I called South Gloucestershire Building Control and they were very helpful. They are going to get the surveyor to get in touch and also forward the EICR from 5 years ago which they should have on file.
Is downlight replacement notifiable work?
- Thread starter hillsrob
- Start date
I called South Gloucestershire Building Control and they were very helpful. They are going to get the surveyor to get in touch and also forward the EICR from 5 years ago which they should have on file.
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Reply back from contractor. As you anticipated no specific paragraphs cited:
The fire rated downlights that we would order will fit as required.
I’m afraid I don’t have the exact exert from the regs that you are asking for to hand but if you wish to look into this further please do so and let me know if you wish to continue with the works. As I am sure you are aware, the engineer testing the system needs to make the decision based on what they believe is safest and as per previous email discussions with yourself, we have stated that we will always go with the safest option.
I won’t place any order for materials until you have confirmed back that you are happy to proceed with the works as quoted.
I think this is the problem. The 'decision' is being made on the basis of "what the engineer ... believes to be safest", despite the fact that no regulations require such a 'decision' - and a personal opinion/belief which goes beyond what regulations require really should not be coded on an EICR (even if it were something relevant to an EICR - which it isn't).
My opinion remains the same, and the same as that of everyone else who has commented - i.e. that fire-rated downlights are not required in the situation. Only you can decide how you want to handle the situation.
If BC confirm, as I hope they will, that fire-rated downlights are not required, I would personally just wave that confirmation at the buyer as an explanation as to why you are not going to act on the basis of the (incorrect) EICR - but, as above, it's obviously up to you.
Kind Regards, John
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When I watch some of these YouTube videos with panels of electricians discussing photos of various horrors (2 half penny pieces, screws and 2 chunky cables feeding a car charging point for example) I have to laugh at the farcical situation that self regulation has come to this. The law aims to be well thought out but always needs expert interpretation and training to understand it.
I was an Electronics Engineer all my working life and a Fellow of the IET but I'm dumbfounded that no-one knows for sure and there is a wide spread of codings for this particular situation. I'm unlucky to have got a strict decision albeit with no reference to the regs. Just a gut feeling that it doesn't seem right.
Because I did my own rewire under building control I went to extreme lengths to get it right. I'm secretly quite smug that I only got 4 C3s. These were the plastic fronted steel CU, a component (neon) failure, a toss of a coin decision between an MCB and an RCBO for the fire alarm circuit and the remaining downlights. The only C2 was the Part B issue.
So I'm going to put it behind me and hopefully move house to get on with my next project. Older and a little wiser I hope.
Thanks again John for an interesting discussion and for giving this problem so much care and attention to detail.
I think one of the things that gets overlooked is that, although the concept of EICRs is introduced, but with no detailed 'instructions', in BS7671, the authors (IET + BSI) probably never intended such inspections and reports to be anything more than a means of advising owners of electrical installations as to what improvement or remedial work was recommended/required. In that context, the fact that it involved a fair degree of judgment and discretion on the part of the particular inspector is not too much of a problem - probably comparable with what happens with, say, a structural survey.
That changes appreciably when third parties (such as your buyers) take an interest in the report, and even more so when it acquires legal 'teeth' (as has recently happened in relation to renal properties) - in which case far more strictly defined 'rules' (and, hopefully, strict regulation of 'the inspectors') are really required.
Kind Regards, John
If they intended that then they had their heads in the clouds.
Almost noone is going to get their electrics inspected just for their own info, they are going to do it to satisfy a perceived need either to immediately convince someone that the installation is safe, or (mostly in the case of commercial installations) to show that they did their due diligence when the **** hits the fine.
Almost noone is going to get their electrics inspected just for their own info, they are going to do it to satisfy a perceived need either to immediately convince someone that the installation is safe, or (mostly in the case of commercial installations) to show that they did their due diligence when the **** hits the fine.
I was thinking and talking specifically about domestic installations but some of what I said probably also applies to commercial/industrial.
In terms of domestic, I'm not sure that you are right. I may be wrong but (prior to recent PRS legislation), I would have thought that only a minority of domestic EICRs will have been done because of the interest of a 'third party'.
However, that was not really the important part of my point. The IET and BSI are not, in legal terms, 'rule makers' or regulators. BS7671 is simply a Standard, the primary purpose of which is for the authors to define what they regard as the 'minimum safety standards' for electrical installations.
The attitude/approach of IET/BSI seems to be apparent from what they have (and have not) written. BS7671 itself says virtually nothing about EICRs (which it calls "Periodic Inspection and Testing"), there being only just over one page about it. Even the guidance in ('informative') Appendix 6 merely gives a ("not exhaustive") list of things that should be inspected and tested, and provides specimens of one type of report form that can be used. With just one small specific exception (which has been discussed) it does not attempt to give even explicit 'guidance', let alone rules, about how specific non-compliances/ conformities should be coded. This is surely an indication that they have made no attempt to produce 'a set of rules' relating to EICRs.
If the government wishes there to be a set of strict and explicit rules about the inspection and testing (and reporting thereof) required to satisfy their recent 'PRS' legislation, then I would think that it is down to them to produce such rules - since, as above, there currently are no explicit 'rules'.
Kind Regards, John
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