Part P Electrical Installation Certification

[JohnW2]

Also, for my LA, they list fees for regularisation - basically if you fail to notify in advance, then they charge an extra 50% and allow you to notify afterwards. If someone's failed to notify in advance,

Indeed - similar with my LA, and I suspect many/most others.

However, that relates to a different situation from what we are discussing here. As you say, these 'regularisation' procedures are to deal retrospective with a situation of prior 'failure to notify'. However, in the OP's case, there has not been any such failure, since the electric work was 'notified' (implicitly, if not explicitly) in his Buildings Regs application.

Kind Regards, John

 

[RickH]

We are perhaps losing sight of the fact that we are only talking about a garage.

It is an outside garage/car port ... all wiring is surface mount, as are the 4 sockets and 4 fluorescent lights & switches. (2 x 1w ccts)

 

[JohnW2]

It is an outside garage/car port ... all wiring is surface mount, as are the 4 sockets and 4 fluorescent lights & switches. (2 x 1w ccts)

That was my understanding and assumption, hence what I said about how easy it would be to 'undo the work' (simply disconnect the ends of the cables0 and then get an election to 're-do the work' (reconnect the few cables!) and then issue an EIC.

However, what you now tell us about the extent of this 'electrical installation' (which is roughly what I was guessing) indicates how very silly this whole 'fuss' (on the part of LABC) is!

Kind Regards,, John

 

[scousespark]

I can't believe this is still being discussed as Part P near 18 years old.

There is a clear process here. There is no major set of hurdles for a diyer to jump over. The homeowner notifies the LABC BEFORE starting the job. The LABC charges for notification and arranges for one of their inspectors to work with the installer and issue an EICR (which the LABC take in to trigger their issue of the Building Regs Compliance Certificate. The homeowner is charged a fee for the inspector's time. IF the installer is suitably qualified (i.e. has qualifications applicable to electrical installation - regs, tradecraft, inspection @ testing ) the Building Control Officer has the option to accept an EIC and waive the requirement for their EICR.

As the OP is not an electrician, has not been trained in electrical installation and doesn't have the required electrical qualifications the LABC will require an EICR from one of their contracted electrical inspectors. The fact the work has been done, just means the LABC is acting retrospectively. This should be following the regularisation process, so the inspection fee would be higher than it would have been if the correct procedure had been followed up front.

The BCO has never been required to be trained as an Electrical Inspector. There is not now, nor has there been, a route to gaining compliance where a person who is not qualified can do the job and turn up at the LABC with an EICR and the BCO just signs the job off.

The problem raised here is that there are a group of posters who have never liked the process and want things back as they were in 2004 when there was no requirement for electricians to have qualifications and diyers were not monitored.

 

[JohnW2]

"Local Authority Building Control
You should make a Building Regulations application to Building Control if the electrician you employ to carry out the works is not registered as a competent person under one of the relevant Competent Person Schemes for electrical installations or if you do the work yourself. You should contact your local authority building control department before you start the work. They will explain the requisite procedures to you. .... It is also best to discuss with Building Control how they wish to inspect and check the works you are carrying out."

I suppose that I have, to a fair extent, being playing Devil's Advocate since, although it may not be apparent, I actually agree with much of your viewpoint.

In the case of standalone (notifiable) electrical work, the situation (per the above) is very straightforward, and not open to much discussion or disagreement. The electrical work has to be notified. If a member of a CPS undertakes the work, he/she issues a Compliance Certificate and informs (aka 'notifies') the LA. In all other cases a Building Regs application has to be made and then, as you have said 'discussion' with the BCO will be necessary.

In fact, I would imagine that that discussion would usually be initiated by the BCO, since he/she had to determine (and inform the applicant) how much supervision and I&T will have to be arranged by the LA, depending upon their view of the person who is to do the work. At one extreme, they may not feel the need for any involvement at all (e..g. if it is a well-qualified and experienced electrician who happens to not have joined a CPS)but, at the other extreme (particularly with a DIYer), they may feel that considerable oversight and I&T on their part is appropriate. I see little scope for debate or argument about all that.

It's a bit different with work which forms part of a larger project (for which there has been a Building Regs application), since the electrical work does not then have to be separately notified - so, even if a CPS member undertakes the work, I don't think he/she would be expected to issue a Compliance Cert (because the LA would ultimately issue a Completion Cert, covering everything, including the electrics).

What we've been discussing is a situation in which work has been completed (by whoever) but, for whatever reason, an EIC cannot be provided - a situation in which an LA really have no sensible option other than to accept an EICR ('in lieu' of the EIC which they can't have), and the discussion has been about why they are only prepared to accept an EICR if they organise (and charge for) it.

