EICR Details please

[ericmark]

Sampling is the norm. Excessive dismantling is potentially as likely to introduce faults as find them. That said, this should always be agreed with the person ordering the work (in this instance likely the landlord or letting agent).

I would agree with this, we had problems with terminals being checked for tightness and necking off the wires, and the maintenance free connector block was a gods send. And if maintenance free why do you need to maintain it?

The LABC can and has engaged an inspector to look at work completed, and often with very clear instructions for example to list all code 4 items, where the installation does not comply with current regulations, and also very clear LIM where only items fitted during resent building work are tested.

It is up to the client to say what is tested, there is nothing to stop the client saying the extension was only done 2 years ago, it does not require testing, or even don't bother with the garage. If the LABC want an EICR then they need to commission it.

I have worked with a running EICR system many times, we do one bit one week and another bit the next time, and as long as the limitations are listed there is nothing wrong with that. In essence the EICR is not fit for purpose in making sure whole house is fit for human habitation unless like with the car MOT the government lists what must be checked.

If some one does an EICR and does not check what they say they have checked, then that is clearly some thing trading standards may be interested in, but as long as the inspector tell the truth, the contract is between him and the client and nothing to do with anyone else.

 

[Furkin]

Thanks to you all guys,
I'm sure that many other readers have learned something here as well.
Thank you for the valuable knowledge and time taken to write it all down.
all the best to you all.

 

[JohnW2]

It seems I may have fallen into a PIT, periodic inspection and testing. As with the English version it seems to suggest non portable equipment is included in the PIT, but the IET seems only to include lighting as current using equipment tested in an EICR.

A literal "EICR" is something invented and defined by the IET - i.e. as in BS7671. However, any legislation is, of course, free to require inspections that go beyond what is required for an ("IET") EICR.

Opinions will obviously vary but, for what it's worth, my personal view is that, as an assessment of the condition of an installation (the clue is in the "I" if EICR) the IET/BS7671 approach is probably reasonable. Forgetting any discussions about 'definitions', in common sense terms an electrical "installation" is the fixed wiring (as far as sockets, FCUs or other 'outlets)' and does not include ("current using") appliances/equipment/whatever - whether hard-wired or simply deemed to be 'non-portable' by virtue of size/weight/usage (even if connected via a plug/socket).

Lighting is, in my opinion, a grey area, and since light fittings will often remain in place and unchanged for the entire life of an installation, I don't personally think it unreasonable to regard them as part of the 'fixed wiring' (hence part of the 'installation').

This is why I was looking for actual law, but could not find it.

It is confusing. As far as I can work out, what is being described as "new" Welsh legislation is, in fact, about 6 years old (but perhaps not yet implemented, fully or at all). One of the guidance documents (see here) says

The Renting Homes Act is the biggest change to housing law in Wales for decades. .... From 1 December 2022 we plan for the Renting Homes (Wales) Act 2016 to change the way all landlords in Wales rent their properties. It will improve how we rent, manage, and live in rented homes in Wales.

The only fairly new legislation appears to be "Renting Homes (Amendment) (Wales) Act 2021" (see here) , but that seems to be just a list of amendments (mainly relating to contractual and admin matters, as detailed in Schedules 5/6) to the original original Act (Renting Homes (Wales) Act 2016 ).

If I understand correctly, other than for the amendments mentioned above, what will be "new" as of 1st December 2022 is that the 2016 legislation will then be 'implemented. That legislation can be found (here) and, although I haven't yet had time to look at it myself, I imagine that it's probably that which you need to be looking at.

Kind Regards, John

 

[ericmark]

I personally think the EICR is really a good tool, it allows the owner to plan ahead, to know for example if I want to add more sockets, I will need to upgrade the consumer unit first, or if it needs changing before an EV charging point is added, or solar panels.

And some warning if your likely to need to spend on part rewire, or other expenditure, before it hits the critical point where it needs doing as an emergency within the next 28 days.

