EICRs - Coding, and the link to the Electricity at Work Regulations 1989 webinar

Here you can find the answers to the questions we had submitted during the above webinar on 8 December 2020.

If you missed the webinar, you can still view it on demand.

This webinar was arranged by the IET's Electrician EngTech programme in association with Wiring Matters. Electrician EngTech helps electricians gain recognition of their professional competence.

Find out more about Electrician EngTech.

Your questions answered

I find that there are always disagreements about category levels - there are plenty of arguments it on your forums. How can we get this more standardised?

Every electrical installation is different and it's not easy to have a "one size fits all" approach to the allocation of codes.

The nearest the industry has got is Electrical Safety First's Best Practice Guide 4. The IET is a partner, which offers suggestions on scenarios and example codes.

The REGs are supposed to be not retrospective. Cables to socket outlets light switches etc buried in a wall without RCD protection are what code. Some say C3, which goes with not retrospective, some say C2 which would mean the regs are retrospective. Which is right? This goes for surge protection AFDDs etc. Always assuming that the rest of the installation is satisfactory! According to the EAWR, the installation is constructed, installed, etc correctly at the time of construction.

The Note from the HSE on page 13 of BS 7671:2018 states "Existing installations may have been designed and installed to conform to the standards set by earlier editions of BS 7671 or the IEE Wiring Regulations. This does not mean that they will fail to achieve conformity with the relevant parts of the Electricity at Work Regulations 1989."

Generally, The IET would advise that cables buried in walls at a depth of less than 50 mm without RCD protection would be C3.

Cables to socket outlets light switches etc buried in a wall without RCD protection are what code. C3.
Currently, BS 7671:2018 states that the installation of AFDDs is "recommended" in some situations, therefore, where AFDDs are not present the allocation of a code is not necessary.

Does having C&G 2392 cover you for carrying out EICR?

No, not in itself. C&G 2392 is entitled "INSPECTION AND TESTING COURSE (INITIAL DOMESTIC)". It is not intended to equip persons to undertake EICR.

Note that other examining bodies exist and have equivalent courses.

You state that rentals require testing at the end of tenancy however the recent landlord regulations do not support this nor do they state what standard the testing has to comply to. Will this be changed and supported by the IET?

In England, for example, the legislation - The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020, does not require inspection and testing between tenancies but IET guidance recommends that it happens.

Provision 11 of the Landlord and Tenant Act 1985 requires that (in the lease) "to keep in repair and proper working order the installations in the dwelling-house for the supply of water, gas and electricity and for sanitation (including basins, sinks, baths and sanitary conveniences, but not other fixtures, fittings and appliances for making use of the supply of water, gas or electricity)".

Consider a house that, has been damaged by the previous occupant, is subsequently rented to a new occupant. If the installation has not been inspected how could the landlord be sure that it is safe for use? Hence, IET advises an inspection and test at the change of occupancy.

In a domestic dwelling that is being rented, Guidance Note 3 clearly states that the maximum period between inspection and testing should be Change of Occupancy/5 years. However, in Scotland, the government has decided to only have a visual inspection after a change of tenancy. What should be followed - Scottish Government or BS 7671?

Guidance Note 3 is IET Guidance; BS 7671 does include requirements for frequency of testing of electrical installations.

How should EICR remedial works be recorded?

An Electrical Installation Certificate would be issued for works, such as the replacement of a consumer unit.

A Minor Electrical Works Installation Certificate could be used to record the replacement of accessories.

Why C3 for a perfectly sound thermoplastic CU as it was compliant with the regulations applicable at the date of installation? Surely more an 'Observation' to advise the householder etc how things have moved on?

The IET generally advises that C3 should be recorded where a consumer unit is present with a combustible enclosure - however - where the consumer unit is present with a combustible enclosure and is located under a wooden staircase which is not finished with plasterboard on the underside, for example, a C2 should be recorded.

We have an ongoing discussion about socket outlets installed under previous versions of the regs that have the potential to be used outside i.e. Ground floor outlets. I have reports ranging from C1-3. Is there a rule for this?

The IET generally advises that a C2 would be applicable in this case.

Under EAWR 1989 is 'employer' the contractor and/or client i.e. public authority ordering the work?

The 'employer' is the entity that employs a worker and asks that worker to undertake a particular task. For example, an electrical contractor could be the employer and the employee is the person carrying out the inspection and test who is paid by the electrical contractor.

Not all replacement LED lighting fixtures are provided with an earth core within their supply cable, therefore should the ceiling grid be earthed to eliminate high touch voltages?

