EICR - tester exceeding remit and the regs?

[JohnW2]

Considering the Grenfell Tower fire it seems they don't have enough clout, Ronan Point lessons were also slow to be learnt ...

That may or may not be true, but they managed to change BS7671 as regards domestic CUs, despite the fact that I find it hard to believe that at least some members of JPEL/64 didn't question the 'need'.

Even with Part P it says one way to comply would be to follow BS 7671 ....

'Part P' doesn't say that, but Approved Document P (which is not law) does.

... but one could follow any of the EU regs and it would still comply, so if you had a German firm you could wire up houses to German standards so their key personal could bring their stuff from home, this has been done with house for US forces.

Perhaps, but not necessarily. To demonstrate compliance with the law (Part P) one would probably have to convince a Court that following some other regulations had not resulted in an installation which was 'less safe' than if it complied with Part P - and I'm far from convinced that that would necessarily be easy in relation to some aspects of what it compliant with, say, German regulations.

Kind Regards, John

 

[ericmark]

Ah - but that's just in the eyes of NICEIC, NAPIT or whichever trade organisation it was. As you and I have pointed out, the actual regulation makes absolutely no distinction between domestic CUs in different locations - they all are ('equally') required to be 'non-combustible', no matter where they are (including when they are not under the stairs).

Kind Regards, John

You are correct, I remember the questions when it came out about when fitted in a garage which is designed to be reasonably fire resistance so even if it did go on fire it was in essence in a fire resistance box, but it was claimed because the box could contain other items it was not good enough.

As yet it seems 'non-combustible' has not been defined, I know the aluminium of a caravan will burn, in fact there is very little which will not burn, the normal is to say it must resist a set fire for so long, but that does not seem to be the case. So I have a metal consumer unit inside a wooden box under a roof made from many materials, and I have not a clue if it will burn or not, likely it will not as originally a garage, but it is still an unknown.

 

[ericmark]

I would say since leaving the EU that is no longer the case, but as yet we don't know.

 

[JohnW2]

You are correct, I remember the questions when it came out about when fitted in a garage which is designed to be reasonably fire resistance so even if it did go on fire it was in essence in a fire resistance box, but it was claimed because the box could contain other items it was not good enough.

One of the many silly things about the regulation is that there is no requirement for fire containment. As I say so often, provided only that what material was left (between the holes) was 'no-combustible', one could have many holes in the case of a CU as one wanted within the constraints (less than 12mm diameter for front, sides and bottom) necessary to achieve the required IP rating!

As yet it seems 'non-combustible' has not been defined ...

Indeed - and, apart from the whole concept of the reg, that is probably the silliest of all aspects of the reg.

As for 'the concept', as I've also said, if it were discovered that a certain electrical or electronic appliance (TV, microwave, mobile phone or whatever) was prone to 'bursting into flames', the cause of that would be rectified - rather than allowing the items to carry on being used but requiring them to be kept in 'non-combustible enclosures'!!

Kind Regards, John

 

[EFLImpudence]

Ah - but that's just in the eyes of NICEIC, NAPIT or whichever trade organisation it was.

Yes, I know.

As you and I have pointed out, the actual regulation makes absolutely no distinction between domestic CUs in different locations - they all are ('equally') required to be 'non-combustible', no matter where they are (including when they are not under the stairs).

I know but the trouble is that if plastic CUs under the stairs are given a C2, then, in effect, the landlord will be compelled to have it replaced.

That's how these things start.

 

[JohnW2]

I know but the trouble is that if plastic CUs under the stairs are given a C2, then, in effect, the landlord will be compelled to have it replaced.

Indeed - which given the ranging of opinions that exists, even here, that's why I think it so unsatisfactory that this decision is at the mercy of the views/judgement/discretion of whoever undertakes the EICR.

If, as it quite possible, this starts becoming the big (and well-publicised) issue, then I suspect (hope!) that a good few landlords, especially 'big' ones, may, if they have plastic CUs under stairs (etc.), start asking electricians what code they would give it before commissioning an EICR from them - and, if that happens to a significant extent, it might just change the ideas of some of the electricians.

Kind Regards, John

 

[JohnW2]

I would say since leaving the EU that is no longer the case, but as yet we don't know.

Is that a reference to your comments about German regulations?

