EICR Fail Codes

[denso13]

As to the example given of gas pressure, that's a fairly simple one.

Well perhaps but so should this be...

If the CU isn't in an escape route, then don't even mention it.

It should be either acceptable or not and existing plastic consumer units should either be acceptable or not. I'm obviously missing something.

 

[JohnW2]

It should be either acceptable or not and existing plastic consumer units should either be acceptable or not. I'm obviously missing something.

As I've explained, BS7671 says nothing about what is, or is not, acceptable in terms of things that were compliant with regs when installed, but not compliant with current regs (merely saying that they are "not necessarily unsafe") and certainly do not (and, realistically, could not) require that every electrical installation be brought into compliance with all new/changed regs whenever they were published.

Kind Regards, John

 

[denso13]

As I've just written, in the real world there may not be a practically-implementable 'right/wrong answer'. In the example I just posted, what objective criteria would you specify for differentiating between 'corroded brake pipe' (=fail) and 'superficial corrosion of brake pipe' (=pass, with advisory)?

I get and agree with what your saying here. But how hard would it be to say that existing plastic consumer units do not need upgraded to the 18th edition and should be a code 3 or not coded at all (one or the other). Is that so difficult.

I genuinely can't understand why so many things seem to be subjective when, for example, you (the powers that be) could surely state "you can have an existing plastic consumer unit or you can't"

 

[denso13]

As I've explained, BS7671 says nothing about what is, or is not, acceptable in terms of things that were compliant with regs when installed, but not compliant with current regs (merely saying that they are "not necessarily unsafe") and certainly do not (and, realistically could not) require that every electrical installation be brought into compliance with new regs whenever they were published.

Agreed again. This started off from my perspective of comparing gas and electrical regulations and that gas decisions are straightforward. That could be debated but I do agree there is a lot of guidance for deciding on AR, ID or NTS on gas installations.

In contrast for EICRs and wider regulations there seems to be a lot of subjectivity. I know you have explained how they work and my use of the term "correct" is incorrect.

However, there is no good reason for not defining things properly within the electrical regulations and no reason why they can't state how an existing plastic consumer unit should be coded. Definitively.

I know they don't, I am not arguing they do. I am arguing that they should. This is what happens most of the time with gas regulations which is where the comparison started.

 

[JohnW2]

I get and agree with what your saying here. But how hard would it be to say that existing plastic consumer units do not need upgraded to the 18th edition and should be a code 3 or not coded at all (one or the other). Is that so difficult.

Theoretically not difficult (in that case), no - but who/what are you suggesting should 'say that' (and make the decision to 'say that'). The Wiring Regs (BS7671) say nothing specifically about the coding on an EICR of anything.

I genuinely can't understand why so many things seem to be subjective when, for example, you (the powers that be) could surely state "you can have an existing plastic consumer unit or you can't"

As above, I agree in that particular case, although I'm not sure what 'powers that be' would necessarily state (or necessarily want to state) things like that. Don't forget that the 'Wiriing Regulations' are published (jointly) by a Standards institute, not a 'regulator' (even the other co-author, the IET, is not 'a regulator').

However, there are many electrical issues more akin to the 'corroded brake pipe' I've been talking about - and, unless you can come up a practical method of quantifying the degree of corrosion (and thereby establishing some objective numerical 'limit') (and similar for all other issues), you're stuck with human judgement (hence 'variability'), aren't you?

Kind Regards, John

 

[JohnW2]

This started off from my perspective of comparing gas and electrical regulations and that gas decisions are straightforward.

I think one of the issues here may be the fact that, in contrast with gas, the electrical industry is essentially unregulated. The only 'law' relating to electrical installations is Part P of the Building Regulations, and that is literally just one sentence saying that electrical work must be done safely. Nothing more than that.

Kind Regards, John

 

[denso13]

However, there are many electrical issues more akin to the 'corroded brake pipe' I've been talking about - and, unless you can come up a practical method of quantifying the degree of corrosion (and thereby establishing some 'limit') (and similar for all other issues), you're stuck with human judgement (hence 'variability'), aren't you?

Of course. For gas you could come across a corroded flue or any number of subjective decisions such as "adequately supported flue". What is too corroded or what does adequately mean? Nevertheless, I don't see many queries on a landlords gas safety check but this forum alone is littered with complaints about EICRs. Without looking I think you have criticised the situation with the "new" landlords EICR regime on a fairly regular basis (apologies if I'm wrong on that).

