EICR Fail Codes

[JohnW2]

Like on a TT supply.

... and when anyone, particularly an non-electrician, 'fiddles' within a CU. Earthed metal around (they'll be some, even with paint) is not the most desirable of things in that situation.

From the very start, I've been repeatedly saying that it is 'only a matter of time' before someone dies as a result of a domestic CU being metal, and that may even already have happened.

Kind Regards, John

 

[EFLImpudence]

I've had email correspondence with someone connected with producing BS7671. The guidance I had was that if it's combustible and in an escape route then code it C2, otherwise either code it C3 or don't even mention it. But that is "personal opinion" and not official guidance.

Well, that explains a lot and unfortunately it is not good.

What stupid things to say.


Why does anyone want guidance? The regulations are quite clear. If they don't state something then it doesn't apply.

There is no mention of what your someone is babbling about.

 

[JohnW2]

I've had email correspondence with someone connected with producing BS7671. The guidance I had was that if it's combustible and in an escape route then code it C2, otherwise either code it C3 or don't even mention it. But that is "personal opinion" and not official guidance.

Indeed, that surely is very much a "personal opinion" which is not necessarily any better than anyone else's?

It's not even as if it is a matter of interpretation (of the intention of) something that is written in BS7671, since BS7671 makes absolutely no distinction, anywhere, between domestic CUs in escape routes and domestic CUs in any other locations. Furthermore as I recently wrote, nor does BS7671 anywhere, or in any context, make any attempt to talk about different degrees of 'dangerousness' (e.g. 'improvement recommended' vs 'requires urgent remedial action') of this that are not compliant with its current version, and therefore does not pretend to offer any guidance as regards the coding of things on an EICR. This #personal opinion' is therefore not really anything to do with BS7671.

I therefore don't really see why someone who is "connected with producing BS7671" should be any more able to offer guidance on such matters than anyone else who knows about electrical installations. Indeed, if his view were shared by a significant number of other people who were "connected with producing BS7671", one would imagine that BS7671 would make distinctions between domestic CUs in escape routes and in other places, wouldn't one?

Kind
Regards, john

 

[securespark]

I obviously do not know the person Simon spoke to, but I have in the past had conversations with the "movers and shakers at the IEE (later IET) who had a hand in contributing to the compilation of the regs as they also formed part of the technical team you could ring up and talk to if you had a query about the regs.
These people often wrote "guidance" articles that were published in trade magazines and later appeared on the interweb.

So I don't know when assistance (with interpretation of the book) from the IET changed into "personal opinion". After all, if they can't untangle the meaning of the words and make it more understandable, what chance has anyone else?

For such an important document, you think the authors would employ assistance from the Plain English campaign when compiling the regs.

I have a feeling that the reason it is not is that the 14th Ed. was much criticised for being too much of an instruction manual that any Tom, Dick or Harry could pick up and follow, rather than a technical document for trained electricians to use.

So I think it was decided that subsequent editions would be less so.

Which is why it was that use of the 14th Ed. was extended and the full introduction of the 15th was delayed until 1st January1985 --
because there were complaints from electricians used to the 14th and prior editions that they could not fathom the new regs.

Edited for clarity.

 

[ericmark]

Yes you have a good point about plain English or English and Welsh if in Wales. We start at the beginning, EICR with the electrical installation first, so question one, is it electrical, if not, then nothing to do with the EICR, so wooden stairs are not electrical so nothing to do with the report, installation is next, not listed in my old copy of BS 7671, but I would say it is everything what is not an appliance. Fuse box, wiring, CU, sockets, bulb holders etc. However the Building regulations seems to expand on that, they consider anything fixed as being part of the installation, so now we all a whole load extra.

Wall mounted hand drier
Extractor fan
Immersion heater
Built in cooker
Cooker hood
Central heating boiler

Ups now that's a problem, can I as an electrician remove all covers on the central heating boiler to access the electrics? If there is flex between a FCU and a boiler, I need to check if that flex has clamps on it.

There is also the question of light fittings, if we are going to do a full test and check, then a pendent light fitting should be able to take a load of 5 kg, (559.6.1.5 in BS7671:2008) now there is only really one way to be sure OK, if we consider a lamp shade and bulb is less than 1 kg, then a 4 kg weight would be a reasonable test with lights that are clearly no where near capacity with existing lamp shade, we could weigh the existing shade with kitchen scales, where it seems existing fitting is a bit heavy.

