EICR Fail Codes

[EFLImpudence]

Perhaps the two - gas and electric trades - are more similar than I thought.

With gas there also seems to be an awful lot of guidance - something which, in my opinion, leads to most of the confusion.

 

[denso13]

I'm sorry for my ignorance on the subject, I did mean pressure at the appliance

No problem, it could mean at the appliance though.

I thought you would adjust it so that it was correct.

I suppose that actually reflects the views by ericmark that dangerous items on an EICR should be fixed at the time of the EICR visit.

It could mean substantial work to rectify things on a CP12 which is really only a report on the installation, not a pass or fail.

 

[EFLImpudence]

Ok, fair enough.

The two are more similar than I thought.

Perhaps all my boilers have been alright (I've had a lot looking after flats) and the engineer did not have anything to wonder about so it seemed more straightforward.

 

[denso13]

something which, in my opinion, leads to most of the confusion

You could be correct although the primary gas legislation is law, https://www.legislation.gov.uk/uksi/1998/2451/contents/made

 

[JohnW2]

No doubt there will be some differences but I'm not sure about appreciable.

Is that not the big difference (between gas inspections and EICRs), then?

As I said, in terms of EICRs, there certainly seem be a good few cases in which there are appreciable differences between 'inspectors'. I gave one, fairly topical, example, with some inspectors seemingly giving a C2 for plastic CUs under stairs, but many/most giving a C3, or maybe no code at all. Given the legal implications of a C2 (i.e. consequential costs to a landlord - given that a CU change is not cheap), that turns the whole thing into a lottery (i.e. pot luck as to which persuasion of inspector one gets) - which is surely not very satisfactory, is it?

Kind Regards, John

 

[denso13]

Is that not the big difference (between gas inspections and EICRs), then?

Seems to be which is what I was getting at here

In the gas industry, landlords safety checks (12 monthly or sooner) have been carried out for a long number of years and I can't recall when last I saw a query over one. Unless of course there were some to begin with which were clarified as time moved on.

which is surely not very satisfactory, is it?

Not at all, even to my untrained eye.

 

[JohnW2]

Seems to be which is what I was getting at here

Maybe it's because matters of gas safety are generally much more 'black and white' than matters of electrical safety?

Not at all, even to my untrained eye.

OK, so we are agreed that the 'lottery' situation with EICRs is unsatisfactory. However, there may be no practical solution if, as above, there are many electrical issues which are less than 'black and white', such that individual judgment/discretion has to be applied. There are many electrical issues for which it would be essentilly impossible to produce concrete absolute pass/fail criteria.

Mind you, that's by no means peculiar to EICRs. For example, there are many aspects of MOT tests which require 'human judgement' (hence potential differences of opinion), such that many/most of us have probably all heard of cases in which, following an MOT fail, the owner has immediately had the vehicle re-tested somewhere else, and got a 'pass'! Again, I see no practical way of avoiding that.

Kind Regards, John

 

[denso13]

there are many electrical issues which are less than 'black and white'

Perhaps, but is this not black or white

I gave one, fairly topical, example, with some inspectors seemingly giving a C2 for plastic CUs under stairs, but many/most giving a C3, or maybe no code at all.

I don't know the correct answer but it seems to me it there should be one correct answer, not possibly three. Or are the electrical regulations so ambiguous?

 

[JohnW2]

I don't know the correct answer but it seems to me it there should be one correct answer, not possibly three. Or are the electrical regulations so ambiguous?

Its not the 'electrical regulations' which are ambiguous, but rather that the matter of EICR coding is 'necessarily' fairly subjective.

The current version of BS7671 requires that all CUs iin domestic premises be made out of a 'non-combustible' material (which, in practice,, means steel) (or housed within a 'non-combustible' enclosure), whether they are under the stairs or anywhere else - so that is the case for newly-installed CUs. However, the regulations are not retrospective, so there is no requirement (as far as the regs are concerned) for an existing plastic CU to be 'upgraded' (to metal).

When it comes to an EICR, the inspector has to decide whether he/she feels that a plastic CU means that "improvement is recommended" (C3) or whether 'remedial action' is required "urgently" (C2) or "immediately" (C1) - and that's where the differences of opinion and variations arises.

.... and similar for countless other electrical issues.

Kind Regards, John

 

[denso13]

However, the regulations are not retrospective, so their is no requirement (as far as the regs are concerned) for an existing plastic CU to be 'upgraded' (to metal).

When it comes to an EICR, the inspector has to decide whether he/she feels that a plastic CU means that "improvement is recommended" (C3) or whether 'remedial action' is required "urgently" (C2) or "immediately" (C1) - and that's where the differences of opinion and variations arises.

So is there a correct "answer" or is it all subjective?

 

[EFLImpudence]

Or are the electrical regulations so ambiguous?