I knew my parents house needed a re-wire, and it was some thing like 3 to 5 years latter I actually got it done, and to arrange and get it done, took the best part of 12 weeks, the time my mother was in hospital and a care home after.

The problem is the English law wanting it done in 28 days, that's all well and good for a new socket or consumer unit, but a full re-wire takes time to arrange, and complete, and to re-decorate after, so it is putting the landlord in a situation where he can't win.

It also places the inspector in a hard place, he knows a code C2 means it has to be done in 28 days, and also a C3 could be simply ignored. Deaths like this back in 2008 clearly could not be allowed to continue, but to be fair

Landlady Hilary Thompson had asked a local electrician to look over the property before the new family moved in, but because of work pressure, he had not done so.

and at the time I remember reading how the tenant was pushing the landlady to move in quickly, and some of the faults which contributed to the death were found with the tenants equipment, clearly it was only one of many faults, however it seems clear this cottage would have got a code C1 not a code C2, but it asks the question, what should be done when faults are found?

I have seen an EICR with a code C1, and the big question is how? If some thing is dangerous then it needs isolating before the inspector leaves, and if isolated it is no longer a C1, the only time a C1 should be recorded is with an empty property. Be it empty when inspected, or the inspector has arrange for alternative accommodation, but a property with tenants still in it, should never get a C1. But either a C3 must also be acted on, or a C2 needs more time, or a sliding scale of time so repairs can be completed or alternative accommodation found while the repairs are done.

 

[DetlefSchmitz]

I have seen an EICR with a code C1, and the big question is how? If some thing is dangerous then it needs isolating before the inspector leaves, and if isolated it is no longer a C1, the only time a C1 should be recorded is with an empty property. Be it empty when inspected, or the inspector has arrange for alternative accommodation, but a property with tenants still in it, should never get a C1.

I dunno. This gets worse every time you say it. I don't think I'd become an electrician if I suddenly had the responsibility to re-house a family.

 

[JohnW2]

I have seen an EICR with a code C1, and the big question is how? If some thing is dangerous then it needs isolating before the inspector leaves, and if isolated it is no longer a C1, the only time a C1 should be recorded is with an empty property. Be it empty when inspected, or the inspector has arrange for alternative accommodation, but a property with tenants still in it, should never get a C1.

dunno. This gets worse every time you say it. I don't think I'd become an electrician if I suddenly had the responsibility to re-house a family.

I hve to say that, every time he says it I have some difficulty in understanding it.

For a start, a C1 is a C1, and if that's what an inspector believes he/she has identified, then that's what they should (initially) report, whether the property is occupied or unoccupied - just as an MOT inspector will initially issue a 'fail certificate', even he/she subsequently undertakes remedial work and, then, issue a further ('pass') certificate. Hence the discussion is (or should be) about what happens after an (initial) EICR with one or more C1s is issued.

It's a bit more complicated in terms of 'moral responsibility', and probably also common sense, but in terms of the law I do 'wonder' about what we repeatedly see being said about what an EICR inspector "must" do if he/she identified what they regard as a CI.

We're not talking about gas, so, albeit I'm no lawyer, I'm by no means sure that someone contracted to (only) perform an EICR can remain on the right side of the law if they 'interfere' with the installation such as to make it unusable without the consent of the property owner (and even more so if the property owner has explicitly withheld such consent).

In practice, I would imagine and hope that any half-decent/competent electrician would do all they could to resolve the situation 'sensibly', and I would also imagine that it would be very rarely the case that it was not possible for them to do something to render the installation 'safe enough' (at least temporarily) without having to de-energise the entire installation. ... although I accept that there obviously might be some exceptions, like a 'totally smashed up' CU', with 'everything exposed'.

Kind Regards, John

 

[ericmark]

We are talking about if the premises are fit for human inhabitation. But unlike a car with a home the electricial installion is split into circuits, so often one can isolate a section without making the home uninhabitable, as you have said.

However to inspect and test at some point we need to turn off the power, so in real terms one has to re-energise rather than switch it off.