It seems on this thread though that, while you aren't necessary defending things, you are happy to accept "that is just the way it is and it is necessarily subjective". Do you not think it could be better.

The next time someone asks about coding on an EICR will you say "that's just the way it is"? You haven't done much criticising on this thread.

 

[securespark]

It's good that we agree - but, if this were an EICR being done on a PRS property, per recent legislation, I wonder what, if the DNO 'decided to do nothing', this would mean in relation to the apparent legal requirement that any C1/C2s be 'remedied within 28 days' ?!

Surely they are not covered by the EICR and therefore no codes should be applied to those situations. Therefore the 28 day limit does not apply.
What I have done, and what I believe every spark should do, is to fill out the EICR with only codeable faults covered by the report.
Any other dangerous situations, eg a cast cut-out or a damaged meter or a faulty extension lead etc..... ought to be mentioned in a letter or note which you present to the customer and if possible, get them to sign it to say they understand there is a dangerous situation present. If there is a fault associated with DNO or meter company equipment, I would ring the company to report the situation.

 

[EFLImpudence]

If that's the case, and I don't doubt it is, you can't really criticise "inspectors" for taking different views.

You can't, but that is the cause of the problem.

The regulations say a certain quite specific thing fairly concisely and then several people and/or organisations find it necessary to write several books about what they think it means.

 

[JohnW2]

Of course. For gas you could come across a corroded flue or any number of subjective decisions such as "adequately supported flue". What is too corroded or what does adequately mean? Nevertheless, I don't see many queries on a landlords gas safety check but this forum alone is littered with complaints about EICRs.

I obviously don't know how common, or how potentially wide-ranging (i.e. potentially costly) those subjective decisions about gas safety are. The increased amount of recent discussion of, and complaints about, EICRs (here and elsewhere) is a consequence of the recent legislation relating to privately rented property ...

Without looking I think you have criticised the situation with the "new" landlords EICR regime on a fairly regular basis (apologies if I'm wrong on that).

I have. There have always been a good few moans about the coding of things on EICRs (and suspicions that some were coding things 'unnecessarily' in an attempt to generate work) but, in the past, there were no legal teeth associated with an EICR - if one didn't like, or didn't agree with, C2s (or even C1s) on an EICR once could just ignore them, and/or have a second EICR undertaken by someone one thought (or hoped) might be more sensible.

However, neither of those options are now available to private landlords. The law now requires that an C2s (or C1s) on the first EICR must be remedied within 28 days of that EICR.

It seems on this thread though that, while you aren't necessary defending things, you are happy to accept "that is just the way it is and it is necessarily subjective".

Not at all. I regard it as totally unsatisfactory (realkly, 'unacceptable') Aside from the questioned raised by EFLI as to whether the introduction of this legislation was really 'necxessary' (I'm inclkined to agree with him that it probably wasn't), since I believe that there are always going to be many things which require subjective judgement, all that could be done would be to 'weed out' those whose subjective judgement was 'questionable'.

That's why I have said, more than once, that if this situation is to persist, what I believe really ought to happen is that those undertaking these 'landlord EICRs' should required to be 'licensed' so to do, that there should be demanding requirements in terms of the qualifications and experience of those being licensed and, most important of all, that the licenses should be 'revoked for life' from any who had showed a pattern of coding things on EICRs 'unsatisfactorily'.

Do you not think it could be better.

See above

The next time someone asks about coding on an EICR will you say "that's just the way it is"?

Again, see above.

You haven't done much criticising on this thread.

I'm not sure where that comes from. I was one of the people who, back on page 1, said that I believed that at least two of the C2s mentioned by the OP should have been C3s (or nothing), and then went on to discuss the serious problem that these C2s would pose if it were "a landlord EICR" we were talking about (which it may have been).

Kind Regards, John

 

[JohnW2]

Surely they are not covered by the EICR and therefore no codes should be applied to those situations. Therefore the 28 day limit does not apply.

That's what I said back on page 1. However ..

What I have done, and what I believe every spark should do, is to fill out the EICR with only codeable faults covered by the report. ... Any other dangerous situations, eg a cast cut-out or a damaged meter or a faulty extension lead etc..... ought to be mentioned in a letter or note which you present to the customer and if possible, get them to sign it to say they understand there is a dangerous situation present. If there is a fault associated with DNO or meter company equipment, I would ring the company to report the situation.