OK this is tongue in cheek, I do not think it is reasonable to check they can take a 5 kg load, and I suspect one would end up with a load of ceiling roses pulled out of the ceiling if you did.

What is reasonable when installing is not the same as reasonable when returning to check. Main thing is when I install some thing, I have the instructions that have come with the item, so if the boiler says must be protected with a type A RCD I know I need a type A RCD, but if I see an Ariston E-Combi One Gas Combi Boiler is fitted, how do I know if it needs a type A or type AC RCD? OK I did down load the installation instructions and did a search for RCD and nothing, just follow IEE instructions not IET so clearly written some time ago also says use 240 volt supply not 230 volt, and do not connect control cables to 240 volt as it uses low voltage for control, I thought 240 was low voltage? Selected as cheapest on Screwfix website.

Now with the Worcester Bosch Greenstar 8000 Life 45C Gas Combi Boiler it says

The correct type of RCD must be employed where additional protection is required that is suitable for a low energy DC modulating pump according to IET wiring regulations.

Selected as most expensive gas boiler on screwfix site. I would assume that means type B?

So should the EICR inspector be down loading all installation instructions for everything installed to ensure correct RCD is fitted? Yes the boiler installer should check, but what about the EICR inspector?

 

[EFLImpudence]

You would, presumably, also have to determine whether the boiler manufacturer had demanded RCD protection because the boiler actually needs it (why would it?) or simply because all circuits must now be covered by an RCD.

Similar to only some shower manufacturers actually stating that the circuit must have an RCD - and
extractor fan manufacturers stating all sorts of things are required but not stating why exactly.

In other words are they considering the product or merely stating what they think the electrical regulations require?

 

[ericmark]

It says

low energy DC modulating pump

the one set of instructions I found did not actually say what type is required, the example posted by @stem actually said use type A.

But my point is not if a boiler does or does not need a RCD and if so what type, but how an inspector who is looking at the installation which when I was taught did not include appliances, if going to know what an appliance needs, or if he can even safely remove appliance covers.

When I did inspecting and testing our equipment register included all appliances, and against certain items there were notes like "Maintained by ABC catering supplies, not to be tested by XYZ personal phone xxxx xxxxx if fault noted" as to if ABC catering supplies actually tested the items, we were to be frank not worried. And even in my own home at one time the fridge/freezer was on a maintenance contract. OK they only came when we phoned to say not working, however in theory it should have been maintained. And with items like boilers it is common for them to be maintained so as a result the PAT tester and the EICR inspector would not look at them, they are beyond their remit.

And this seems to be the problem, define the remit of an EICR inspector. Where I work, fire safety is done by an expert in fire safety, I never test a fire alarm unless asked to assist the fire safety man, the boiler inspector is the same, he may request we remove some thing so he can get access, but it is not my job to inspect a boiler. The safety officer will select who inspects and tests what, but does not do it all himself.

So in the home we have social services inspecting as to if OK for child care, the fire service will visit and fit if required smoke alarms, or tell you what is required, and it was on a Monday morning when the gas man came to call. And it all makes work for the working man to do.

When a fit a down light then it is my job to ensure any fire safety requirements are adhered to, but at that time I will have any paperwork that comes with it, 10 years latter with an EICR that paperwork will no longer exist in most cases, so the inspector has no idea if grade A1, A2, B, C, E or F and to be frank it's not his job to know.

As said before to make any reference to items out of your spear of expertise can be dangerous, the house buyers report due to including electrical items in the report with no disclaimer made it seem as if the report included the condition of the electrical installation.

So we can put "Suggest a fire prevention report is commissioned as there seems to be a lack of smoke alarms." but if we say "smoke alarm missing from kitchen" it makes it seems as if the EICR includes fire prevention.

"So noted seal missing on incoming DNO fuse, suggest to inform DNO." is OK, but to try and say this is potential dangerous is clearly wrong.

 

[JohnW2]

... So I don't know when assistance (with interpretation of the book) from the IET changed into "personal opinion". After all, if they can't untangle the meaning of the words and make it more understandable, what chance has anyone else?

As often discussed here, there are many aspects of BS7671 which are far from totally clear, such that there are problems of interpretation. However, as I wrote yesterday, the matter we are talking about is not a case of that.

As I wrote yesterday, no interpretation is required in relation to what BS7671 says about domestic CUs which are not 'non-combustible'. BS7671 does not anywhere make distinctions between CUs in different locations. Nor does it anywhere offer any instructions, or even 'guidance', as to what (if any) code should be given on a plastic CU (or any other specific non-compliance with current regs, come to that), anywhere. All is says, totally clearly, is that domestic CUs must be made of 'non-combustible' material (or housed in non-combustible enclosure), and says nothing about EICR coding of non-compliance (with this or any other specific reg).