Where a luminaire is declared as Class II by the manufacturer, there would be no requirement to connect it to the means of earthing. The metallic ceiling grid is not an exposed-conductive part and would not need to be earthed, it is not an electrical appliance in its own right.

If there is a concern that the metallic ceiling grid could become live in the event of a fault on the Class II luminaire's cable then the installation method needs to be redesigned to suit the external influences.

When fault finding it is not always possible to have the supply isolated. It is a different scenario when you know the fault is?

In the case of testing live conductors, for example, measures such as proper training, correct tools for the circumstances, use of GS 38 compliant test equipment, control of the area, etc., would need to be put in place.

Adequate working space and means of access are open to interpretation. Can we have an exact definition of what is adequate?

EWR 1989 is 'goal setting' and the purpose of the word 'adequate' is to ensure sufficient means are provided to enable the work to be carried out in situations that may give rise to danger.

Check out HSG150 [PDF].

Can someone be considered as a competent person to carry out an electrical installation condition report after completing level 2 City and guide 2392-52?

No, not in itself. C&G 2392 is entitled "INSPECTION AND TESTING COURSE (INITIAL DOMESTIC)". It is not intended to equip persons to undertake EICR.

Note that other examining bodies exist and have equivalent courses.

In a lighting circuit, the CPC is found to be discontinuous and ceiling roses have very strained conductors - R1%2BR2 and Zs testing is not possible. In terms of coding is this a C2 or C3?

I think you're highlighting a situation where parts of the circuit have gone open-circuit and other parts are suffering from mechanical strain - definitely not C3. Therefore, if danger is present - C1. If the circuit is potentially dangerous - C2.
Either way, it's an unsatisfactory outcome.

A competent person is stated to only require technical knowledge or experience - it doesn't state any qualifications are required. Should that not be improved and clarified?

EWR 1989 doesn't require particular qualifications. The industry has got together to agree on the levels of academic achievement and experience, for example, to set the benchmark.

Check out the Electrotechnical Assessment Specification (EAS).

What paperwork is supposed to be used to document the revised condition when remedial works have ben completed?

An Electrical Installation Certificate would be issued for works, such as the replacement of a consumer unit.

A Minor Electrical Works Installation Certificate could be used to record the replacement of accessories.

As a landlord and 2391 holder can I legally carry out my own EICR?

EWR 1989 requires that you are competent, in itself, the C&G 2391 (note that other examining bodies exist and have equivalent courses) is not a statement of competency.

Noted the EICR is not a certificate but a report based on the tests and observations made. How about the Initial Verification Tests which are carried out at the completion of a new installation? Would that be considered a certificate of the new electrical installation?

Usually, the initial verification test results would be added to the Electrical Installation Certificate and given to the client at the time of handover.

Spotlights that are not fire rated would these be classed as a c2?

Assuming the luminaires are recessed into the ceiling. Fire-rated luminaires are required where the ceiling, in which they have been installed, is deemed to be a fire barrier. C2 would seem reasonable given that non-fire-rated luminaires have been recessed into a ceiling deemed to be a fire barrier.

Is a new EICR really required every time there is a change of tenancy in a rented property - it seems excessive, especially if the tenant changes annually.

Consider a house that, has been damaged by the previous occupant, is subsequently rented to a new occupant. If the installation has not been inspected how could the landlord be sure that it is safe for use? Hence, the IET advises an inspection and test at the change of occupancy.

If on an EICR Inspection, an integral RCD socket outlet is discovered but protected by a single-pole CPD what code should that be given, especially if it tests OK with the usual RCD time and current tests?

The RCD is providing additional protection which is intended to stop the flow of current to save a life - it can do this by breaking one pole only. By CPD I assume you mean OCPD (overcurrent protective device), e.g. fuse or circuit-breaker. The breaking of all poles, in some cases, is necessary for isolation; isolation may be provided upstream, for example, such as the main switch on a consumer unit.

Would the coding on the C1 not depend on the accessibility or access to reach the fitting?

Yes, it could. BS 7671:2018+A1:2020 permits systems that have bare live conductors which are out of reach. However, if the evident problem is not as originally intended by the designer it would be a non-compliance, if not C1 it would be C2, either way unsatisfactory.

Wouldn't the height of light fitting place it out of reach so would be a C2?

On an EICR would you consider some of the regulations from BS7671 18th Edition as non-retrospective (requiring improvements), even though the installation was constructed to a previous edition?