I have suggested that they are sometimes written to be ambiguous covering all a*ses.

Take what John mentioned:

Metal CUs are the latest requirement if being fitted now. Plastic ones do not have to be replaced just for the sake of it.

Government guidance for the new landlord safety check says C3s (improvement recommended) will be accepted.

Another guidance says it should be C2 (potentially dangerous and to be rectified) if in understairs cupboards. Someone has just made up that totally out of the blue.

 

[SimonH2]

When it comes to an EICR, the inspector has to decide whether he/she feels that a plastic CU means that "improvement is recommended" (C3) or whether 'remedial action' is required "urgently" (C2) or "immediately" (C1) - and that's where the differences of opinion and variations arises.

You missed out the other option I was advised by a representative of the IET. If the CU isn't in an escape route, then don't even mention it. But, that was given as a personal opinion and my requests for an official position supported by the IET was ignored.

As to the example given of gas pressure, that's a fairly simple one. The analogy in an EICR is you measure the loop impedance of a circuit, look at the relevant table, and if the loop impedance is too high to trip the OCP in the required time then it's a fail (a matter of judgement whether it's C1 or C2) - if it's low enough then you do nothing but note it on the test results page. For a gas appliance, you measure the gas pressure under full load - if it's below the manufacturer's specification then it's a fail, otherwise it's OK. I'm not sure how much leeway the tester has in terms of issuing an "at risk" (roughly a C2), or "immediately dangerous" (roughly a C1).
Most of what is checked for a gas safety check are similarly easy. There are laid down rules on siting of flues for example - so a flue either meets the rules or it doesn't.
I did say "most" there. There is some judgement in terms of things that are NCS (not to current standards), and there's some variation there. Some regs are explicitly retrospective - for example flue routing and it being accessible for inspection (many properties were build with flues boxed-in or otherwise hidden, and these needed works doing or failed inspection). Some would appear not to be - I know that in our flat, we can't fit a new boiler and use the same flue location, but as long as the same boiler stays there then it's OK - but I think there's also an element there of the extra condensation you get from a condensing boiler which makes the current location unsuitable.

Another guidance says it should be C2 (potentially dangerous and to be rectified) if in understairs cupboards. Someone has just made up that totally out of the blue.

If under WOODEN stairs actually. And I don't think it was completely out of the blue (or pulled from someone's backside).
The intent behind the guidance is clearly along the lines of "a conflagrating plastic CU shouldn't stop someone getting out of the house". if it's under the wooden stairs, then there's a logical risk that the fire gets going and the structural integrity of the stairs may be impaired before people have got out (and the FRS have checked that everyone is out). Similarly if the CU is directly in the escape route.
It's clearly been done as the IET have recognised the absurdity of telling people that the shiny new CU they had fitted 2 years ago now needs to be replaced because it's become dangerous - it obviously underwent some transmogrification at midnight when the new regs came into force, a bit like Kevin turning 13 But rather than properly admit the error and revise the regs, we have to put up with "not officially endorsed" guidance issued in the name of the IET to shift the problem onto everyone else.

 

[denso13]

Government guidance for the new landlord safety check says C3s (improvement recommended) will be accepted.

Another guidance says it should be C2 (potentially dangerous and to be rectified) if in understairs cupboards. Someone has just made up that totally out of the blue.

If that's the case, and I don't doubt it is, you can't really criticise "inspectors" for taking different views. Subjective feelings shouldn't come in to it where it seems a simple right/wrong answer would be easier.

 

[JohnW2]

So is there a correct "answer" or is it all subjective?

The problem is with this word 'correct' you keep using.

The only thing which is definitely 'correct' is that current regulations effectively require all newly installed CUs to be metal. The regulations say nothing specific about already in-service plastic CUs (which were compliant with regs at the time they were installed).

Other than in obvious/extreme cases, there is no 'correct' answer as to whether something not compliant with current regs (but compliant when installed) is 'no real problem' (just 'improvement recommended'), potentially dangerous (C2) or 'dangerous' (C1) - and that's what is subjective.

As I said, it's not really any different from the subjective judgments involved in MOT tests. One tester's 'corroded brake pipe' (=fail) might be another tester's 'superficial corrosion of brake pipe' (=pass, with an 'advisory' concerning 'recommended improvement').

Kind Regards, John

 

[JohnW2]

... Subjective feelings shouldn't come in to it where it seems a simple right/wrong answer would be easier.

As I've just written, in the real world there may not be a practically-implementable 'right/wrong answer'. In the example I just posted, what objective criteria would you specify for differentiating between 'corroded brake pipe' (=fail) and 'superficial corrosion of brake pipe' (=pass, with advisory)?

Similarly for 'play' in steering/suspension joints etc., or even rusty bodywork?

Kind Regards, John