Old 'KMF' on EICR

JohnW2 · 13 Mar 2021

333rocky333 said:
I take it its "K Main Fuse", but whats the K stand for, first time i have ever heard of it, does not look big enough to have a fuse in, was it rewirable

Ah. The OP seems to have now indicated that the fuse holder below it (which I thought was a DNO one) is actually part of the installation, so that (if I'm now understanding correctly) the switch/isolator above is 'just a switch/isolator' (not a switch-fuse).

Kind Regards, John

seasickstevie · 13 Mar 2021

ericmark said:
I was looking at the DNO equipment bit, on the IET form is does say the DNO equipment should be inspected, but on the new law it says it should not.

This is after the meter (and service head) so obviously was not installed by the DNO. This would have been installed by the spark when the property was wired in the early 70s.

Interesting that you say 'In the new law' the DNO equipment 'should not' (need not?) be inspected. Again, this isn't DNO property/switchgear, but nevertheless I'm intrigued as I've not heard that comment made before.

JohnW2 · 13 Mar 2021

seasickstevie said:
Interesting that you say 'In the new law' the DNO equipment 'should not' (need not?) be inspected. Again, this isn't DNO property/switchgear, but nevertheless I'm intrigued as I've not heard that comment made before.

The "new law" to which eric referred is, I presume, the ('PRS') legislation related to electrical inspections of private rental property which appeared in mid-2010.

I think his point was that whilst BS7671 says that (for an EICR) the DNO equipment 'should be inspected' (even though it is actually outside of the scope of BS7671), the new PRS legislation requires an 'inspection' (which it does not call and EICR) 'of the installation', and includes a definition of 'the installation' which appears to exclude DNO equipment.

However, as you've said (and I now realise!), we are not talking about DNO equipment.

Kind Regards, John

seasickstevie · 13 Mar 2021

Thanks for that explanation John.

SUNRAY · 13 Mar 2021

Personally I'd have always expected any PIR/EICR to include the DNO kit. I see no point in having a 'faultless' EICR in which the DNO equipment is damaged and possibly lethal.

JohnW2 · 13 Mar 2021

SUNRAY said:
Personally I'd have always expected any PIR/EICR to include the DNO kit. I see no point in having a 'faultless' EICR in which the DNO equipment is damaged and possibly lethal.

Agreed. As I said, per BS7671, an EICR does include an 'inspection' of the DNO equipment (even though, strictly it is outside of the scope of BS7671), but that can only really be a 'visual inspection'.

However, as I also wrote, the PRS legislation appears to have been written in a way that means that the required inspection (which the legislation does not call an EICR, although associated non-mandatory 'guidance documents do!) excludes DNO equipment.

Kind Regards.

ericmark · 14 Mar 2021

JohnW2 said:
Agreed. As I said, per BS7671, an EICR does include an 'inspection' of the DNO equipment (even though, strictly it is outside of the scope of BS7671), but that can only really be a 'visual inspection'.

However, as I also wrote, the PRS legislation appears to have been written in a way that means that the required inspection (which the legislation does not call an EICR, although associated non-mandatory 'guidance documents do!) excludes DNO equipment.

Kind Regards.

Yes the EICR has always included distribution equipment, ceiling roses, and lamp holders, consumer units etc. But it did not include in-service equipment which came under the inspection and testing of in-service electrical equipment i.e. current using. However the new PRS legislation includes anything which is not intended to be moved, so includes washing machine, etc. So I can see why not called an EICR, however I had missed that it was not called an EICR.

So

The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 said:
every electrical installation in the residential premises is inspected and tested at regular intervals by a qualified person;

where

The Electricity Safety Quality and Continuity Regulations 2002 said:
“consumer’s installation” means the electric lines situated upon the consumer’s side of the supply terminals together with any equipment permanently connected or intended to be permanently connected thereto on that side;

and

The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 said:
“qualified person” means a person competent to undertake the inspection and testing required under regulation 3(1) and any further investigative or remedial work in accordance with the electrical safety standards;

seasickstevie · 14 Mar 2021

flameport said:
C2 - basic insulation outside an enclosure
C3 - no RCD for cables concealed in walls

Thanks for the reply flameport. I was wondering about the basic insulation. As it's in the 'electric cupboard' , and only likely to be accessed by a 'competent person'(?) I was thinking maybe it could be a C3.

I'm prepared to call it a C2, but want to be prepared for a landlord who thinks that because it's been fine for 40+years, how can it now be 'dangerous'?

flameport · 14 Mar 2021

Cupboards are not enclosures, and all unsheathed cables have been required to be enclosed since the 1960s at least.
It was permitted in the 1955 13th edition to have short lengths of single insulated conductor exposed at switchgear as in the photo.

The installation has either never been inspected, or those inspecting it previously didn't do it properly.

ericmark · 14 Mar 2021

I got in hot water with HSE because the boards had plastic knobs in the catches so could be opened without a key or tool, and had to remove them all and carry a key

which seemed pointless as so many people had the key, but it satisfied HSE. So it depends if the electrical cupboard needs a tool or key or simply just a door anyone can open. Personally I would say code 3 if in a cupboard, but not sure if HSE would agree.

