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DIY Electrical work and the law - changes to Part P

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ban-all-sheds

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PostPosted: Wed Apr 05, 2006 7:15 pm Reply with quote

Part P of the Building Regulations changes from April 6th 2006.

. . . . .

DIY Electrical work and the law

On January 1st 2005 legislation came into effect which brought electrical work in dwellings under the Building Regulations, and made it a controlled service. This amendment to the Building Regulations, known as "Part P", imposes safety requirements, and also classifies electrical installation work into two basic categories, notifiable and non-notifiable.

Essentially the distinction is between major work, or work in what are deemed high-risk areas such as kitchens, bathrooms and gardens, and minor work such as replacing switches or adding sockets to existing circuits. (NB to those with a knowledge of the IEE Wiring Regulations, the term "minor work" is used here in its generic sense rather than the meaning defined in the Wiring Regs.)

A very important and fundamental point to note is that DIY electrical work has not been outlawed. It has been brought within the remit of the Building Regulations and cannot be carried out as freely as it was before, and in many cases cannot be carried out without involving your local council, but you may still DIY.

Major work is classed as notifiable, i.e. it must be notified to your Local Authority's Building Control department (LABC). How this happens depends on who does it.

If the work is carried out by an electrician who is registered with one of the organisations who administer self-certification schemes, (sometimes referred to as "Competent Person" schemes) they carry out the work and report the details to their scheme organiser, who then notify the appropriate LABC that the work has taken place, and that it has been certified by the person who carried it out as being in compliance with the Building Regulations. You may be familiar with this method of operation if you have ever had windows replaced by a FENSA member.

If the work is carried out by someone who is not registered with one of the schemes, be they an electrician or another type of tradesman (e.g. kitchen fitter) who has chosen not to register, or a DIYer, then it must be notified to LABC in advance in the same way that any building work which requires their involvement is notified in advance. And just like when you are building an extension, or converting a loft, etc, there is a fee payable to LABC to cover their activities related to checking compliance with the Building Regulations. (But see "LABC Issues" below regarding this).

Another important point to note is that apart from a Building Inspector, nobody can certify someone else's work as being compliant with the Building Regulations. Unless arranged by or in cooperation with LABC, a 3rd party electrical inspection is of no value in terms of complying with the law.

The full text of the legislation can be found here: http://www.opsi.gov.uk/si/si2004/20043210.htm amended by the 2006 SI here: http://www.opsi.gov.uk/si/si2006/20060652.htm . It is worth making the effort to read and understand them, because there is a lot of misinformation on the Internet, some of it put out by organisations with a vested interest in pretending that DIY work is illegal, some of it by LABCs who have either misunderstood the legislation, or who are also attempting to mislead the public in order to reduce the amount of work notified to them by non-self-certifying people, some of it, surprisingly, by the ODPM themselves (The Office of the Deputy Prime Minister were responsible for the legislation), and much of it on electrical advice and discussion fora like this one.

At the time of writing (April 2006), the following work was classed as not needing notification to LABC:

Code:
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;

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

   (c) re-fixing or replacing enclosures of existing
       installation components, where the circuit
       protective measures are unaffected;

   (d) providing mechanical protection to an existing
       fixed installation, where the circuit protective
       measures and current carrying capacity of
       conductors are unaffected by the increased thermal
       insulation.

   (e) installing or upgrading main or supplementary
       equipotential bonding;

   (f) in heating or cooling systems -


          (i) replacing control devices that utilise existing fixed
              control wiring or pneumatic pipes;

         (ii) replacing a distribution system output device;

        (iii) providing a valve or a pump;

         (iv) providing a damper or a fan;


   (g) in hot water service systems, providing a valve or a pump;

   (h) replacing an external door (where the door together
       with its frame has not more than 50% of its internal
       face area glazed);

   (i) in existing buildings other than dwellings, providing
       fixed internal lighting where no more than 100m² of
       the floor area of the building is to be served by the
       lighting.


2. Work which -

   (a) is not in a kitchen, or a special location,

   (b) does not involve work on a special installation, and

   (c) consists of -


         (i) adding light fittings and switches to an
             existing circuit or

        (ii) adding socket outlets and fused spurs to an
             existing ring or radial circuit.


3. Work on -

   (a) telephone wiring or extra-low voltage wiring for the
       purposes of communications, information technology,
       signalling, control and similar purposes, where the
       wiring is not in a special location;

   (b) equipment associated with the wiring referred to in
       sub-paragraph (a).