You have presented what probably is the only way of trying to justify that position, namely that it means that they have 'control' over who undertakes the EICR (i.e. can utilise "selection processes" and "vetting". Whilst that is literally true, I am doubtful that this often happens in a manner that has significant relevance to the 'competence' of the person concerned, something which is consistent with my personal experiences ...

... in such situations (electrical work within a larger project) I have on many occasions seen an EIC accepted by an LA without question when the person who did the work and issued the EIC was not a CPS member (in some cases not even having any formal 'qualifications') and who had given no indication of their qualifications on the EIC (there is no provision in the standard EIC form for that). They obviously could have taken steps to 'investigate' the individual concerned but, in the cases I'm referring to, they don't seem to have done so.

In any event, returning to the specific, the OP has now confirmed that the situation is roughly what I suspected, namely that the 'electrical installation' we're talking about consists of all surface wiring, with 4 sockets and 4 fluorescent lights & switches. Do you really think it is 'reasonable' to ask for £322 to inspect and test that and/or that a person who was experienced in doing EICRs, but who had not been through an LA's "selection processes and vetting" would not be able to test that 'installation' competently?

Kind Regards, John

 

[JohnW2]

I can't believe this is still being discussed as Part P near 18 years old. ... The problem raised here is that there are a group of posters who have never liked the process and want things back as they were in 2004 when there was no requirement for electricians to have qualifications and diyers were not monitored.

If you count me as one of that "group of posters" you are wrong. In fact, long before 2004 I was expressing surprise, and some concern about the lack of regulation of electrical work in the UK, not the least because of some of the things I had seen done by self-styled 'electricians'. I therefore welcomed the appearance of Part P (or, rather, the notification requirements which came with it), albeit it was (in England) almost diluted out of existence in the 'relaxations' in 2013.

This current discussion all started because, in the specific context of the OP's particular situation, I felt that, in common-sense terms, his LA were being 'unreasonable'.

I had always assumed that we were talking about a very modest amount of work, and the OP has now confirmed that it consists to two circuits, serving 4 sockets and 4 fluorescent lights/switches, all with surface-mounted wiring. I remain of the view that it is 'unreasonable' to charge £322 for having that 'inspected and tested', and equally 'unreasonable' for the LA to take the view that a EICR relating to that very small 'installation' provided by an electrician who is presumably 'qualified' (and may even be a CPS member) is not acceptable.

Kind Regards, John

 

[EFLImpudence]

(which the LABC take in to trigger their issue of the Building Regs Compliance Certificate.

Just for accuracy - "Completion" Certificate,

 

[JohnW2]

Just for accuracy - "Completion" Certificate,

Indeed, as I (a non-electrician) wrote in my penultimate post

As I wrote in that post, one importance of that distinction is that, when electrics is part of a wider project, there is no need for the electrician to provide a Compliance Certificate (hence no need for him/her to be a member of a CPS) since the LABC's Completion Certificate encompasses everything, including the electrics.

Kind Regards, John

 

[JohnW2]

I've been drawn so much into complicated tangential discussions that I think my point about the OP's issue raised in this thread may have been lost in a forest of weeds, so I thought I would provide a very brief statement of my actual (on-topic) point:

I stated my opinion that the OP's LA were seemingly being 'unreasonable' in this particular case because of the following situation:

1... The OP installed a small amount of electrics in a garage which he is building (for which a Buildings Regs application was made). We now know that the work consisted of two circuits, one supplying four sockets and the other supplying four fluorescent lights and switches, all with surface-mounted wiring.

2... For whatever reason, an EIC is not available, so the LABC have no real choice but to accept an 'after-the-event' EICR, which they have agreed is an acceptable course.

3... An electrician, who I imagine is 'qualified', is probably experienced in undertaking EICRs and is possibly even a member of a CPS, undertook I&T on this 'new installation' and issued an EICR for it.

4... The LABC refused to accept that EICR, instead saying that they had to commission some other electrician to conduct another EICR inspection, for which they will charge the OP £322.

I do not find that particularly 'reasonable' - does everyone else?

Kind Regards, John

 

[flameport]

Applying logic to bureaucratic processes will never work.
LABC require one of their own contractors to do the EICR in this instance. That is what they have decided, and that is what they will accept.
The presence of an EICR from someone else changes nothing in their view, as that is not the proper procedure and therefore is entirely invalid, regardless of whether it's reasonable, sensible or anything else.

