Advice on EICR failure C2

[TonyWarrington]

Some years ago (about 15) I was left my uncles old home a terraced property built 1901. Which we have rented out after undertaking extensive refurbishment. At that time I employed a professional electrician whose work to me was known from prior jobs and in whom I had the utmost confidence. As he is now enjoying a well earned retirement I am not bothering him with this

I have had notification from the letting agents that a recent EICR instigated by them revealed some C2 issues that need to be rectified. If I understand correctly C2 is "potentially dangerous". An EICR could only be issued once the recommended work completed.

I do appreciate that safety is vitally important and recognise my legal responsibility as well as my moral responsibility to ensure the safety of any occupiers of the property. However I am surprised that as these reports are done every five years and this must be the third one that what was mentioned has not been picked up before. So I would appreciate comments suggestions prior to me giving an OK for the work.

Briefly this is what was stated (italics):

The installation has been assessed as Unsatisfactory, as Code C2 observations were identified. The issues noted were:

1. Unsealed opening to the consumer unit affecting its fire integrity. Suggested action Fire seal unit

The consumer unit is in a small vestibule by the front entry mounted high and has been there as long as the house has stood. The consumer unit would have been new 15 years ago. So why is it now unsatisfactory? Have rules changed?

2. Absence of a protective conductor (earth) on the upstairs lighting circuit, and a bedroom light switch that is insecure due to being fixed on a single lug.

No idea what to make of this lack of earth, I cannot believe that this would have been omitted at the time of the complete rewire? Light switch OK


3. Bathroom light fitting is not suitably IP-rated for its location.

Well no it is not an IP rated light fitting it is a globe light set at about 8 foot above the toilet bath area and switched by wall light. Again been the same type for 15 years

The estimated cost to rectify is about £500 +VAT.

I have no idea or contact with the electrical contractor that was employed but just question the conclusions reached and would appreciate opinion/advice.

Asking due to having been once bitten twice shy by a different company carried out and EPC rating the property lower than it should be based on inaccurate assessment of the property making me question if a visit made!

 

[Murdochcat]

A photograph of the consumer unit would be helpful

Lack of CPC on the lighting circuit points to an installation pre 1966 - so really needs sorting out which means a partial or full rewire

Photo of the bathroom light?

Replacement switch back box required

£500 is an odd price given what has been identified

Your agent needs to provide you with the unsatisfactory EICR

 

[plugwash]

I have had notification from the letting agents that a recent EICR instigated by them revealed some C2 issues that need to be rectified. If I understand correctly C2 is "potentially dangerous". An EICR could only be issued once the recommended work completed.

This is not true, an "unsatisfactory" EICR can absoloutely be issued.

On the other hand, this guy may have done you a favour by not issuing an EICR, because once an unsatisfactory report is issued then it starts a clock under the law.

Unsealed opening to the consumer unit affecting its fire integrity. Suggested action Fire seal unit

Sounds like BS to me. BS7671 requires consumer units to be made of "non-combustible material" but afaik there is no requirement for "fire integrity" beyond that.

No idea what to make of this lack of earth, I cannot believe that this would have been omitted at the time of the complete rewire? Light switch OK

If a complete rewire was done in the past few decades there should bloody well be an earth. This leaves several possibilites.

1. The electrician the estate agent hired is lying.
2. The electrician the estate agent hired has mixed up results for different properties.
3. The electrician who "rewired" the house was a cowboy and did not actually rewire it. I've certainly had a friend who was told their house was rewired, but later came across 1960s cabling still in use.
4. Earth wiring is present but it somehow faulty and this has been reported as "no earth".

3. Bathroom light fitting is not suitably IP-rated for its location.

Well no it is not an IP rated light fitting it is a globe light set at about 8 foot above the toilet bath area and switched by wall light. Again been the same type for 15 years

The height is critical here. Equipment in the bathroom zones is required to be IP rated, but the bathroom zones usually end 2.25m off the floor, this puts most ceilings outside the zones but a room with low ceilings could be an exception.

There is also a general requirement that "equipment should be suitable for it's environment", some electricians seem to interpret this as all equipment should be IP rated.

Asking due to having been once bitten twice shy by a different company carried out and EPC rating the property lower than it should be based on inaccurate assessment of the property making me question if a visit made!

You are right to be skeptical.

