Personally, I would urge her to have a fan fitted.
- Fans greatly reduce condensation, dampness & smells throughout the house
- That means bedding, curtains, wallpaper, general health too if elderly
- Additionally kitchen fabric can last longer re condensation, cleaning
CWI & DG exascerbate the problem of limited ventilation.
- CWI often reduces ventilation to a house as vents are not always sleeved
- DG directly reduces ventilation hence the need for many trickle vents
However the law is clear.
- BR AD "F" uses the word "Shall" which is Guidance and not "Must" which is Requirement
- BR are not retrospective, but apply under changes subject to BR
If the ORIGINAL work was classed as refurbishment...
- Client should have been advised of BR AD "F" guidance re fan
- Client should have been advised if existing ventilation sufficient *1
*1 Very often existing ventilation is NOT sufficient.
Realise BR reducing thermal losses ALSO require BR regs to *re-instate* ventilation
Realise BR must consider this with regard to New Build rather than limited refurbs.
Trickle vents are just that - not substitute for extractor fans.
Too many DG were installed over the decades without trickle vents, fixed trickle vents are equivalent in CSA to an old wood window without draught excluder.
Thus NICEIC/whoever...
- Can advise on the omission of a fan, quote to fit one
- Can not state the law *requires it* to obtain the contract
- Can not fit one in her absence and later charge *2
*2 That would be a criminal offence under the Unsolicited Goods & Services Act.
Existing "replace a few cables" work does not constitute refurbishment.
Bottomline is the decision is up to her.
Roll on the shadow gov't who are set to radically change BR and I hope a lot of the red tape forced on small business, their report is due later this year IIRC.
As for "whoever" making up regulations...
1. Regulations are not prescriptive, they are subject to interpretation
Some bodies like prescriptive - as do clients, it reduces labour rates
IET want to avoid prescriptive - keep skills up, increasing labour rates.
What one person does, another may not just do differently, but fail.
This can get expensive for client and irritating when it "flip-flops".
However it is subject to a test of "Reasonableness" - and BS7671 regs
2. Regulation interpretation can be to client or contractor financial benefit
I recall a recent IET post where 30Mohm IR on one cable was suggested (by some, not all) as grounds to rip the kitchen apart.
Nothing in BS7671 would support it, the figure is one data-point if no previous PIR exists on which to project a trend.
A more experienced spark may check for condensation in the backbox in a moisture laden kitchen (hence BR AD "F"!), because once conductors & backbox drop below the dew point condensation will occur, tracking during IR test.
Ripping an old kitchen apart turns the bill into replacement AND refurbishment under BCO control requiring extensive changes (32mm+ insulation on solid walls etc).
3. Best Practice is subject to miss-use to apply to the large, not the miniscule.
NICEIC are often quoted as stating "no junction boxes are allowed anywhere" when BS7671 permits them as long as accessible, such as not under a laminate floor. NICEIC argue they are not under "Best Practice" despite BS7671 explicitly stating accessible is permitted.
Where T/S got involved is where changing a light fitting on a loop-in light f.c. became rewire of lighting for sole reason of "junction boxes not permitted", EFLI, IR, Visual, CCC re not enclosed in insulation etc all ok.
NICEIC inspectors DO kick people who do unnecessary work, but some have also initiated it (see 4.).
4. Best Practice at local level.
i) NICEIC NAPIT in my area will not fit 2C SWA on a domestic.
- It must be 3C, some will not do a job without ripping 2C out
- Argument is PIR are too far apart, EFLI can drift out of spec if cable/gland damage
BS7671 permits steel armour as CPC subject to CSA sizing, which for most domestic cables is ok.
ii) Some will not permit booster 6491X CPC alongside SWA in domestic.
- This might stick now because of 17th 526-06-06 the CSA needs to be sized to be CPC
- I can see a future amendment somewhere re adiabatic calculations (red goes green)
Argument in the past was penetration of armour CPC did not also penetrate the 6491X CPC.
iii) HiTuff by Draka is not permitted for fixed wiring.
- Manweb used to go ape at seeing flex anywhere on an install & will disconnect
- BS7671 does not preclude use of flex BUT 17th require appropriate terminals or (say) bootlace ferrules
Conversely in the south Hituff is popular re black & UV proof for lighting.
iv) SWA can not be screwed into steel conduit box as no lockring (backnut) capability
- BS EN gland not used as intended, no locknut to prevent the earthed gland loosening & impacting EFLI
- Debateable tho commonly done, better protection than BS8436 (or FP200G) with plastic glands
That is where "making up regulations" comes from.
I could go on all day, but usually it is ignorance rather than "rogue trader" - just ask for BS7671 reg & BR *wording*. A spark has his own standards of safety, but can not pass them off as law (unless he wants to join the IET committee along with the other corp, I mean, conscientious members).
The 17th is going to create bigger jobs out of small jobs and the public may fight back.
Will be interesting to see what the shadow gov't proposals re BR are.
My opinion?
Fit an extractor if it is obviously going to be beneficial - and 99.9% of time it is.
Quality is not cheap, Xpelair use decent motors/bearings, china knock offs can sound awful after 2-3yrs. You will be glad to know that like-for-like replacement is permitted under Part P though