I'm not sure where this idea came from that one can use compliance with other countries' regulations to demonstrate compliance with Part P. Even Approved Document P doesn't say that. Throughout, that document says that installations should comply with BS7671, but it also says (which I presume is what gives rise to the sort of comments you made):

... but nothing I can find about compliance with other countries' regulations necessarily being a way of complying with Part P. Am I missing something?

Kind Regards, John

 

[EFLImpudence]

511.

 

[JohnW2]

511.

Indeed, but as I recently wrote to eric ...

Perhaps, but not necessarily. To demonstrate compliance with the law (Part P) one would probably have to convince a Court that following some other regulations had not resulted in an installation which was 'less safe' than if it complied with Part P - and I'm far from convinced that that would necessarily be easy in relation to some aspects of what it compliant with, say, German regulations.

... and that seems to be precisely what 511.1 is saying when it says ...

... Alternatively, if equipment complying with a foreign national standard based on an IEC Standard is to be used, the
designer or other person responsible for specifying the installation shall verify that any differences between that standard and the corresponding British or Harmonized Standard will not result in a lesser degree of safety than that afforded by compliance with the British or Harmonized Standard ...

... which, by my reckoning, means that BS7671 is the 'minimum acceptable standard' (in which case it would seem that nothing would be gained by working to some other country's regulations, since one would have to satisfy B7671 requirements 'or greater').

I would add that 511 only relates only to 'items of equipment'. Whilst it would therefore indeed apply in the case of CUs (non-combustible or otherwise), it presumably would not relate to 'wiring practices', which is what quite a lot of BS7671 is about?

Kind Regards, John

 

[plugwash]

If, as it quite possible, this starts becoming the big (and well-publicised) issue, then I suspect (hope!) that a good few landlords, especially 'big' ones, may, if they have plastic CUs under stairs (etc.), start asking electricians what code they would give it before commissioning an EICR from them - and, if that happens to a significant extent, it might just change the ideas of some of the electricians.

I suspect things may go somewhat further than that in terms of landlords "shopping around for the most lenient inspector they can find".

 

[JohnW2]

I suspect things may go somewhat further than that in terms of landlords "shopping around for the most lenient inspector they can find".

That's what I'm suggesting - but in the specific context of what we've recently been discussing, the landlord would have to have some understanding of the CU business to know what question(s) to ask (in order to determine 'leniency').

Of course, although we've been discussing this in relation to landlords and the new legislation, it could have much wider implications for EICRs in general (e.g. when undertaken in relation to house purchase, or just 'routinely') - if some electricians start giving C2s to, for example, plastic CUs under stairs, there are suddenly going to be an awful lot of 'unsatisfactory' EICRs out there!

I wonder if consumer groups and the media might get interested in this at some point, if large numbers of people start being told that "urgent remedial action is required" because the (possibly less than 5 years old) plastic CU under their stairs is "potentially dangerous"?

Kind Regards, John

 

[oldbutnotdead]

And I wonder how many landlords will look at their existing plastic CU and think to themselves 'hmm. I can buy a tin one from Screwfix for £100, chuck it in and then get the EICR done. The testing will pick up any cockups I make, won't it?'

 

[davelx]

If the plastic CU is recent enough that the same devices are used in the maker's steel CUs, then the cheapest option might be to buy an empty (ie DP isolator only) CU of the same make & size and just swap the guts from the plastic CU.

That would certainly be possible with my plastic Eaton CU installed a few years ago.

 

[JohnW2]

And I wonder how many landlords will look at their existing plastic CU and think to themselves 'hmm. I can buy a tin one from Screwfix for £100, chuck it in and then get the EICR done. The testing will pick up any cockups I make, won't it?'

Who knows?! ... but, as I recently wrote, if the issue 'spreads' it won't only be landlords who are affected - if electricians start coding plastic CUs under stairs (and maybe other locations) as C2, then house owners (or prospective owners) commissioning EICRs (e.g in relation to house purchase) will find themselves being told that "urgent remedial action is required" (because of a "potential danger"), even if it is pretty new and 'fine' (other than being plastic).

Kind Regards, John

 

[R Benny Waered]

And I wonder how many landlords will look at their existing plastic CU and think to themselves 'hmm. I can buy a tin one from Screwfix for £100, chuck it in and then get the EICR done. The testing will pick up any cockups I make, won't it?'

I was quoted £450 for this non requirement to be 'rectified'! If it was £100 then we wouldn't be wasting so much breath i guess.