EICR Coding Opinions

[Starspark1]

Good responses guys.

A bit of background to this... basically the company i work for own a lot of houses of various archetypes eg two story houses,bungalows, flats etc. Up until very recently our policy has been to change front end RCD boards for split load consumer units with half the circuits on the RCD side and the other half on seperate RCBO's. Obviously this was at great expense. In my opinion an unnecessary expense. There has been debate about this and we are now going to go the way of leaving these front end boards in situ which i believe to be perfectly acceptable. Now however the issue of coding of this has arose hence the post.

Whilst i tend to agree with RMS and ericmark this is certainly a debate which i can and have seen having many opinions!!

 

[EFLImpudence]

A C3 is an observation (that gives rise to danger) whereby improvement is recommended.

That is not the case. C3 implies no danger.


Not necessarily to RMS -

It is merely a recommendation that improvement is needed.
Would you prefer that another word were used instead of 'recommended'?

Is that what is causing this difference of opinion which, to be honest I do not really understand.

If we must 'note' all non-compliances with the latest regulations, as has been agreed, should this not be done with a C3? and an explanation rather than only a note.
What would be put in the outcome column?
It just seems odd to me to put a tick signifying it is acceptable and then explain it could do with improvement?

'Improvement recommended' implies no compulsion.


I suppose it boils down to whether it is thought that now-non-compliant-but-safe items warrant a tick or a C3.

 

[JohnW2]

That is not the case. C3 implies no danger. ... It is merely a recommendation that improvement is needed.

I think we're getting into an almost semantic discussion which exists because the safety/danger spectrun is not yes/no - but, rather, shades of grey which require some judgements. If the recommendation is that "improvement is needed", why is that (other than to achieve compliance with a set of regs)? Presumably to make the installation 'safer' - and 'safer' is really just another way of saying 'less dangerous', isn't it?

Would you prefer that another word were used instead of 'recommended'? Is that what is causing this difference of opinion which, to be honest I do not really understand.

You know that I would prefer some other word. I would prefer non-compliances identified and reported, and then 'expert recommendations' as to which of those represented situations in which 'improvment' would (in the opinion of the professional electrician) result in significant increases in safety (aka reduction in danger).

Kind Regards, John

 

[EFLImpudence]

That is not the case. C3 implies no danger. ... It is merely a recommendation that improvement is needed.

I think we're getting into an almost semantic discussion which exists because the safety/danger spectrun is not yes/no - but, rather, shades of grey which require some judgements. If the recommendation is that "improvement is needed", why is that (other than to achieve compliance with a set of regs)? Presumably to make the installation 'safer' - and 'safer' is really just another way of saying 'less dangerous', isn't it?

Well, yes but we are marking it against the latest regulations.

Would you prefer that another word were used instead of 'recommended'? Is that what is causing this difference of opinion which, to be honest I do not really understand.

You know that I would prefer some other word. I would prefer non-compliances identified and reported, and then 'expert recommendations' as to which of those represented situations in which 'improvement' would (in the opinion of the professional electrician) result in significant increases in safety (aka reduction in danger).

A C3 doesn't negate the rest of what you want.

Surely, a significant increase in safety would be as a result of any C2s.

We are only talking about the items which don't comply with the latest regulations and are not a danger.

 

[RMS]

A C3 is an observation (that gives rise to danger) whereby improvement is recommended.

That is not the case. C3 implies no danger.


Not necessarily to RMS -

It is merely a recommendation that improvement is needed.

Disagree.

Departures from the requirements of the current edition of BS 7671 that do not give rise to danger or need improvement
Amendment 1 to BS 7671: 2008 no longer requires departures from the requirements of the current edition of BS 7671 that do not give rise to danger or need improvement to be recorded in condition reports.

So the way I see it, departures do not warrant a C3 unless they give rise to danger.

 

[EFLImpudence]

'Departures' are alternative methods which DO comply to other recognised regulations.

For what is being discussed see page 9 of ESC BPG.

 

[JohnW2]

I would prefer non-compliances identified and reported, and then 'expert recommendations' as to which of those represented situations in which 'improvement' would (in the opinion of the professional electrician) result in significant increases in safety (aka reduction in danger).

A C3 doesn't negate the rest of what you want.

It might not 'negate it', but it would create somewhat of a nonsense. If, per the BS7671 definition, a C3 has told me that "improvement is recommended", it would be a bit daft/confusing if you then "recommended" that the potential increase in safety was not significant enough for it to really warrant any action, wouldn't it?

Surely, a significant increase in safety would be as a result of any C2s.