JohnW2 · 14 Mar 2021

ericmark said:
However the new PRS legislation includes anything which is not intended to be moved, so includes washing machine, etc.

That's not quite what the PRS legislation says. As you have quoted, it says;

...any equipment permanently connected or intended to be permanently connected thereto on that side

... and I think that can probably be interpreted as only applying to equipment which is 'hard wired' (hence excluding any 'plugged in' equipment/appliances), can't it?

ericmark said:
So I can see why not called an EICR, however I had missed that it was not called an EICR.

As I said, although the legislation, per se, does not call the inspection an 'EICR', the associated guidance document is all about EICRs (called such) and, indeed, indicates that it's only C2 and C1 items that require any action per the PRS legislation.

Kind Regards, John

JohnW2 · 14 Mar 2021

flameport said:
Cupboards are not enclosures, and all unsheathed cables have been required to be enclosed since the 1960s at least.

Whilst that's true, and makes sense, I wonder where the dividing line is between a 'cupboard' and an 'enclosure'? The BS7671 definition of 'enclosure' is really too vague to be of much help ...

BS7671:2018 said:
Enclosure. A part providing protection of equipment against certain external influences and in any direction providing basic protection.

Eric seems to think that the need for a 'key or tool' to open it makes the difference?

Kind Regards, John

ericmark · 14 Mar 2021

JohnW2 said:
... and I think that can probably be interpreted as only applying to equipment which is 'hard wired' (hence excluding any 'plugged in' equipment/appliances), can't it?

I would say where the socket is dedicated then it is only to assist maintenance, so a built in oven plugged into a 13 amp socket is intended to be permanently connected, so comes under the PRS legislation, now a twin tub washing machine I would say does not come under the PRS legislation, as it is only connected to mains when in use, but with a front loading washing machine with an isolator for easy assess and a dedicated socket that likely does come under the PRS legislation.

Since the early days of PIR and inspection and testing of in-service electrical equipment there has be arguments as to what falls under each test, and in the main we do consider if fitted with plug then PAT test, and if not part of the PIR, but this was an arrangement made because of the problems of using semi-skilled people to do PAT testing, so the fully trained electrician tested the more involved equipment.

However anything on the equipment register would have a PAT test paper trail, there is nothing in the PIR/EICR paperwork to record most the functions done in PAT testing.

But you have hit the nail on the head, law does not say EICR or PAT testing, all it basic says is all should be tested at least every 5 years, and it is down to the building manager to tell electricians what to include.

JohnW2 · 14 Mar 2021

ericmark said:
I would say where the socket is dedicated then it is only to assist maintenance, so a built in oven plugged into a 13 amp socket is intended to be permanently connected, so comes under the PRS legislation, now a twin tub washing machine I would say does not come under the PRS legislation, as it is only connected to mains when in use, but with a front loading washing machine with an isolator for easy assess and a dedicated socket that likely does come under the PRS legislation.

I think that a lot of that is open to debate, and that some would say that connection via a plug/suggest did not represent a 'permanent connection' (or even an 'intended permanent connection').

I've certainly known some ultra-cautious people who 'unplug' anything they can after use, so I wouldn't say that such things were 'permanently connected' (or 'intended to be').

ericmark said:
But you have hit the nail on the head, law does not say EICR or PAT testing, all it basic says is all should be tested at least every 5 years, and it is down to the building manager to tell electricians what to include.

As I've said, although 'the law' does not mention EICRs (or PATesting), the associated guidance document makes it pretty clear that what is required is an EICR, and that any C2s or C1s on that EICR (and only that) have to be remedied in order to satisfy the legislation. As you've said, the EICR will not include any information on 'connected equipment' - so, despite the bits of the legislation you've been quoting, there does not seem to be any expectation of testing of 'connected equipment'.

Kind Regards, John

SimonH2 · 14 Mar 2021

JohnW2 said:
Eric seems to think that the need for a 'key or tool' to open it makes the difference?

And I'd agree with him.
Consider this, a typical CU only needs a common pattern screwdriver to open it - few people don't have access to a screwdriver that will fit well enough to open it, yet we don't consider that a problem. IMO it comes down to :

If it needs a tool, even if it's a commonly available tool, then there is a deliberate act to open the enclosure, i.e. there's a conscious decision to obtain a tool and use it. Once someone has decided to obtain and use a tool - that's a deliberate positive act.
If it doesn't need a tool, then the enclosure can be opened without a conscious decision to get hold of a tool. So potentially access to live (or only single insulated) parts without that deliberate positive act.

If we don't consider "needs the use of a tool" as adequate - then what do we do about all the accessories (switches, sockets, etc) in a typical house where only the use of a small screwdriver is needed for access to live parts ?

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Old 'KMF' on EICR

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