   (c) pre-fabricated equipment sets and associated flexible
       leads with integral plug and socket connections.


4. For the purposes of this Schedule -

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

   "special installation" means an electric floor or ceiling
   heating system, an outdoor lighting or electric power
   installation, an electricity generator, or an extra-low
   voltage lighting system which is not a pre-assembled
   lighting set bearing the CE marking referred to in
   regulation 9 of the Electrical Equipment (Safety)
   Regulations 1994; and

   "special location" means a location within the limits of
   the relevant zones specified for a bath, a shower, a
   swimming or paddling pool or a hot air sauna in the
   Wiring Regulations, sixteenth edition, published by the
   Institution of Electrical Engineers and the British
   Standards Institution as BS 7671: 2001 and incorporating
   amendments 1 and 2.


Like any law, things can change, and you are urged to ensure that you make yourself familiar with the law as it stands now, not necessarily as it was when this document was written.

The starting point on the ODPM website for information related to Building Regulations is http://www.odpm.gov.uk/index.asp?id=1130474 and a list of the relevant legislation can be found at http://www.odpm.gov.uk/index.asp?id=1130483 .

It is in the nature of the Internet for sites to change, and it may well be that today, when you are reading this, the links above no longer work, and you will have to search for the pages you want.


Useful Information

On the ODPM website there are a number of "Approved Documents"
( http://www.odpm.gov.uk/index.asp?id=1130478 ). These are not definitions of the law, nor do they tell you what you must, or must not, do. Instead they give guidance on ways in which the law can be satisfied. They do point out that you are not obliged to adopt any solution contained in them if you prefer to meet the requirements in another way, but that said they are useful as they contain common sense advice and often there is no good reason not to adopt the solutions they contain.

Approved Document P can be found here: http://www.odpm.gov.uk/pub/323/ApprovedDocumentPElectricalsafetydwellings2006edition_id1164323.pdf.


Technical Requirements

The technical requirements laid down by Part P are remarkably simple. They are:

P1 Reasonable provision shall be made in the design and installation of electrical installations in order to protect persons operating, maintaining or altering the installations from fire or injury.

It is worth noting however that they apply to all work, not just notifiable work, no matter who does it. So a DIYer adding a socket or a fused spur to a ring final circuit must work to the same technical standards as a registered electrician doing a complete rewire.

The biggest practical issue that arises is testing. To carry out testing of electrical circuits requires expertise and equipment, neither of which are likely to possessed by the average DIYer. So although Part P allows a DIYer to replace an entire circuit cable if it is damaged, without notification, it is arguable that he could not be sure that he had done it properly unless he carried out a series of tests on it, something he would probably be unable to do.


The IEE Wiring Regulations, aka BS 7671

Surprisingly, perhaps, Part P does not alter the status of the Wiring Regulations. They are still non-statutory, and there is still no legal requirement to adhere to them in domestic installations. This is a source of great discomfort to many electricians, and some of them will jump through hoops to try and prove that they are mandatory, but the fact remains that they are not.

HOWEVER, adherence to them is a very good way of ensuring that you meet the technical requirements of Part P, and you would need a very good reason, and a very good understanding of what you were doing, to decide to not adhere to them.


LABC Issues

As mentioned above, some LABCs are spreading misinformation, either by accident or design, about the status and acceptability of electrical work done by DIYers or other non-registered people.

These include:

1) Stating that such persons simply cannot carry out notifiable work, and that it must be done by registered electricians. The legislation referenced above, Statutory Instrument 2004 No. 3210 The Building (Amendment) (No.3) Regulations 2004 makes it quite clear that this is not the case. LABCs are not allowed to refuse to process Building Notices submitted by non-registered people.


2) Stating that work carried out by a non-registered person must be inspected and tested by someone who is registered, or who they regard as qualified. Again, there is no mention of this requirement in the statutory instrument.

Recently the ODPM issued a circular to local authorities making it absolutely clear that they are not allowed to do this:

http://www.odpm.gov.uk/index.asp?id=1131042

Additionally, the new Approved Document P now explicitly says

1.26 The building control body may choose to
carry out the inspection and testing itself, or to
contract out some or all of the work to a specialist
body which will then carry out the work on its
behalf. Building control bodies will carry out the
necessary inspection and testing at their
expense, not at the householders' expense.


Unfortunately, many LABCs have been simply ignoring what the ODPM say, and persisting with their policy of requiring DIYers or other non-registered people to hire someone to inspect and test the work. The ODPM's position on this appears to be that if you are being told this by your LABC you should take them to court.

