasonable provision to avoid a risk of fire or injury - and no-one (no sensible person!) can really argue with that requirement. The problems all relate not to Part P itself, but to the unsatisfactory systems which have been put in place for notification and certification that work has been undertaken in compliance with Part P.

Kind Regards, John.

 

[JohnW2]

I keep telling people - Never assume those in charge know what they are doing.

Over the years and decades, I've had to deal regularly with regulators in several different fields (never Building Control!) and what you say has applied 'across the board' in my experience.

However, I have to say that things have tended to improve over the years. Whereas 'regulators' in government etc. departments were once mainly administrators who knew nothing of the field they were regulating or, at best, those who had failed to establish academic, industrial, commercial or other professional careers in their fields, there are increasingly some very high calibre people getting involved, either as regulators or, at least, advisors to regulators. There is also now a healthy and thriving two-way movement between government regulatory departments and academia, industry and commerce in many fields.

Kind Regards, John.

 

[ban-all-sheds]

You can't discuss them in isolation.

Actually you can - they are completely separate - nothing in Schedule 4 or Part 3 has any effect on Part P, and vice-versa.

Well it specifically says "room or part of a room", thus the wording is there for part of a room to not be a kitchen. So the law as written does not require all of a room to be the kitchen just because it has a sink and food preparation facilities.

But if all you use it for is a kitchen, then is it not all a kitchen, no matter what size it is?

Since it doesn't define when each definition should be used, it just shows yet another area where the law is deficient.

It's badly written because it was not based on any unambiguous definitions. With special locations they were OK because they could refer to the BS 7671 definitions of Zones. Maybe they should have defined their own "zone of notifiability" as being 3m from a sink or to a dividing wall, whichever is less.

But they didn't.

The 2006 version of the building regs said As a guide only, in open plan areas the zone of the kitchen may be considered to extend from the edge of the sink to a distance of 3m or to a nearer dividing wall.

Even that doesn't help.

Does a dividing wall have to be full height? e.g. if I remove the wall between my kitchen and my dining room (which as it happens has the sink against it) down to the height of the sink, do I still have a dividing wall, or does my kitchen area now extend 3m into my dining area?

Or what if my sink was opposite a door into the kitchen and less than 3m from it, and I remove the door - is it now open plan?

If not, does it become open plan if I widen the opening? If I widen it a lot, and make the top arched?

So clearly at some point the people writing the documents intended that a large room with sink at one end wouldn't automatically all be kitchen.

Did they?

Or did they intend to deal with open-plan situations?

The courts have to consider what was written in the law. There have indeed been cases where the judge has effectively said the law is a crock of manure, but he's powerless to change it. Where the judge does have discretion is in how things are interpreted. There's not much interpretation needed for much of this - if the law says "you can do X without notifying", then that's what the law says. The fact that some of it is stupid, and in cases not consistent with other bits of the same act doesn't come into it.

Courts can, and do, interpret legislation on the basis of what they think the legislators intended.

So if, for example, a judge decided that what was intended by "part of a room" was an open-plan space, and not something which was plainly a kitchen room which just happened to be large, then he is free to do so, and your claim that the socket you put in the corner to allow you to use that corner of the room to work at your laptop was not notifiable would fail until and unless you could get a higher court to rule differently.

The other thing they do is a sort of mens rea test. If they believe that you have done something just to evade the law then they can disregard it. So, for example, a judge could easily decide that even though the law is unambiguous about replacing damaged cables, if you'd damaged them deliberately in order to make their replacement non-notifiable you could not claim the exemption. And again you'd be stuffed until a successful appeal.

This is what I meant above, and on previous occasions, about the only time it really mattering whether you're right about something being non-notifiable would be if it got to court. At which point if you'd done something artificial which was clearly done with the intent of making the work fit the written category of non-notifiable then you should not be surprised if the court disagreed with you.

 

[ban-all-sheds]

Would we tolerate a situation in which, because there were not enough people qualified to certify the airworthiness of aircraft, some such certification was done half-heartedly by inadequately qualified personnel and some was allowed to slip through loopholes and not be done at all?

Or the sea-worthiness of large, shallow-draught, top-heavy cruise ships?