This has been debated many times, each edition of BS 7671 gives the date at which a design must comply, so if designed before that date then that edition does not apply, that is if you follow what is says in BS 7671.
However in real terms, no one is going to have every edition of BS 7671 so the EICR is not directly linked to BS 7671 although one can reference the book to show what section needs to be complied with when the design is altered.
However it is near impossible not to alter the design, if designed to use filament lamps and now fitted with LED then clearly a design change. And so many appliances stipulate not only the use of a RCD but actually state type A.
It is near impossible for anyone doing an EICR looking up every manufactures recommendations to see if a RCD is required. And when one does some times one is supprised, my solar panel inverter says use a type AC or better RCD, I did not expect it to say type AC.
So the inspector has to use his skill to decide if protentially dangerous or not, not if complies with BS 7671 or not. So the same thing coded C3 by one inspector can be coded C2 by another, and neither is wrong.
More than if it will pass or not, is the morrow question, your tenants can't fit RCD's them selves, only you can do that, and you have no idea what equipment they may be using, so in real terms it needs RCD protection.
As to SPD, that's not so cut and dried, if the equipment which could be damaged by a surge is yours, i.e. integral lights, then you can deside to take the risk, but if tenant provides bulbs, then really you must protect them, but no fixed requirement.
As electricians we devide the home into two sections, the installation, and current using equipment, but the landlord law splits it into portable equipment and the rest. So 18 kg I seem to remember is the demarcation line, with no wheels.
So the boiler needs inspecting when doing an EICR following new law, but often the electrician is not gas safe so can't open boiler to check. With commercial building we have a building manager who has to deside who tests what, so he can tell either the guy doing PAT testing or the guy doing the EICR to test the hand drier. But with domestic there is only the landlord, and he needs to specify who tests what.
So washing machine likely on wheels so PAT test, the tumble drier likely not on wheels so not portable, so who tests it? If there is a danger of an electric shock, then the EICR can fail it, But if some thing simply does not work, be it an immersion heater or smoke alarm that is outside his remit. So also looking for a fire inspection, maybe a pressure vessel inspection, a gas inspection, and if some one does two inspections together then he needs to still use diffrent forms, so the tumble drier even if inspected will not have the results on the EICR form.
It is a complete mess, and we are seeing the results, properties for rent are getting harder and harder to find, this area we are seeing loads of mobile homes as the regulations are not as strict.
www.legislation.gov.uk
