EICR Questions

[donrkebab]

"653.2 The Report shall include the following:
- - any non-compliance with the requirements of BS 7671 which may give rise to danger"

Appendix 6
An installation which was designed to an
earlier edition of the Regulations and which does not fully comply with the current edition is not necessarily
unsafe for continued use, or requires upgrading. Only damage, deterioration, defects, dangerous conditions
and non-compliance with the requirements of the Regulations, which may give rise to danger, should be
recorded.

Note the word "danger" eg An unearthed lighting circuit has not complied for more than 50 years, and as long as all accessories are plastic it is not dangerous. I would note the fact, advise that metallic accessories and fittings should not be used, and that circuits of that age should be replaced due to hidden deterioration. But it is not a failure

 

[donrkebab]

I have a pretty good idea. For many years I have seen and reviewed several EICRs (PIRs in earlier years) every month (hence many hundreds in total), hence have a pretty good awareness of what is 'common practice'.

I review my bank statements every month!!

 

[JohnW2]

Note the word "danger" eg An unearthed lighting circuit has not complied for more than 50 years, and as long as all accessories are plastic it is not dangerous. I would note the fact, advise that metallic accessories and fittings should not be used, and that circuits of that age should be replaced due to hidden deterioration. But it is not a failure

I don't think that anyone has suggested that what you describe should be a 'failure' (i.e. C1 or C2). However, many would 'recommend improvement' (i.e. C3).

What do you mean when you say you would "note the fact"? - how/where would you record that 'note'?

 

[donrkebab]

What do you mean when you say you would "note the fact"? - how/where would you record that 'note'?

What I mean is perfectly understandable to anyone that wants to understand.

 

[flameport]

And isn't a Domestic Installer one of those "go on a 5 day course and you can carry on botching kitchen/bathroom installs" qualifications ?

It might be.
Or it could be that the person only does domestic work, and therefore hasn't been assessed on other types of installation because they don't have any examples of such work.

 

[ban-all-sheds]

I agree with everything you say in your post.

I have doubts about listing every single non-conformity as requiring improvement.

As it is, they now have a non-conformity as not having a ferrous metal enclosure - but there's some discussion about whether that should be listed as a C3 or not even mentioned.

I can't immediately think of any other examples, but I'd be surprised if there weren't any.

Indeed - and it's probably worth mentioning that, with the advent of the 18th, non-conformities are not necessarily regarded as non-compliances - since non-compliance is now defined as a non-conformity which may give rise to danger. That might give rise to a debate as to whether a non-conformity which is judged not to be a non-compliance necessarily even warrants a C3.

I'd forgotten that bit of non-conformant, (or possibly even non-compliant ), use of English.

With the disclaimer that I've only dipped into a couple of these https://www.google.com/search?q=conformity+vs+compliance it seems that either the difference is moot for 99.99999% (ish) of people, or they should never have used "compliance" in the first place. I have not yet found anything which agrees with their idea that non-compliance means a non-conformity which may give rise to danger.

 

[ban-all-sheds]

"653.2 The Report shall include the following:
- - any non-compliance with the requirements of BS 7671 which may give rise to danger"

And do you think that means non-compliance with the requirements of the current edition of BS 7671, or the one that was in force when the work was originally done?

Appendix 6
An installation which was designed to an
earlier edition of the Regulations and which does not fully comply with the current edition is not necessarily
unsafe for continued use, or requires upgrading. Only damage, deterioration, defects, dangerous conditions
and non-compliance with the requirements of the Regulations, which may give rise to danger, should be
recorded.

And do you think that means non-compliance with the requirements of the current edition of the Regulations, or the one that was in force when the work was originally done?

Note the word "danger" eg An unearthed lighting circuit has not complied for more than 50 years, and as long as all accessories are plastic it is not dangerous. I would note the fact, advise that metallic accessories and fittings should not be used, and that circuits of that age should be replaced due to hidden deterioration. But it is not a failure

But why would you note the fact?