That bit's true - but the implication of your saying that is presumably that you think that remedying C3s would not result in a significant increase in safety (or would result in an insignificant increase in safety), isn't it? If so, why would you be 'recommending' improvement of a C3, if you didn't believe it would significanly improve safety?

We are only talking about the items which don't comply with the latest regulations and are not a danger.

As I said, you are using 'danger' as an absolute, whereas it comes in shades of grey which are part of a spectrum. If C3s were 'not any danger at all' (i.e. if remedying them would do nothing to reduce danger {aka 'increase safety'}), why on earth would you 'recommend improvement'? If the recommendation is not about 'increasing safety' (aka 'reducing danger'), what on earth is it about?

Kind Regards, John

 

[EFLImpudence]

It might not 'negate it', but it would create somewhat of a nonsense. If, per the BS7671 definition, a C3 has told me that "improvement is recommended", it would be a bit daft/confusing if you then "recommended" that the potential increase in safety was not significant enough for it to really warrant any action, wouldn't it?

I explain that that's what I have to do because it is relating to the latest regulations but is still as satisfactory as when it was installed.
Any 'improvement' is 'recommended'.
I 'recommend' you give up smoking - it would be better but it's not compulsory.

For example, no RCDs for (outside) socket circuits - it is 'recommended' that it the circuit is 'improved' by installing an RCD.
Don't forget that your recent thread questioned whether anyone had actually been 'saved' by an RCD.

We are only talking about the items which don't comply with the latest regulations and are not a danger.

As I said, you are using 'danger' as an absolute, whereas it comes in shades of grey which are part of a spectrum. If C3s were 'not any danger at all' (i.e. if remedying them would do nothing to reduce danger {aka 'increase safety'}), why on earth would you 'recommend improvement'? If the recommendation is not about 'increasing safety' (aka 'reducing danger'), what on earth is it about?

Because it is an EICR.

So, you are saying that if I were of the opinion that almost nothing WAS a danger - because so few people are killed by electricity, then unless anything is actually live I could just tick everything whether it complies or not and go away.

 

[JohnW2]

I explain that that's what I have to do because it is relating to the latest regulations but is still as satisfactory as when it was installed.

... so far, so good ...

Any 'improvement' is 'recommended'.

So what if you have a customer as awkward as me, who asks "Mr EFLI, why are you recommending this improvment? Is it your opinion that it will makes things significantly safer for me and my loved ones?" ??

I 'recommend' you give up smoking - it would be better but it's not compulsory.

I've never suggested that any recommendations are 'compulsory' ... and that's surely a dreadful analogy, because there is surely little doubt that smoking is 'a danger' and that giving up smoking would have beneficial (c.f. 'safety') effects?

For example, no RCDs for (outside) socket circuits - it is 'recommended' that it the circuit is 'improved' by installing an RCD. Don't forget that your recent thread questioned whether anyone had actually been 'saved' by an RCD.

That's an interesting one, since it illustrates that a professional's recommendation depends upon their own expert view of things (which may differ from that of colleagues). However, in this particular case, the 'official view' is undoubtedly that 'RCDs save lives', so you'd have to be pretty convinced (with evidence you could cite) about a personal view that this was not the case before you did other than 'recommend' the installation of an RCD.

If the recommendation is not about 'increasing safety' (aka 'reducing danger'), what on earth is it about?

Because it is an EICR.

Ah! - now maybe that is actually what it's all about. Improvement is not being recomemnded because it would improve safety but, rather, 'because it is an EICR'.

So, you are saying that if I were of the opinion that almost nothing WAS a danger - because so few people are killed by electricity, then unless anything is actually live I could just tick everything whether it complies or not and go away.

This is surely where your personal professional judgement has to come into play - but if a electrician's views were as extreme as that, I think it would only be reasonable (and sensible/responsible) to bring to the attention of the customer the fact that most other electricians would take a very different view. As I keep saying, there is an awful lot between 'obviously immediately dangerous' and 'totally safe' (if anything is ever 'totally safe'). However, at the other extreme, we could all produce lists of very trivial non-compliances which, if we were honest, I think we would find hard to say really required 'a recommendation of improvement'.

Kind Regards, John

 

[ban-all-sheds]

I would prefer non-compliances identified and reported, and then 'expert recommendations' as to which of those represented situations in which 'improvment' would (in the opinion of the professional electrician) result in significant increases in safety (aka reduction in danger).

Such expert opinion needs to be informed, and there is no data available for anybody to form an opinion on what is significantly dangerous and what is not.