It will be interesting to see if LABCs change their behaviour given what the Approved Document now says…


3) Attempting to impose extra charges to cover the inspection and testing of work done by a non-registered person. An LABC may well elect to subcontract inspection and testing if they do not have the capacity to do it themselves, but they are not allowed to charge extra because of this – the cost to them of subcontracting must be borne by them

Individual local authorities co-ordinate their services regionally and nationally (and provide a range of national approval schemes) via LABC Services. ( http://www.labc-services.co.uk ).

I recently posed LABC services the following question:

"My local Building Control dept has told me that because of staffing problems they are unable to inspect some building work, and will have to sub-contract it, and that I will therefore have to pay this cost on top of their fees.

Are they allowed to do this?
"

Their reply was:

"Building Regulation fees are set to a scale that embraces the whole scope of what may be necessary in respect of checking and approving the plans and inspecting the work. The input necessary can vary according to the circumstances of a specific scheme, but the fees are not variable due to this feature.

The local authority has a legal duty to carry out the Building Regulation function to a proper degree. This can also vary in extent according to the demands of any scheme and considerable discretion rests with the authority. However they are responsible to give a proper service within the fee and cannot charge extra for the reason you mention. Indeed if they failed to inspect yet still charged you might have a case for a refund
."

. . . . .
. .
. .


Last edited by ban-all-sheds on Thu Jun 29, 2006 8:02 am, edited 1 time in total
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Jim2287

from United Kingdom

Joined: 22 Oct 2005
Posts: 226
Location: United Kingdom

PostPosted: Wed Apr 05, 2006 8:37 pm Reply with quote

Not much to do with Part P but it might have some relevance...

Old colour cable is not allowed to be used now, only EU harmonsied colours should be used.

True or False ?


You can use old colours on old colour installations, aslong as its not complete rewires ?

Fact not opinion please if you answer icon_razz.gif
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plugwash

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PostPosted: Wed Apr 05, 2006 8:55 pm Reply with quote

Jim2287 wrote:
You can use old colours on old colour installations, aslong as its not complete rewires ?


FACT: they have afaict been phased out of the IEE wiring regs this will now be a noncompliance with those if you use thier certs this will now have to be marked up as a deviation.
FACT: the laws themselves (EAW and part poo) afaict don't make any mention of this
OPINION:this by itself is unlikely to get you in legal trouble but if the work is notifiable it might give you problems with the LABC and the self cert schemes.
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PompeySparks

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PostPosted: Wed Apr 05, 2006 11:00 pm Reply with quote

You can still use old coloured cable as long as you sleeve the conductors in the new colours - Ugly but re-assuring if you still have 100m of 50mm SWA to use up!
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Stoday

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PostPosted: Thu Apr 06, 2006 1:09 am Reply with quote

ban-all-sheds wrote:

The technical requirements laid down by Part P are remarkably simple. They are:

P1 Reasonable provision shall be made in the design and installation of electrical installations in order to protect persons operating, maintaining or altering the installations from fire or injury.

It is worth noting however that they apply to all work, not just notifiable work, no matter who does it. So a DIYer adding a socket or a fused spur to a ring final circuit must work to the same technical standards as a registered electrician doing a complete rewire.

The biggest practical issue that arises is testing.




Really?

The old version of part P said:

P1. Reasonable provision shall be made in the design,
installation, inspection and testing of electrical installations
in order to protect persons from fire or injury.


That implies that the requirement to test has been relaxed.
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Stoday

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PostPosted: Thu Apr 06, 2006 1:18 am Reply with quote

ban-all-sheds wrote:


(h) replacing an external door (where the door together
with its frame has not more than 50% of its internal
face area glazed);

(i) in existing buildings other than dwellings, providing
fixed internal lighting where no more than 100m˛ of
the floor area of the building is to be served by the
lighting.



Been a bit generous with the copy/paste buttons Eh BAN?

WTF have these got to do with part P? Part P applies to domestic installations yet your copied paragraph (i) applies to buildings other than dwellings.

Not surprising, since (i) and (h) apply to part L. And I suspect (g) applies to some other AD part too.

I expect a suitably grovelling response on your part to these errors. icon_lol.gif
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ban-all-sheds

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PostPosted: Thu Apr 06, 2006 8:35 am Reply with quote

plugwash wrote:
Jim2287 wrote:
You can use old colours on old colour installations, aslong as its not complete rewires ?


FACT: they have afaict been phased out of the IEE wiring regs this will now be a noncompliance with those if you use thier certs this will now have to be marked up as a deviation.