Hence, if someone offers an opinion about the coding on an EICR of non-compliance with that reg, and particularly if his opinion is that the coding (if any) should differ according to the location of the CU, then absolutely none of that has got anything to do with 'interpreting BS7671' (which is clear and unambiguous on this point) - so, no matter how sensible the opinion may be, it surely cannot possibly be anything other than a 'personal opinion', can it (regardless who the person is and whatever association he might have with the writing of BS7671) ?

More generally, I think that people may be reading too much into the nature and purpose of BS7671. It exists merely to set out what is currently considered (by JPEL/64) to be the minimum safety standards for electrical installations. It does not seek, or attempt, to offer any opinions, or give any guidance, in relation to the degree of 'dangerousness' associated with any specific non-compliance - hence says absolutely nothing about what EICR codes (if any) should be given to any non-compliances.

I might speculate that some of this could be the deliberate result of considerations of legal liability. If, for example, BS7671 were to say/imply (by indicating that a C3, or no code, was appropriate) that some particular non-compliance did not "require urgent remedial action", then legal fingers could get pointed at them if, following some 'incident', the person who undertook an EICR (not indicating that any urgent action was required) said that he/she had merely followed the 'instructions' in BS7671.

On a more practical level, how 'dangerous' a particular non-compliance (hence how urgent the remedial action) is will often depend on the particular circumstances, and no set of rules could hope to comprehensively cover 'all possible circumstances' - hence, I think, expert/profession judgement is often going to be required, in all but 'obvious'/extreme situations.

Kind Regards, John

 

[SimonH2]

Well, that explains a lot and unfortunately it is not good.

I agree. But as I said, I am fairly certain they've stuck this thing in because LFB insisted on it, and only afterwards did the queries start rolling in and they were effectively forced to find some way of not peeing off millions of people in double quick time. I did push for an "official" statement, but nothing ever came of that.

But my point is not if a boiler does or does not need a RCD and if so what type, but how an inspector who is looking at the installation which when I was taught did not include appliances, if going to know what an appliance needs, or if he can even safely remove appliance covers.

You also missed out LEGALLY remove covers. Some boilers you can easily access the plumbing and electrics, but with others, accessing anything gets you into The Gas Safety (Installation and Use) Regulations 1998 territory, and specifically :

3.—(1) No person shall carry out any work in relation to a gas fitting or gas storage vessel unless he is competent to do so.
3.—(3) Without prejudice to the generality of paragraphs (1) and (2) above and subject to paragraph (4) below, no employer shall allow any of his employees to carry out any work in relation to a gas fitting or service pipework and no self-employed person shall carry out any such work, unless the employer or self-employed person, as the case may be, is a member of a class of persons approved for the time being by the Health and Safety Executive for the purposes of this paragraph.​

Because on some boilers, the main outer cover is also the front of the combustion chamber - so cannot be removed without bringing the GSIUR into play. While on other boilers, the combustion chamber is a separate cover so the main cover can be removed to give access to the plumbing and electrics.

... and it was on a Monday morning when the gas man came to call. And it all makes work for the working man to do.

For the younger members who might not get that classic reference.

 

[EFLImpudence]

I think a lot of these opinions on the location of CUs is to do with "Escape Routes".

As I have said before escape routes as defined in BS7671 Part 2 and in 422.2 by reference to the classifications in Appendix 4 do not apply to dwellings where there are no official escape routes; any means of escape being the necessary escape route in case of a fire.

For example, in a block of flats the requirements for passages and stairs (sign posting, emergency lighting, fire doors etc.) do not apply inside each flat but only to the escape routes.

 

[JohnW2]

I think a lot of these opinions on the location of CUs is to do with "Escape Routes". ... As I have said before escape routes as defined in BS7671 Part 2 and in 422.2 by reference to the classifications in Appendix 4 do not apply to dwellings where there are no official escape routes; any means of escape being the necessary escape route in case of a fire. ... For example, in a block of flats the requirements for passages and stairs (sign posting, emergency lighting, fire doors etc.) do not apply inside each flat but only to the escape routes.

That's all true, and I essentially agree with all you say.

However, at least one of the trade organisations (was in NAPIT?) have talked not only about CUs "in escape routes" but also one "under stairs" - and there's no doubt that the concept of "under stairs" does exist in relation to all multi-storey domestic dwelling units.

