EICR, plastic CU, coding and the checklist

[EFLImpudence]

Yes, but, as I mentioned, can you not have 'improvement recommended' for things which 'do not give rise to danger' and are 'not non-compliant' and indeed for things which are in an 'acceptable condition'?
After all, C3 does not mean anything has to be improved.

I do not know what was in their minds when they wrote the new definitions.
It would seem to indicate that we can do whatever we want as long as it 'does not give rise to danger'.

 

[JohnW2]

Yes, but, as I mentioned, can you not have 'improvement recommended' for things which 'do not give rise to danger' and are 'not non-compliant' and indeed for things which are in an 'acceptable condition'?

Quite. As I've said, maybe the idea now is that only things which are actually "non-compliant" (per the new BS7671 definition) should get C3s - and that things which "do not conform" with the requirements of BS7671, but which are judged by an inspector to "not give rise to danger" should not.

I do not know what was in their minds when they wrote the new definitions. It would seem to indicate that we can do whatever we want as long as it 'does not give rise to danger'.

Indeed. As I've said, with this new definition they seem to have opened up a massive can of worms, which brings into question the meaningfulness of having the 'regulations' at all - since, as you say, decisions about 'noncompliance' now seem to be down entirely to individual discretion/judgement!

Kind Regards, John

 

[EFLImpudence]

An example which has immediately occurred in another thread is that we no longer need run a CPC to all points where class 2 items are fitted.

 

[JohnW2]

An example which has immediately occurred in another thread is that we no longer need run a CPC to all points where class 2 items are fitted.

Who knows - it's seems to have become a purely individual personal judgement ....

... it's possible that the judgement of some individuals might be that not having a CPC at a 'particular point' "may result in a danger" if a Class I item is subsequently installed at that 'point', and therefore that to not have a CPC would be "non-compliant" - but, as you imply, if they do not take that view, then not having a CPU to the 'point' is presumable NOT "non-compliant"!

In my opinion, a total mess, created by a tiny number of new words!

Kind Regards, John

 

[SimonH2]

Yes, but, as I mentioned, can you not have 'improvement recommended' for things which 'do not give rise to danger' and are 'not non-compliant' and indeed for things which are in an 'acceptable condition'?

You can, but to what end ? There's been long "discussions" about whether having a metal (and therefore conductive) CU case can introduce other risks. So is replacing a perfectly safe plastic CU with a metal one automatically an improvement ? And would it be "recommended" ?

After all, C3 does not mean anything has to be improved.

Well, you and I (and I think most people here) would agree with that - but I suspect that if you asked a few people on the mythical Clapham Omnibus then you'd get a range of answers, many of which would be some variant of "if improvement is recommended then it must be unsafe in some way".
And at this point I might indicate what my interest in this distinction is. The EICR is for a flat which my wife and I rent out - so speaking with my other hat on (as one of the landlords commissioning the report) I would prefer to have a "clean sheet". The current (new) tenant seems to be a "good 'un", but I have had tenants in the past who will try anything - and that could include trying to claim unsafe electrics. It really doesn't bother me either way - we've a good tenant, and she won't be offered a copy of the report anyway.

 

[SimonH2]

Well I had a reply from someone fairly senior at ESR who was involved in changing the requirements for CUs - he's (quite understandably IMO) asked not to be dragged into an online discussion, many of which can get heated and be pointless time drains.
Their advice is indeed a pragmatic response to the spectre of having nearly all the CUs currently in use be "failed" in an EICR. Apparently early discussions were heading towards "no code", but they decided to add the risk based bit about when they are installed in high risk locations (under stairs, sole escape route). The new requirement raises the bar for new installations, but the costs of retrospectively applying it are considered excessive for the marginal increase in safety by replacing otherwise perfectly good CUs'
Also, (in response to my question about item 4.4 in the inspection schedule) he pointed out that as long as the CU met EN 61439-3 then it would have met the fire resistance requirements for that - and so would meet the fire resistance requirements to give a tick to item 4.4, apart from regulation 421.1.201 which it is advised to not apply retrospectively.

I did get the "comments are my own, but BSI & IET would agree" disclaimer - I've responded by asking if there is any official statement on the matter, which IMO is a quite significant departure from what everyone has been told to do in the past.

 

[JohnW2]

Their advice is indeed a pragmatic response to the spectre of having nearly all the CUs currently in use be "failed" in an EICR. Apparently early discussions were heading towards "no code", but they decided to add the risk based bit about when they are installed in high risk locations (under stairs, sole escape route). The new requirement raises the bar for new installations, but the costs of retrospectively applying it are considered excessive for the marginal increase in safety by replacing otherwise perfectly good CUs'

As a pragmatic viewpoint, that obviously makes good sense, particularly to those who question the necessity of 'non-combustible' CUs in the first place.