 

[JohnW2]

We are talking about if the premises are fit for human inhabitation.

... which it would be (as it was before the inspector arrived), unless the inspector did things which made it 'uninhabitable'- and, as I said, I think he/she could probably only do that (legally) with the property owner's consent/permission.

But unlike a car with a home the electricial installion is split into circuits, so often one can isolate a section without making the home uninhabitable, as you have said.

Quite so.

However to inspect and test at some point we need to turn off the power, so in real terms one has to re-energise rather than switch it off.

True, but I would regard failing/refusing to energise as being effectively the same as actively 'switching off' - i.e. something that could/should probably only be done (legally) with the property owner's consent/permission.

Forget about MOTs, because there are legal requirements (imposed on the tester) if the vehicle is regarded as unsafe to be driven on public roads. Instead, consider a situation in which you took your car to a service station for an 'informal' inspection/check (i.e. with no legal duties imposed on the mechanic, hence analogous to an EICR). which involved removal of one or more wheels, then, if, for whatever reason the mechanic felt that the car was not safe to be driven, do you think he would be within his (legal) rights to refuse to put the wheel(s) back on in the absence of your consent to that (and particularly if you had explicitly withheld your consent/permission)?

Kind Regards, John

 

[JohnW2]

I personally think the EICR is really a good tool, it allows the owner to plan ahead, to know for example if I want to add more sockets, I will need to upgrade the consumer unit first, or if it needs changing before an EV charging point is added, or solar panels.

I'm not at all sure that the format of an EICR is such that the average member of the public could derive any guidance from it in relation to future requirements such as you mention.

Kind Regards, John

 

[ericmark]

The owner has to give permission to turn off the power, without that you can't do the test, I would agree one could simply not turn it on again, but not lock it off, so it would then be up to the owner to re-energise, so as long as instructions given in writing before one leaves then the inspector is off the hook, but needs to be in writing before he leaves, not sent though the post.

 

[JohnW2]

The owner has to give permission to turn off the power, without that you can't do the test, ..

Agreed (that is implicit in commissioning the testing). However, I'm talking about refusal to re-energise the installation (or, worse, 'lock it off' or remove the DNO fuse) - which, as I said, I doubt that (strictly speaking) can be done without permission.

I would agree one could simply not turn it on again, but not lock it off, so it would then be up to the owner to re-energise, so as long as instructions given in writing before one leaves then the inspector is off the hook, but needs to be in writing before he leaves, not sent though the post.

I suppose that's fair enough, but it still requires that the occupier is happy to "re-energise". Right up to her dying day, my grandmother would not touch so much as a light switch or TV switch, so she certainly would not have touched anything in a CU - so, if an inspector had done to her what you suggest above, he./she would have effectively made the property 'uninhabitable'.

Kind Regards, John

 

[ericmark]

I had it with an oven with my mother, council social services sent some one to teach her how to use an electric oven, the instructor said turn off at the FCU when finished, and on turning back on oven would not work without resetting the clock, and in a wheel chair she could not see it well enough to reset it.

She would not believe me, had to get social services to send some one to tell her they had made a mistake.

Excuse was the teacher used gas, but when I asked if she turned gas off at isolator when finished could not get an answer.

But if there is a code C1 then it should not be re-energised until fixed, I would assume this is why the law says the inspector must be able to correct errors?

 

[JohnW2]

But if there is a code C1 then it should not be re-energised until fixed, ...

As I've said, one would assume and hope that any half-decent/competent/sensible person undertaking an EICR would do just that

I would assume this is why the law says the inspector must be able to correct errors?

As I undertsand it 'the law' merely requires that the person undertaking the inspection be 'competent to' undertake remedial work, not that he/she has to.

Furthermore, the legislation does not appear to require the person undertaking the inspection to be member of a CPS. If they are not, and if the required remedial work were notifiable (e.g. replacing a CU), then the process of involving LABC would presumably take appreciable time?