Kind Regards, John

 

[EFLImpudence]

That's all true, and I essentially agree with all you say.

Ok.

However, at least one of the trade organisations (was in NAPIT?) have talked not only about CUs "in escape routes" but also one "under stairs" -

Maybe, but what I am saying is that they shouldn't and there are no specific escape routes in dwellings.

and there's no doubt that the concept of "under stairs" does exist in relation to all multi-storey domestic dwelling units.

What do you mean by that?

 

[SimonH2]

If we take a step back from "he said that, they guided the other, ..." and consider what the point of the EICR is ...
So we have a plastic cased CU where the regs say it has to be steel. Is that "dangerous" given the particulars of this specific installation - not in general, not for other installations, but for "this" installation that is being inspected/tested ?
So the first step would have to be: What is the risk ? And the answer is that if the connections have been loosened by a ham fisted meter fitter, will the plastic case contribute to the ensuing fire, and is that a danger to life ?

If the CU is out in the garage, with a solid block wall and a closed door between that and the dwelling space - then the risk is pretty minimal. The fire isn't going to affect the ability of the occupants to get out.

If the only way out of the property means having to get to a door (and unlock it in the dark), with the CU spitting burning plastic at you - then the risk is "quite a bit higher".
Similarly, if the stairs are made from dried wheatabix, and the CU is fitted hard against the underside of a tread, then there's a risk that a problem in the CU could quite quickly compromise the integrity of the stairs - and if that's the only easy route out from the upper floor(s), then that's "not a good thing".

So if we take a starting point on which I think we are all agreed - a plastic cased CU doesn't comply with current regs - then the question is, does this non-compliance constitute a danger that should be coded ? And this is where the guidance comes in.

IMO, taking the case of the garage above, then that's probably just a note at most. The various "stuff" typically found in the garage is likely to be more of a risk - we allow petrol to be stored in plastic containers.
If the only way out from the upper floor(s), and possibly the whole property, means passing a burning CU or using stairs with an incendiary device underneath, and the house doesn't have any smoke alarms to give early warning, then that's clearly not a zero risk situation - and IMO worthy of a C2.
But where does that leave a 2 storey house, with open plan downstairs (so stairs open to living area), with working interlinked smoke alarms, and CU on the living room wall opposite the stairs ? Getting downstairs and to the front door doesn't involve going near the CU - but any smoke emitted by the CU will be affecting this exit route. Occupants should be alerted by the smoke alarms in the early stages, so should be out before the smoke gets bad. So C3 ? Clearly there is some risk inherent in the non-compliance, but it's not high (IMO).

 

[JohnW2]

Maybe, but what I am saying is that they shouldn't and there are no specific escape routes in dwellings.

We are agreed tat they shouldn't - but they do.

My point was that, quite apart from theie reference to "escape routes" (which, as you say probably don't exist within domestic dwellings), as a totally separate issue they also talk about "under stairs" (which does exist within many domestic dwellings).

... so, to my mind, "they shouldn't" in either case - in the first case because they are talking about something that probably doesn't exist within domestic dwellings and, in the second case, probably simply because "they shouldn't" (because they are making up something that doesn't exist in the regs).

What do you mean by that?

As above - that, whilst "escape routes" probably don't exist within domestic dwellings, "under stairs" does.

Kind Regards, John

 

[JohnW2]

... If the only way out of the property means having to get to a door (and unlock it in the dark), with the CU spitting burning plastic at you - then the risk is "quite a bit higher". ... Similarly, if the stairs are made from dried wheatabix, and the CU is fitted hard against the underside of a tread, then there's a risk that a problem in the CU could quite quickly compromise the integrity of the stairs - and if that's the only easy route out from the upper floor(s), then that's "not a good thing". So if we take a starting point on which I think we are all agreed - a plastic cased CU doesn't comply with current regs - then the question is, does this non-compliance constitute a danger that should be coded ? And this is where the guidance comes in.

I think you are merely underlining what I have said - that, even though it introduces all sorts of complications/problems in relation to the competence and consistency of inspectors, in many cases (like the one we are discussing) it will inevitably require professional/'expert' judgement to assess how dangerous (if at all) a particular non-compliance is in a particular situation, hence what code to give on an EICR.

No 'guidance' can be comprehensive enough to always preclude the need for this 'expert judgement'. Even if the guidance included the case of the stairs being made out of Wheatabix, what if it were made out of Shredded Wheat?

Kind Regards, John