Possibly but no example given to enable discussion.

In an EICR - is it good practice to mention a Group RCD as a separate line item in the description of Circuits?

This could be your way of working, as long as the information is clear I could see no issue.

Working on controls, you need to find where the breakdown has occurred. Hence the live working.

EWR 1989 takes the stance that you should always aim to not work on live conductors. Where this cannot be achieved suitable precautions (including where necessary the provision of suitable
protective equipment) are taken to prevent injury. In the case of testing live conductors, for example, measures such as proper training, correct tools for the circumstances, use of GS 38 compliant test equipment, control of the area, etc., would need to be put in place.

Would not having fire rated recessed downlights be a C2 code?

Fire-rated luminaires are required where the ceiling, in which they have been installed, is deemed to be a fire barrier. C2 would seem reasonable given that non-fire-rated luminaires have been recessed into a ceiling deemed to be a fire barrier.

If the cons unit is now metal why can we use PVC trunking around them and not metal?

Looking at Regulation 421.1.201, it refers to the enclosure of switchgear (shall have their enclosure manufactured from non-combustible material). The intention is to keep all arcing, etc., within the enclosure. The biggest problem I can see is where a large hole has been cut in the metal enclosure and the trunking is used to meet IP requirements (in addition to allowing safe entry for the cables). In this case, the enclosure is not entirely non-combustible.

Do you need to have taken the BS 7671 18th Edition to carry out an EICR? I have not but I have taken the C&G 2391 & C&G 2400. I am qualified for BS 7671 - 17th Edition. I did EICR 5 years ago and was registered with NAPIT. What do local authorities require?

To answer your question, you would need to contact the relevant local authority.

When undertaking an EICR how much dismantling of local switches for fixed equipment e.g room heaters should be undertaken when there is a significant number?

When testing an existing installation it is important to be aware of the equipment that is connected as it can influence test measurements and could also be damaged by high testing voltages. The extent of the inspection would need to be agreed upon with the client.

I have a rewire-able fuse with all its correct fuse ratings. Does that mean a C1 code is required?

Certainly not. See Table 41.2, item (c) and Table 533.1 of BS 7671:2018, where fuses to BS 3036 are cited. Semi-enclosed fuses to BS 3036 are permitted by BS 7671, they are very good and economically very cheap.

In a commercial building, and where results from a previous ECIR are available, what level of sampling is acceptable for the next ECIR?

To be agreed with the client.

Risk Assessment must show that you have considered the equipment to be in fault, as defense may have been defeated due to the fault. E.g. testing a live good circuit, IP2X relied on etc. Fault finding in the same panel, will the barriers be removed etc... accompanying person is required, means of emergency isolation etc.

Noted

Is arc flash PPE required if changing a cons unit?

The changing of a consumer unit would be undertaken when the electrical supply had been isolated, hence, no risk of arc flash.

Is the EICR a fault-finding exercise?

No. The EICR (Electrical Installation Condition Report) reports on the condition of an electrical installation and states one of two outcomes:

Satisfactory
Unsatisfactory

Where an unsatisfactory result is recorded it will be supported by observations with C1 or C2 identified non-compliance with BS 7671.

I believe the HSE deem live testing as live working and suitable precautions would be required as per regulation 14...?

Agreed

During fault-finding Dead testing is always preferred first before any Live testing is undertaken - this avoids LIVE working - do you agree?

How is phase rotation measured if, as some candidates insinuate, live testing is not permitted?

Again, with respect to OK on past regulations, split boards have been installed with an RCD trip causing an unsafe condition and RCD/RCBO regs have moved on. Surely a C3 can be similar to an 'advisory' on a car MOT and needs a more suitable wording?

Agreed, C3 is a recommendation to improve the installation but is not safety dependent.

Is it acceptable to pull the service fuse if the tails look like they will cause a fire?

The cutout fuse is the property of the electrical supplier and does not belong to the owner of the electrical installation. It is currently not permissible for persons to cut the seal and remove the cutout. Arrangements must be made with the supplier of electricity.

Where can we get a copy of Best Practice 4?

On the Electrical Safety First website.

Regarding the supply protective device - a 1361 type 11b fuse on a certificate and cant prove it is would you put a limit on the certificate?

Yes. Then make reference in Section D - Extent and Limitations of Inspection and Testing of the EICR.

When I worked for a manufacturing company an HSE inspector visited and found electrical panels were found to have been left open danger of electric shock. The company was issued with an improvement notice and threatened with prosecution and warned no live working should be done under any circumstances.