It's really hard to make money doing honest EICRs. Doing a proper EICR takes a bunch of work and domestic EICRs often go to the lowest bidder. Scumbags can make money either by exaggerating real faults, outright inventing faults, or even doing a "drive by" EICR where the whole report is a work of fiction.

 

[endecotp]

Unsealed opening to the consumer unit affecting its fire integrity.

Could it be a missing blanking cover over an unused MCB slot?

I agree with the other replies. Are you able to visit the property yourself, and get some photos?

 

[ericmark]

An EICR could only be issued once the recommended work completed.

Incorrect, an EICR is issued showing the faults, and once you have some paperwork to show corrected it is simply added to the EICR.

So I would appreciate comments suggestions prior to me giving an OK for the work.

Something has to have changed, this may not be the installation, it could be the equipment being used in the installation.

Unsealed opening to the consumer unit affecting its fire integrity. Suggested action Fire seal unit

Seems an odd fault, the question is if this is an electrical problem, or a fire department problem? The EICR is looking for electrical danger, not fire danger, but these are related. If there is a potentially dangerous fault be it in the fire departments report or electricians report it needs fixing, the debate as to who should have reported it, really does not matter.

Bathroom light fitting is not suitably IP-rated for its location.

IP rating is not something which needs to be written on an item, it is simply a way of saying how resistance the item is to three items, and the regulations are not interested is all 3 so they use X for the bits they and not interested with so "affording a degree of protection of at least IPXXB or IP2X" for example. It depends on where fitted and what voltage, but IPX4 = devices are protected from splashing water that hits at any direction or angle.
It is up to the inspector to decide will the fitting resist water splashes. Not all inspectors will judge the same.

Absence of a protective conductor (earth) on the upstairs lighting circuit, and a bedroom light switch that is insecure due to being fixed on a single lug.

This has been something I have questioned before, if a previous inspector has missed something, have you any redress? The regulations say

BS 7671:XXXX Requirements for Electrical Installations was issued on Date and is intended to come into effect on Date. Installations designed after Date are to comply with BS 7671:XXXX.
The Regulations apply to the design. erection and verification of electrical installations, also additions and alterations to existing installations. Existing installations that have been installed in accordance with earlier editions of the Regulations may not comply with this edition in every respect. This does not necessarily mean that they are unsafe for continued use or require upgrading.

The word "necessarily" allows for some lea way. The code 4 was removed from the EICR this was does not comply with current edition. It was felt it was misleading.

In the main, if it passes when BS7671 came out (1992) then it will still be OK. But there are exceptions, in the last year it was realised for example that some protective devices will be damaged with current passed in the reverse to normal direction, in 1992 we did not have anything which would either cause current to flow in both directions, or devices that could be damaged when this happens, so in this case the regulations are retrospective. A lot earlier in history we had the ELCB-v which was found not to protect as first thought, so these needed changing, and we also have rules which allow things only if something else is done, like earth bonding requirements for a bathroom.

An EICR was designed to tell the owner what state the premesis are in, it was never designed to be included into a UK law, and for that job it is not fit for purpose. The landlord law does not refer to an EICR. The guide to the law talks about EICR, but not the law. “safe for continued use” comes up, and ISIT which refers to:-

Since it does not refer to EICR it also does not refer to codes C1, C2, C3, LIM, FI etc, that is only in the guide, not the law.
Also, it refers to equipment not installation, we split equipment into installation and current using equipment, but the law splits into portable and non-portable, so over 18 kg, and not on wheels is included in the inspection.

This has raised a problem, where items of current using equipment requires some special training before we can remove covers, for example central heating boilers, so the EICR has to have either LIM or FI, that's limitation or further inspection required. Since neither is referred to in the law, only in the guidance, and the same applies to C2 and C3, the inspector can report omissions or defects as either, as long as reported, he has done his job.

The “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; this is rather open, there is a qualification C&G 2391, but the law does not refer to this. And the scheme operators often do not authorise EICR under their control, so even when done by a scheme member, it often has nothing to do with the scheme.

So even though I retired some 20 years ago, there is as it stands nothing to stop me doing an EICR, the letters behind my name do not tell anyone if I passed the C&G 2391 (I did) but it does at least show I have had some training. The letters behind the name come with level 5 and above, most electricians train to level 3, which is enough, but it means you have no idea if they at a 1st year apprentice, or have 50 years experance.