FACT: This is quite true, according to the wiring regs you may no longer use the old colours at all, but EICs etc provide space for you to record deviations from BS 7671.
FACT: The cable specs have not changed apart from insulation colours, so it is in no way unsafe to use old colours.

Quote:
FACT: the laws themselves (EAW and part poo) afaict don't make any mention of this

FACT: Also quite true - using the old colours is not illegal.
FACT: There is a legal requirement to make reasonable provision in the design and installation of electrical installations in order to protect persons operating, maintaining or altering the installations from fire or injury.

Quote:
OPINION:this by itself is unlikely to get you in legal trouble but if the work is notifiable it might give you problems with the LABC and the self cert schemes.

OPINION: Given requirement P1, an excellent case can be made that using old colours to extend or repair old installations actually makes better provision for safety that arbitrarily introducing mixed colours.
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ban-all-sheds

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PostPosted: Thu Apr 06, 2006 8:42 am Reply with quote

Stoday wrote:
That implies that the requirement to test has been relaxed.

In the Building Regs it may have been relaxed, or more explicity transferred to LABC, but from a generic POV testing is still a Good Thing™, and probably the hardest thing for a DIYer to be able to accomplish.

A fact which should be particularly borne in mind by those who fail to notify.... icon_confused.gif
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ban-all-sheds

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PostPosted: Thu Apr 06, 2006 8:47 am Reply with quote

Stoday wrote:
I expect a suitably grovelling response on your part to these errors. icon_lol.gif

Don't hold your breath icon_wink.gif

It's true that Schedule 2B now contains paragraphs which are not related to electrical work (parts of (f), and (g), (h) & (i)). I couldn't decide whether to edit these out, or quote the schedule as it stands.

Opinions welcome....
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Stoday

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PostPosted: Fri Apr 07, 2006 12:56 am Reply with quote

ban-all-sheds wrote:
testing is still a Good Thing™, and probably the hardest thing for a DIYer to be able to accomplish.


It's hard for a DIYer to accomplish because cheap (i.e. non-pro) instruments for testing to BS7671 are not available. No cheap jap/chinese testers. I woinder why? Is it because no other country expects tests to be carried out as specified in out regulations? If so, are our testing procedures over the top? Is a simpler precedure appropriate for a DIYer (especially with the limitation on what he can do without notification)?
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ban-all-sheds

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PostPosted: Fri Apr 07, 2006 9:14 am Reply with quote

Kewtech do a basic continuity & IR tester whch isn't very expensive, which is probably all that a DIYer really needs. It can't do loop tests or RCD, but you can assume Ze or get it by inquiry, and as someone pointed out recently, we all just assume that MCBs are going to work as advertised, so why not RCDs?
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coshhassessor

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PostPosted: Fri Apr 07, 2006 11:57 am Reply with quote

I agree that testing is indeed a good thing, but
Quoting BAS:
"as someone pointed out recently, we all just assume that MCBs are going to work as advertised, so why not RCDs?"

Is it me, or does this fly in the face of the concept of testing everything within one iota of destruction to ensure it is "safe"? Especially given that an MCB or RCD failure could have very serious consequences?

BAS - love that .sig file

M
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Pens

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PostPosted: Fri Apr 07, 2006 12:47 pm Reply with quote

coshhassessor wrote:


BAS - love that .sig file

M


<<hates that sig file icon_wink.gif
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ban-all-sheds

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PostPosted: Fri Apr 07, 2006 1:18 pm Reply with quote

coshhassessor wrote:
BAS - love that .sig file

Pensdown wrote:
<<hates that sig file icon_wink.gif

Actually - it's a bit hacked about to get it into the 100char limit.

The full version should read:

"A good scientist has original ideas. A good engineer makes a design that works with as few original ideas as possible."

and it's meant to be pro-engineer.

Here are some others from the same site:

If something is worth doing once, it's worth building a tool to do it

Your problem is another person's solution; your solution will be their problem

The significant problems we face cannot be solved by the same level of thinking that created them -- Albert Einstein

One test is worth a thousand opinions

If you think good engineering is costly and time consuming, try bad engineering

Abraham Lincoln reportedly said that, given eight hours to chop down a tree, he'd spend six sharpening his ax
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Stoday

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PostPosted: Fri Apr 07, 2006 1:47 pm Reply with quote

ban-all-sheds wrote:

One test is worth a thousand opinions


One screw is worth a thousand piccies icon_lol.gif
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