However, what about the more general, regulatory, question? Is it being said (and noting that "comments are my own, but BSI & IET would agree") that, in general, it is acceptable to not give a C3 (and maybe 'not even mention') something which is clearly non-conformant with what BS7671 "actually says" (presumably in the name of reducing/avoiding some alleged 'danger') - if (apparently contrary to the regs) the electrician does not believe that the non-conformity "may result in a danger"?

If they are (as I previously discussed) trying to hide behind the "non-conformant but not non-compliant" argument now apparently available, this would imply that an individual electrician is able to over-ride the whole apparent thinking behind 421.1.201 if he/she though that it ws not possible that having a plastic CU "may result in danger" - which would seem a rather odd 'official viewpoint" (which could presumably applied, if/when considered appropriate, to any regulation 'in the book').

KInd Regards, John

 

[EFLImpudence]

Their advice is indeed a pragmatic response to the spectre of having nearly all the CUs currently in use be "failed" in an EICR.

What about all the CUs that do/did not have RCDs?

Apparently early discussions were heading towards "no code", but they decided to add the risk based bit about when they are installed in high risk locations (under stairs, sole escape route). The new requirement raises the bar for new installations, but the costs of retrospectively applying it are considered excessive for the marginal increase in safety by replacing otherwise perfectly good CUs'

Why did they need (early) discussions in the first place?

Also, (in response to my question about item 4.4 in the inspection schedule) he pointed out that as long as the CU met EN 61439-3 then it would have met the fire resistance requirements for that - and so would meet the fire resistance requirements to give a tick to item 4.4, apart from regulation 421.1.201

So it wouldn't meet the non-combustible requirement, then.
'Fire resistant' is not the criterion.

which it is advised to not apply retrospectively.

Of course it doesn't; neither do any of the others (apart from bonding depending how you interpret the regulation). So what?

So, it means nothing and has no authority.

 

[JohnW2]

Of course it doesn't; neither do any of the others (apart from bonding depending how you interpret the regulation).

I'm sure that we have discussed this before, but there are surely some things which were 'acceptable' (and presumably compliant with whatever regs existed at the time), say, 100 (or even, some cases, 50) years ago which would would be totally unacceptable today, even if they had been acceptable (and 'compliant') when they were installed. In addition to things like the below, more recently VOELBs might be an example? Is there any formal sense in which such things are now 'outlawed' even though current regs are "not retrospective"?

Kind Regards, John

 

[EFLImpudence]

Perhaps such things were specifically stated for replacement - like bonding but generally, as you well know, the regulations are not retrospective..

 

[JohnW2]

Perhaps such things were specifically stated for replacement - like bonding but generally, as you well know, the regulations are not retrospective..

Sure, I obviously understand that - but, as I said, I was wondering what, if any, 'formal mechanism' there is for outlawing something which is obviously 'unacceptable' now if it were compliant with prevailing regs when it was installed.

Kind Regards, John

 

[EFLImpudence]

People are willing to accept that things should be updated - far too susceptible at times, it would seem.

The knife switch is a bit extreme; what else did you have in mind?


Of course, if they never want any work done, no one will know about such things.

 

[JohnW2]

People are willing to accept that things should be updated - far too susceptible at times, it would seem.

True.

The knife switch is a bit extreme; what else did you have in mind?

I'm sure I could think of a good few if I put my mind for it.

For starters, how about the (round) light switches I was brought up with, the covers of which could easily be unscrewed by a child 'without the use of a tool' (as I proved at the time!)? In fact, thinking back to my grandparent's house, in the 50s and early 60s, I'm not sure that there was much about the visible parts of the electrical installation which would be regarded as particularly 'acceptable' these days - although a lot of that was nothing to do with the 'fixed wiring'/installation!

Kind Regards, John

 

[EFLImpudence]

As for the round switches, I am sure fashion had them replaced - or breakages and not being able to find similar for replacement.

 

[JohnW2]

As for the round switches, I am sure fashion had them replaced - or breakages and not being able to find similar for replacement.

Very largely, obviously, but I wouldn't count on it as a universal truth ...

When an elderly neighbour died only a few years back, there seemed to be little (including lead-sheathed VIR cables) in the electrical installation of her cottage which appeared to have changed significantly since WW2, if not earlier! Much closer to home, there was at least one of those light switches in my cellar until I changed it relatively recently.

Kind Regards, John