EICR, plastic CU, coding and the checklist

[SimonH2]

OK, it seems (from what I can find online) that advice at the moment is to code C3 if a plastic CU is under wooden stairs or in an escape route - but not to even note it otherwise. So if the plastic CU is somewhere out of the way - not in an escape route or under stairs - what do you put for checklist item 4.4 "Condition of enclosure(s) in terms of fire rating etc (421.1.201; 526.5)" ? (Model EICR form in appendix 6)
It's not C1 or C2, consensus seems to be that it's not C3, it's not FI or N/V or LIM or N/A.
Can't just leave it blank. And if consensus is that it doesn't even need to be noted, then putting a C3 here would then lead to the question of why there isn't a corresponding entry in section K.

 

[EFLImpudence]

If a plastic CU, wherever it is, is not C3 - not to current regulations so improvement recommended - then why the need for the requirement for metal CUs at all?

That's the trouble with people writing the innumerable totally unnecessary guides for everything.




Thou shalt not kill. Now write a book about what it means.

 

[JohnW2]

OK, it seems (from what I can find online) that advice at the moment is to code C3 if a plastic CU is under wooden stairs or in an escape route - but not to even note it otherwise.

Per what EFLI has said, I wonder who on earth came up with that 'advice', and how/why?

Whatever we may think about it, the regulation is clear enough (other than in relation to the material it requires a CU to be made about) - and says nothing about escape routes or 'under wooden stairs' (or locations other than those).

... or is it being suggested that, as a generalisation, someone undertaking an EICR can use discretion to decide whether or not to give a C3 to (or 'even note') something which is clearly non-compliant with a current regulation?

Kind Regards, John

 

[flameport]

If the consumer unit is plastic, and it's installed in a domestic premises, and it's not totally enclosed in a steel or other non-combustible cabinet, then the code is C3.
The location within the domestic premises is irrelevant.

If it's not in a domestic premises, then no code, as the regulation only applies to consumer units in domestic premises.

 

[SimonH2]

I have to admit, I thought it was odd to suggest not coding it C3.

But, that's what advice seems to be :
https://www.electricalsafetyfirst.org.uk/media/1200/best-practice-guide-4-issue-4.pdf
Page 10 : Since Amendment 1, BS 7671: 2008 has not required non-compliances with 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.
Page 16 (examples of C3) : Presence of a consumer unit or similar switchgear made from combustible material (e.g. plastic) that is not inside a non-combustible enclosure and which is:
• Located under wooden staircase,or
• within a sole route of escape from the premises
And on page 17 (Items worthy of note that do not warrant a classification code), the same text but for where the CU is not in the escape route or under wooden stairs.

Since both BSI and IET are stated to have contributed to or supported the guide, it's hard to see how this guidance doesn't have at least "official blessing". Very confusing, and as pointed out by EFLI - it seems to be saying that "the regs say we need X to be safe, but the guidance says that not having X is safe"
I guess it all comes down to interpretation of what 653.2, item 4, means : "any non-compliance with the requirements of BS7671 which may give rise to danger" - specifically the bit I've put in bold. As above, both BSI and IET have put their name to a document saying that a plastic CU does not (of itself) give rise to danger unless it's under wooden stairs or in the sole escape route.
IMO that's a pragmatic approach since we've used plastic CUs for "a lot of years", and coding them all C3 means just about every EICR will have a defect listed on it. But once again, it takes a clear* statement and throws it over to the inspector to make a judgement call.

* Yes, we can leave out the "discussions" about what "non-combustible" means

 

[SimonH2]

Well in light of this "confusion" I've emailed ESR and IET about this apparent conflict where what looks like "official" guidance is effectively saying a reg doesn't matter. Be interesting to see if I get a reply from either of them !

 

[JohnW2]

I have to admit, I thought it was odd to suggest not coding it C3. But, that's what advice seems to be : https://www.electricalsafetyfirst.org.uk/media/1200/best-practice-guide-4-issue-4.pdf

We've seen some very odd things written by those people in the past. [In parrticular, I note that they have removed all the very iffy 'data' they used to have their about electric shocks and electrocutions, and now just have stuff related to allegedly electrical fires].

Since both BSI and IET are stated to have contributed to or supported the guide, it's hard to see how this guidance doesn't have at least "official blessing". Very confusing, and as pointed out by EFLI ...

The OSG not only has their 'official blessing' but is actually published by them, but it contains all sorts of 'guidance' which is not directly related to compliance (or even conformity - see below) with BS7671.

I guess it all comes down to interpretation of what 653.2, item 4, means : "any non-compliance with the requirements of BS7671 which may give rise to danger" - specifically the bit I've put in bold.