You said

An EICR should only state factual discrepancies based on the regs at the time of installation,

According to that an unearthed lighting circuit which did comply when it was installed would not be a factual discrepancy.

 

[ban-all-sheds]

What I mean is perfectly understandable to anyone that wants to understand.

Just answer the question.

Where and how would you "note the fact"?

 

[JohnW2]

I have doubts about listing every single non-conformity as requiring improvement.

As we both have done, I went on to talk about the terminological issues - and my point was that I probably agree that every non-conformity "which may give rise to danger" (Simon did write "non-compliances") probably should be coded as "improvement recommended".

I have not yet found anything which agrees with their idea that non-compliance means a non-conformity which may give rise to danger.

I haven't looked into the linguistic issues but, whether anything/anyone else agrees or not, it is clear that BS7671:2018 has chosen to define non-compliance (for the purpose of the Standard) as it has - which I suppose is its prerogative!

 

[ban-all-sheds]

Considering ones wider responsibilities, I'm not sure that we should allow the redefinition of words to be the prerogative of a bunch of electrical engineers.

Particularly given that some of the documents my search uncovered seem to indicate that "compliance" and "conformity" already have well established meanings in the fields of legal and standards requirements...

 

[JohnW2]

Considering ones wider responsibilities, I'm not sure that we should allow the redefinition of words to be the prerogative of a bunch of electrical engineers.

I have sympathy with that statement, but I'm not sure how one can go about "not allowing" a definition that, for whatever reason, has been explicitly included in BS7671.
After all, one of the reasons why official documents very frequently include definitions of words (for the purpose of that document) is often because they are using the word in a manner which differs in some respects from what the word would be taken to mean in terms of normal English usage.
Without looking it up, I'm not sure what the 'established meanings' of "compliance" and "conformity" are but, off the top of my head, I think the way I usually think of it is that one "complies" (or not) with an instruction/order/law but that one "conforms" (or not) with a description/specification/whatever.

 

[donrkebab]

Just answer the question.

And now its barking out orders.

JWhere and how would you "note the fact"?

I feel that answering the question would seem like an insult, but it is obvious to anyone of average intelligence.

 

[ban-all-sheds]

I feel that you are twisting and wriggling and doing absolutely anything you can to avoid answering the question.

You see the problem you have is that what are obvious to anyone with average intelligence are these:

1) You'd "note those facts" via coding the items on an EICR

2) Doing that contradicts your "An EICR should only state factual discrepancies based on the regs at the time of installation"

Are they obvious to you?

 

[ban-all-sheds]

Also you seem to have missed this:

"653.2 The Report shall include the following:
- - any non-compliance with the requirements of BS 7671 which may give rise to danger"

And do you think that means non-compliance with the requirements of the current edition of BS 7671, or the one that was in force when the work was originally done?

Appendix 6
An installation which was designed to an
earlier edition of the Regulations and which does not fully comply with the current edition is not necessarily
unsafe for continued use, or requires upgrading. Only damage, deterioration, defects, dangerous conditions
and non-compliance with the requirements of the Regulations, which may give rise to danger, should be
recorded.

And do you think that means non-compliance with the requirements of the current edition of the Regulations, or the one that was in force when the work was originally done?

Note the word "danger" eg An unearthed lighting circuit has not complied for more than 50 years, and as long as all accessories are plastic it is not dangerous. I would note the fact, advise that metallic accessories and fittings should not be used, and that circuits of that age should be replaced due to hidden deterioration. But it is not a failure

But why would you note the fact?

You said

An EICR should only state factual discrepancies based on the regs at the time of installation,

According to that an unearthed lighting circuit which did comply when it was installed would not be a factual discrepancy.


Is your plan to ignore, or try to wriggle out of answering, those questions too?

 

[donrkebab]

Just answer the question.

Where and how would you "note the fact"?

OK, I would record the info in a permanent form, and that could vary from carving in stone to typing on a word processor.