Yes, but we have to remember that the legislation says nothing about an EICR. Rather it requires that a competent electrician undertakes an inspection and produces 'a report' which confirms that the installation complies with 'electrical safety standards' - and anything in that 'report' which says that remedial action is required then has to be remedied within 28 days.

Hence, it could be said that if the inspector found anything unsafe within the premises (even if in DNO equipment), he/she should mention that in the 'report' and that if the report said that remedial action was required, that had to be done within 28d, again even if it related to DNO equipment.

As I discussed with EFLI above, what would happen if the DNO then 'decided not to do anything' about some aspect of their equipment that had been described as 'unsafe' in 'the report' is anyone's guess!

Kind Regards, John

 

[securespark]

Another guidance says it should be C2 (potentially dangerous and to be rectified) if in understairs cupboards. Someone has just made up that totally out of the blue.

The people writing this drivel need to bang their heads together to knock the rubbish out of them and then put them together again to actually produce a coherent document that can be used by electricians to code electrical installations nationally.

And electricians need proper training to know how to complete an EICR.

 

[SimonH2]

In the example I just posted, what objective criteria would you specify for differentiating between 'corroded brake pipe' (=fail) and 'superficial corrosion of brake pipe' (=pass, with advisory)?

As you've pointed out, it's not possible - at least, not without going into a great level of detail and requiring measuring equipment (if the pipe is size X of material Y, then a corrosion site may not be more than Z deep kind of stuff). But rather bizarrely, I got my car back from it's MoT yesterday and found an advisory "brake pipe corroded, covered in grease or other material Offside Front and all rear pipes". I suspect you've already spotted an issue here - a brake pipe covered in grease and protected against corrosion gets the same advisory as a brake pipe that is clean and shiny and showing plenty of corrosion (just not enough to get a fail). I did check with the tester - it's grease, not corrosion, that's the problem in my case.
I can sort-of see the logic - if the pipe is covered in grease, the inspector can't see if it's corroded or not. But it's really daft not having a different code/description for that.

 

[SimonH2]

It should be either acceptable or not and existing plastic consumer units should either be acceptable or not. I'm obviously missing something.

I think we all agree on that.
The problem is that "there was a problem, something needed to be done, this was something, so it was done". The root cause is, some of us suspect, poor workmanship during the mass meter change program that's being foisted on people. Meter fitters moving cables, and not checking connections afterwards, can leave bad connections where the meter tails enter the terminals of the main switch - causing heating and in many cases, a fire. Thus we believe the LFB (London Fire Brigade) called for CUs to be "non combustible". Constrary to popular belief, that does not mean they have to be steel cased - but the reg was so badly crafted as to not define what they mean by non-combustible, and stated that ferrous metal is an example of non-combustible material. So in the absence of any definition to work to, the only material you can be sure of compliance with the reg is steel.

But there's a bigger problem in that the reg just says that CUs must be made of non-combustible material - but it doesn't say that they actually have to be able to "contain" a fire that starts within as there's no requirement for lids to self close etc. And as stated, nothing is said about existing CUs.
What is stated is that when inspecting/testing an installation, it should always be to the current standards - no-one is expected to know all the previous versions of standards the installation may have been designed/installed to. So a plastic cased CU is non-compliant with the current standard - there isn't any argument about that.

Where all the "discussion" comes from is what to do when EICRing such an installation. It's non-compliant, but BS7671 explicitly says that non-compliant does not automatically mean not safe. And different organisations have issued their ideas of what the implications of non-complaince are - some have recommended coding C2, some have recommended coding C3, some have recommended that the coding depends on the situation, ...
I've had email correspondence with someone connected with producing BS7671. The guidance I had was that if it's combustible and in an escape route then code it C2, otherwise either code it C3 or don't even mention it. But that is "personal opinion" and not official guidance. In part, I think it's driven by a realisation that telling potentially millions of owners that the new CU has to be replaced again would be "unpopular"
The bodies who's names appears on the front of the book have declined to come out with definitive official guidance. IMO that's inexcusable as it leaves the whole industry in this big swamp of uncertainty - as you've witnessed in this thread. I've noted that the draft of the next version of BS7671 does not change the wording at all for this reg - and I've posted a comment to the effect that they really need to, at the very least, define what non-combustible means (preferably by referencing an existing standard - it exists). If they referenced a standard for combustibility then manufacturers could potentially declare existing products as compliant (if they are).

And for good measure, there are arguments for non-conductive enclosures being electrically safer WRT certain risks.

 

[securespark]

Like on a TT supply.