The OP has 2 choices.
Either pay LABC their fee and get the mostly irrelevant piece of paper.
Or pay them nothing and get nothing.

 

[JohnW2]

Applying logic to bureaucratic processes will never work. LABC require one of their own contractors to do the EICR in this instance. That is what they have decided, and that is what they will accept. The presence of an EICR from someone else changes nothing in their view, as that is not the proper procedure and therefore is entirely invalid, regardless of whether it's reasonable, sensible or anything else.

That may well be true, and I haven't really said anything to the contrary - I've merely said that I regard the situation as 'unreasonable', which I do.

The OP has 2 choices. .... Either pay LABC their fee and get the mostly irrelevant piece of paper. ... Or pay them nothing and get nothing.

Again, maybe - but I have to say that, if I were in the OP's position, I might be seriously considering the second of those options - and then see 'what happens'.

Kind Regards, John

 

[SimonH2]

I can't believe this is still being discussed as Part P near 18 years old.

And being pedantic, "Part P" has absolutely nothing, nada, zilch to do with the OPs problem. What we're talking about are the notification requirements that came into the Building Regs in 2005. I'm sure that had the two different things come out at different times we'd have less confusion about it - though I'm sure the charlatans who jumped on the "Part P" bandwagon would still have been sowing confusion to part unsuspecting punters from their money.

 

[JohnW2]

And being pedantic, "Part P" has absolutely nothing, nada, zilch to do with the OPs problem. What we're talking about are the notification requirements that came into the Building Regs in 2005. I'm sure that had the two different things come out at different times we'd have less confusion about it ...

Whilst I share your dislike of the way in which some people (particularly one of our 'regulars') constantly misuse the phrase "Part P" to refer to the notification requirements, I don't think one can actually separate the two concepts in the manner you suggest.

I don't think that "Part P" and the associated notification requirement (for electrical work) could really have "come out at different times". There could not have been any notification requirements (for electrical work) prior to the appearance of Part P, since there would have been nothing (electrical) to notify! The other way around, I suppose that, when Part P first appeared, they could initially not have made the corresponding changes to Schedule 3 and Schedule 4, but it would really have made little sense to add a 'part' to the Buildings Regs but without any provision for 'policing' it!

So, I think it would be more realistic to always talk about "Part P AND associated notification requirements", since the two things really come as a 'job lot'

Kind Regards, John

 

[scousespark]

This thread is just another rehash of the whining seen here since 2005. The BCO has applied the rues which apply to any notifiable job carried out by a person who is not on the Competent Person's Register. There are 2 fees. Notification - applies to all jobs. Inspection and Testing - the BCO has discretion to accept the Electrical Installation Certificate (if the INSTALLER is suitably qualified) or request an Electrical Installation Condition Report, carried out by an inspector contracted by the LABC (if the INSTALLER is NOT suitably qualified. In the Welsh Approved Document P, the rules are laid out in Section 1. I have copied some of the relevant points and pasted them belw.

1.9 Inspection and testing should be carried out to follow the procedures in Chapters 71 and 74 of BS 7671:2001, and a copy of the appropriate installation certificate should be supplied to the person ordering the work. The electrical installation certificate must be made out and signed only by someone “qualified” to do so. Where this is the case, a safety certificate should be issued for all but the simplest of like-for-like replacements.

1.10 “Qualified” in this context means having the appropriate qualifications, knowledge and experience to carry out the inspection and testing procedures and complete the relevant electrical installation certificate.

Certification of notifiable work

a. Where the installer is registered with a Part P competent person self-certification scheme (This section covers installers on the CPR)

1.18 Installers registered with a Part P competent person self-certification scheme are qualified to complete BS 7671 installation certificates and should do so in respect of every job they undertake. A copy of the certificate should always be given to the person ordering the electrical installation work.

1.19 Where Installers registered with Part P competent person self-certification scheme, a Building Regulations compliance certificate must be issued to the occupant either by the installer or the installer’s registration body within 30 days of the work being completed. The relevant building control body should also receive a copy of the information on the certificate within 30 days. 1.20 The Regulations call for the Building Regulations compliance certificate to be issued to the occupier. However, in the case of rented properties, the certificate may be sent to the person ordering the work with a copy sent also to the occupant.

b. Where the installer is not registered with a Part P competent person self-certification scheme but qualified to complete BS 7671 installation certificates (This section covers installers who have relevant qualifications, but who are not on the CPR)

1.21 Where notifiable electrical installer work is carried out by a person not registered with a Part P competent person self-certification the work should be notified to a building control body (the local authority or an approved inspector) before work starts. Where the work is necessary because of an emergency the building control body should be notified as soon as possible. The building control body becomes responsible for making sure the work is safe and complies with all relevant requirements of the Building Regulations.