 

[ericmark]

Some points seem clear if your not recommending an improvement then what ever the regulations say you can't code it as C3. So the question has to be in the inspectors option does it require improvement?

As to the old code 4 there was many arguments over that as well. What was the previous edition. Was it any other edition of IEE wiring regulations or any other edition of BS7671 or just the edition preceding the current one and if the one preceding current one was that by IEE/IET number or BS7671 number.

BS7671 only came out in 1992 so nothing in the wiring regulations before 1992 would be a previous edition of BS7671. This means lack of earths to lighting was not allowed in any previous edition of BS7671.

The ESC Best Practice Guide 1 on fitting a new consumer unit when there is no earth to lights is interesting reading. 1966 was cut off date from the 14th Edition onwards we needed to earth lights. We are looking back nearly 50 years. There has to be a point where we say that's enough time to have got it corrected times up. However the rules also mean we can't make a house uninhabitable and although in industry we in theory can lock them off until corrected that is not an option in a home.

We have been forced to stick on labels warning of danger rather than isolate the problem is of course florescent kitchen lights and metal faced switches were not common in 1966. My parents had a wooden light fitting with three arms with bulb holder on each arm never seen one of those in years. Also ceilings were often much higher.

But returning to the RCD question the big thing is the danger from using a single RCD is not an electrical danger. It is all connected with lighting and we have lived in houses without electric lights for 1000's of years and it is not part of an electricians training to assess the dangers from failing electric lights. In larger buildings there are rules as to emergency lighting but this does not apply to the home.

Heating methods must also of course be considered. I have one gas fire rarely used installed just to ensure with an electrical power cut I still have heating. As an emergency I can use either all electric or all gas heating cooking would be the BBQ.

So as well as the immediate problem of being plunged into darkness if there was a earth fault stopping the power being restored would the house still be inhabitable for the time it took to get professional assistance to restore the power?

Which again returns me to training. As electricians are we trained to make these judgements and if we are not then does the question of being habitable really come into our remit when doing a EICR?

Personally I think not. So although we clearly should make a note of only one RCD it is really not a fault which can be coded as a C3. There will be exceptions I am sure but in the main we can't code a singe RCD with any code currently offered.

 

[JohnW2]

I would prefer non-compliances identified and reported, and then 'expert recommendations' as to which of those represented situations in which 'improvment' would (in the opinion of the professional electrician) result in significant increases in safety (aka reduction in danger).

Such expert opinion needs to be informed, and there is no data available for anybody to form an opinion on what is significantly dangerous and what is not.

That's obviously true, but that leads to the sort of approach being promoted by EFLI (although I don't think he accepts that this is what it boils down to) that one has to take the conserative ('safe') approach of assuming that any non-compliance is potentially 'significantly dangerous' and therefore that 'improvement should be recommended".

As I've said, if one's recommendation of 'improvement' is not based on the fact that the improvement would increase safety (aka reduce danger), then what on earth would be the reason for the recommendation (other than to achieve compliance with a 'book of words')?

Kind Regards, John

 

[JohnW2]

As to the old code 4 there was many arguments over that as well. What was the previous edition. Was it any other edition of IEE wiring regulations or any other edition of BS7671 or just the edition preceding the current one and if the one preceding current one was that by IEE/IET number or BS7671 number. ... BS7671 only came out in 1992 so nothing in the wiring regulations before 1992 would be a previous edition of BS7671. This means lack of earths to lighting was not allowed in any previous edition of BS7671.

The 'note from the HSE' on page 12 of the BGB refers to work undertaken in compliance with earlier editions of BS7671 or the IEE Wiring Regulations (i.e. back to 'year dot') - and says that work undertaken in compliance with such old regs does is not necessarily non-compliant with EAWR.

But returning to the RCD question the big thing is the danger from using a single RCD is not an electrical danger. It is all connected with lighting ... So as well as the immediate problem of being plunged into darkness if there was a earth fault stopping the power being restored would the house still be inhabitable for the time it took to get professional assistance to restore the power?

Quite, and I think people probably sometimes get over-concerned with interpretations of 314. For a start, as you say, we're not talking about 'electrical dangers' per se. More to the point, sudden loss of lighting due to fault on some other circuit (which 'divisoon of circuits' is designed to reduce) is no less dangerous than sudden loss of lighting due to a fault in the lighting circuit itself - so if it were considered significantly 'dangerous' not to divide circuits so as to reduce the risk of lighting loss, there would logically be a requirement for emergency lighting (which would,of course, then remove the need for the division of circuits!).

KindRegards, John