Kind Regards, John

 

[plugwash]

But if there is a code C1 then it should not be re-energised until fixed, I would assume this is why the law says the inspector must be able to correct errors?

Though at least the electrical safety council guidance implies that said fix doesn't have to be perfect/permanent. For example it says.

"For example, where there are accessible, exposed
live parts due to blanks missing from a consumer
unit, suitable temporary barriers should be provided
to protect persons from direct contact with those
live parts"

The problem IMO comes when, as is all too often the case, an inspector comes across a complete basket case of an installation. Rubber wiring that was life-expired decades ago. Horrible bodges as the installation was extended. If on top of that one has say a "smashed up fusebox" what is an inspector to do?

Having said that we are now past the deadline in most cases for private rental properties to get their first inspection, so "complete basket cases" should be pretty rare in that sector going forward. We will probabbly continue to see them in owner-occupied properties for a long time though.

 

[ericmark]

Furthermore, the legislation does not appear to require the person undertaking the inspection to be member of a CPS. If they are not, and if the required remedial work were notifiable (e.g. replacing a CU), then the process of involving LABC would presumably take appreciable time?

No it has been always been permissible to do emergency work without informing LABC first.

Having said that we are now past the deadline in most cases for private rental properties to get their first inspection, so "complete basket cases" should be pretty rare in that sector going forward. We will probabbly continue to see them in owner-occupied properties for a long time though.

No not started yet, does not come in until 1st December. The problem is can't actually see where it says must be done in any law, the guides to the law says it must be done, but enter EICR or PIT in the "Find in page" and every page reports not on the page, the

“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;

likely applies equally in England and Wales, so as with English regulations it includes current using equipment like immersion heater, boiler, cooker, and dishwasher, washing machine, and drier if not on wheels. I can't remember the weight at which without wheels not classed as portable think 18 kg, and a tumble drier is over that.

One of these costs £8.50, only needs a tie wrap so needs a tool to remove, but I don't have a large supply in my tool box. I was very nearly in a lot of trouble locking off, no on site transport, walked around the Sizewell 'B' building site, told to remove a motor on a crane, so used one of those to lock off, with a lock, and left the key in foreman's hut, if not me replacing the motor, electrician did not have to walk across the site and get the key.

Fitter arrived, and decided he wanted to move crane first before doing the work we had removed the motor for him to do, he got the key, and switched it back on, there were sparks as a result. I know my fault, key should have not been left with some one not classed as competent, lucky for me, the fitters foreman blamed him not me. But I know really my fault, had HSE been involved I would have been taken to court. I was very lucky.

The same goes for insulation tape where a CU blank is missing, we know most people would not remove it, same as insulation tape holding a MCB off, it is one would hope clear it should not be removed, however if some one does, the electrician is up the creak without a paddle. We know it should require a tool or key to remove it, we can't say not our fault.

Basic thing is when the owner gives you permission to work on the installation he knows you will turn it off, and can't turn it back on unless safe to do so. The one where it becomes a grey area, is the faulty consumer unit with no isolator, you can't win, phoning the DNO is no good, must be in writing, and you should not remove the DNO fuse, they should provide an isolator I know, but two wrongs don't make a right. As to if you can send the DNO a text message, fax, or email I don't know, but needs to be in writing, so only way is to lock the home.

So if you ensure everyone outside the house and lock the house, you have complied, even if there are other keys, you need a key or tool to gain access to live parts. Totally crazy I know, and can't see it ever being done, but when you read court cases, it seems they do expect one to go to silly lengths.

I would say giving an electricians mate a meter to plug in, press the button, and record the results was well within what an electricians mate can do. But in the Emma Shaw case the court did not agree, I read cases like that and think there by grace of god go I, I would have never expected any electricians mate I worked with to fudge up some results, OK entering the electricians mates name on the certificate was wrong, however in the same way with any EICR, EIC, Minor Works, the person ordering the work should insure the person doing the work is qualified to do it, how many home owners ask for the electricians certificates.