1.22 Where installers are qualified to carry out inspection and testing and completing the appropriate BS 7671 installation certificate, they should do so. A copy of the certificate should then be given to the building control body. The building control body will take this certificate into account in deciding what further action (if any) needs to be taken to make sure that the work is safe and complies fully with all relevant requirements. Building control bodies may ask for evidence that installers are qualified in this case.

1.23 Where the building control body decides that the work is safe and meets all building regulation requirements it will issue a building regulation completion certificate (the local authority) on request or a final certificate (an approved inspector).

The above sections apply to jobs being carried out by installers whoa are "qualified" as per section 1.10.
The following appliers to installers who are not qualified.

c. Where installers are not qualified to complete BS 7671 completion certificates

1.24 Where such installers (who may be contractors or DIYers) carry out notifiable electrical work, the building control body must be notified before the work starts. Where the work is necessary because of an emergency the building control body should be notified as soon as possible. The building control body then becomes responsible for making sure that the work is safe and complies with all relevant requirements in the Building Regulations.

1.25 The amount of inspection and testing needed is for the building control body to decide, based on the nature and extent of the electrical work. For relatively simple notifiable jobs, such as adding a socket-outlet to a kitchen circuit, the inspection and testing requirements will be minimal. For a house re-wire, a full set of inspections and tests may need to be carried out.

1.26 The building control body may choose to carry out the inspection and testing itself, or to contract out some or all of the work to a specialist body to carry out the work on its behalf. Where the building control body is a local authority it cannot require the building owner to undertake this work. However, under the Building (Local Authority Charges) Regulations 2010, the authority may charge a higher building control charge when first notified the work or levy a supplementary charge later, based on the recovery of its costs.

1.27 A building control body will not issue a BS 7671 installation certificate (as these can be issued only by those carrying out the work), but only a Building Regulations completion certificate (the local authority) or a final certificate (an approved inspector).

Third party certification
1.28 Unregistered installers should not themselves arrange for a third party to carry out final inspection and testing. The third party – not having supervised the work from the outset – would not be in a position to verify that the installation work complied fully with BS 7671:2001 requirements. An electrical installation certificate can be issued only by the installer responsible for the installation work.
1.29 A third party could only sign a BS 7671:2001 Periodic Inspection Report or similar. The Report would indicate that electrical safety tests had been carried out on the installation which met BS 7671:2001 criteria, but it could not verify that the installation complied fully with BS 7671:2001 requirements – for example with regard to routing of hidden cables.

The OP falls into the 3rd group, and the BCO has followed the rules and requested an EICR by their contracted inspector. The OP has installed a new circuit and the fee to get this inspected/tested is set by the LABC. The OP has a choice (as stated throughout this thread)
1 - pay up and get the job completed
or
2 - don't pay up not and leave the job incomplete

 

[JohnW2]

This thread is just another rehash of the whining seen here since 2005.

As I have said, that certainly in not true of me, nor of my contribution to this thread.

As I said, I welcomed the notification requirements which appeared when Part P was introduced in 2005 and regretted their serious dilution (in England) in 2013, but I didn't (and still don't) think that the degree of regulation (even pre-2013) went anything like far enough

Were it not for the complication introduced by the fact that houses change hands, I would probably suggest that householders should be allowed to do whatever they like to the electrical installations within their homes without any 'regulation'

However, my personal view is very different in relation those who undertake paid electrical work for customers. In relation to a spectrum of work at least as wide as that which became notifiable in 2005, I believe that people should only be able to undertake such work ('for reward') if they are in some way registered/licensed so to do, and that registration/licensing should be regularly reviewed and the work undertaken adequately audited/'policed' - so that the 'licenses' could be revoked whenever appropriate.

The rest of what you go on to write seems to be essentially about bureaucratic 'box ticking' and does not alter my view of the OP's situation. To summarise my personal view about the actual topic under discussion (rather than about perceived 'anti-regulation' lobbies):

We are talking about new work relating to the installation of two sockets and four lights/switches. An EICR of that work has been undertaken, I assume by someone 'qualified', probably experienced at undertaking EICRs and quite possibly a CPS member. The LA have refused to accept that EICR and, instead, want £322 to have it repeated by someone else.
The LA's position is probably totally correct in terms of the rules and the boxes they want to tick, but that does not make me feel that it is 'reasonable'

That is, of course, nothing other than a personal view.

Kind Regards, John