I would personally say that it's a bit worse than that ... given that the 18th now defines "non-compliance" as "a non-conformity which may give rise to a danger", the qualification which you emboldened above is not even necessary - since if some non-conformity "may not give rise to a danger" then, by current BS7671 definition, it is NOT a non-compliance"!

Is that not perhaps what a lot of this new confusion is all about. For the first time in history, the 18th had made a distinction between 'a non-conformity with BS7671' and a 'non-compliance'. Is their intention now that only non-compliances (per there definition) need to be coded (or even 'mentioned') in an EICR, and that things which are merely non-conformities (but not meeting their definition of 'non-compliance') don't need to be mentioned at all?

.... which, of course, would beg a question, given that BS7671 is essentially about 'safety', if something is not regarding as necessary to address a potential danger, then why would BS7671 'require' it?

Kind Regards, John

 

[SimonH2]

.... which, of course, would beg a question, given that BS7671 is essentially about 'safety', if something is not regarding as necessary to address a potential danger, then why would BS7671 'require' it?

Exactly !
But there is a more serious issue as well. Once you get into the realm of "but only if it presents a danger" then you immediately open everything up to interpretation by the installer/inspector as to what "presents a danger". So as you point out, it's now valid to not comply with BS7671 if you think it's safe to do so - but then why have regs rather than guidance

 

[JohnW2]

Exactly ! But there is a more serious issue as well. Once you get into the realm of "but only if it presents a danger" then you immediately open everything up to interpretation by the installer/inspector as to what "presents a danger". So as you point out, it's now valid to not comply with BS7671 if you think it's safe to do so - but then why have regs rather than guidance

Quite so.

With just a handful of words in Part 2, the 18th seems to have introduced a whole new can of worms, almost to the extent of making 'regulations' pretty meaningless. Previously, it was pretty clear that one was required to conform with the regulations, and that such conformity constituted 'compliance' - and I also imagine that virtually everyone assumed the converse - i.e. than non-comformity meant non-compliance.

However, all of a sudden it seems that we can have non-comformities which are not regarded as non-compliances - which, as you say, leaves almost everything to the discretion/judgement of whoever is interpreting the regs, and 'working to' those personal interpretations!

Kind Regards, John

 

[EFLImpudence]

Once you get into the realm of "but only if it presents a danger" then you immediately open everything up to interpretation by the installer/inspector as to what "presents a danger".

That is the fundamental principle of EICRs - that it iS up to the interpretaion of the inspector using his knowledge and experience; not a tick list.

 

[EFLImpudence]

I see no difference between plastic CUs and fuse boards. They are just not to current regulations and therefore C3.

Neither does present a danger if installed correctly.

 

[JohnW2]

I see no difference between plastic CUs and fuse boards. They are just not to current regulations and therefore C3. Neither does present a danger if installed correctly.

Yes - but, as discussed, if they don't "present a danger" then, in the language of the 18th, they are not non-compliances - so are you saying that some things should be given C3s even though they are not considered (by the 'inspector') to be (per 18th definitions) "non-compliant"?

Kind Regards, John

 

[EFLImpudence]

Is "non-compliant" the determining factor for C3s?
Whether the words have been used correctly or not, is a matter for debate.

The plastic CU is not to current regulations - i.e. should/could not be fitted now - therefore C3, surely.
If anyone disagrees with that then it must also follow that 'combustible' CUs may still be fitted.
They cannot have it both ways.

Is there anything in the new regulations which specifically says CUs shall not be installed under the stairs in a cupboard?

 

[EFLImpudence]

Condition Report:

Improvement.....l....State
recommended....l......C3

4.4 Condition of enclosure(s) in terms of fire rating etc. (421.1.201; 526.5)

The only alternative is 'Acceptable condition' which you may think is appropriate but if you do then so too would be a new one of the same material.

 

[SimonH2]

That is the fundamental principle of EICRs - that it iS up to the interpretaion of the inspector using his knowledge and experience; not a tick list.

Indeed, but here we are talking about something that SHOULD be a simple yes/no in terms of meeting regs.

I see no difference between plastic CUs and fuse boards. They are just not to current regulations and therefore C3.
Neither does present a danger if installed correctly.

And it's that latter bit that matters, because in the 18th edition, it is now allowed to depart from the regs where it does not present a danger. Go and read 653.2, item 4, where it says : "any non-compliance with the requirements of BS7671 which may give rise to danger".
So it is clear that non-compliance isn't sufficient reason for reporting, and hence if you say that a plastic CU does not present a danger if installed correctly, then it should not be reported if it's properly installed (and doesn't have other faults such as heat damage from loose terminals).

If they had omitted the words "which may give rise to danger" then it would be simple - Plastic CU = C3 report. But instead we are now left with the judgement call of whether the specific plastic CU in the specific installation "may give rise to danger".

I wonder if I'll get an answer to me email