So if you looked around the home, and used the IET forms, what would the courts do? If I was to say, I was trained by NACAP BV in algeria, in 1980, it would be hard to prove otherwise, specially since I was, but finding records to show I was would be hard. We have seen a court case where an electrician did not do his job, but he pleaded guilty, and he was done under the trades discription act, not Part P or The Electrical Safety Standards in the Private Rented Sector and Social Rented Sector (England) Regulations 2020, which did not apply anyway as he was in Wales.

 

[TonyWarrington]

Wow, gentlemen, Murdochat, plugwash, endecotp, ericmark thank you so much for your considered, thoughtful and expert responses.

Based on this and my own knowledge (admittedly limited) I have passed on to the agents my concerns relating to the "accuracy" of the report and asked for "clarification" quoting any rules and regulations the contractor sees as fitting the remedial work. We shall see what response in due course!

 

[Murdochcat]

Just remember you are under absolutely no obligation to use the spark to do the remedial work

 

[ericmark]

Just remember you are under absolutely no obligation to use the spark to do the remedial work

It states qualified person.

“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;

it does not say must have City & Guilds 2391, but it does imply that.

 

[securespark]

Late to the party as ever...

Not fire integrity, but gaps in enclosures should be sealed or closed up. IP4X on horizontal surfaces and IP2X on vertical ones.

1. Where I think the guy might have got confused with fire integrity is that the IP4X rating is considered difficult for dust and fluff to enter enclosures and become a fire risk.
At least, that was my training.

2. I suspect the guy might have done a flying lead test to one point, probably an easily accessible switch, rather than getting the steps out and getting up to a rose. I've seen earth's not quite terminated properly or the sleeving caught by the screw. I've even seen reused metal boxes with plastic lugs where the new cable is connected to the switch, but the CPC is just in sleeving and not attached.

In any case, a lighting circuit without CPC is no biggie, providing there are only Class II fittings, so if this were the case, it would be a C3. If there is no CPC, and there are Class I fittings on that circuit, then replace them with Class II and you're done.

3. If it's above 2.25m, it shouldn't need a bathroom-specific IP rating. Suspect the spark is a young kid who also thinks you need fire-rated down lighters everywhere.

The original rule was if it was within arm's reach of someone in the bath or shower, it had to have a Home Office skirt on the lamp holder (flared) or, preferably, an enclosed fitting.

 

[JohnW2]

Not fire integrity, but gaps in enclosures should be sealed or closed up. IP4X on horizontal surfaces and IP2X on vertical ones.

Strictly speaking, IP4X only on 'top' horizontal surfaces.

However, the fact that IP2X is acceptable on most surfaces illustrates how totally daft this 'non-combustible' regulation is, since it involves absolutely no requirement for 'fire containment'. Provided only that what little material is left is deemed to be 'non-combustible', a CU could be totally covered in 12mm diameter holes (on front, back, sides and bottom) and yet be 'compliant'!!

... and, as I always ask, I wonder if anyone has yet died, or been seriously injured, as a result of a domestic CU being metal?

 

[securespark]

Do you mean "not being metal?"

 

[JohnW2]

Do you mean "not being metal?"

No. Why should a plastic CU be a 'threat to life' (other than as a result of alleged CU-originated fires) ?

 

[pete01]

... and, as I always ask, I wonder if anyone has yet died, or been seriously injured, as a result of a domestic CU being metal?

I think one fell off the shelf at my wholesalers and knocked the young lad out....is that the kind of thing you mean?

 

[JohnW2]

I think one fell off the shelf at my wholesalers and knocked the young lad out....is that the kind of thing you mean?

Not really

My point is a serious one. If everyone were as competent and careful as they should be, then metal CUs ought not to present any risk. However, given that 'injudicious fiddling around' in a CU is far from unknown, I would suggest that it is safer for one's 'fiddling' hands/fingers not to be surrounded by lots of touchable earthed metal, from which one is 'protected' by nothing more than paint (and even that probably not everywhere)!

 

[trojanhawrs]

I like the change to metal CU's, just feels more robust and better quality. Don't necessarily think plastic ones were much of a fire hazard though.

If your existing CU is on a brick wall fire sealing is almost certainly not required.