Since the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 came into force on 1 June 2020, the IET technical helpline has been inundated with calls related to the Electrical Installation Condition Report (EICR). This previous IET Wiring Matters article provides further information. In this article, we are going to answer some of the most common questions received and dispel some of the myths associated with the EICR.
What is an EICR?
An EICR is an electrical installation condition report, on the condition of an electrical installation. The process involves a combination of inspection and testing to determine if the electrical installation is safe for continued use. and on completion, a report is issued.
An EICR is carried out Regulation 651.1 of BS 7671:2018+A1:2020 states that:
‘Where required, periodic inspection and testing of every electrical installation shall be carried out in accordance with Regulations 651.2 to 651.5 in order to determine, so far as is reasonably practicable, whether the installation is in a satisfactory condition for continued service.’
The EICR can be used to assist the duty holder in assessing the risk to determine the safety of the installation. The information in the report could be used to develop safety measures to mitigate the danger until remedial works can take place, such as isolation of an affected circuit.
Is an EICR retrospective?
We often get enquiries advising that an EICR has been carried out and the customer has been advised that their installation needs to comply with the latest edition of BS 7671, which is not the case.
The extract below is taken from the note by the HSE in BS 7671:2018+A1:2020:
‘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.’
Just because the installation does not fully comply with BS 7671:2018+A1:2020, does not necessarily mean it is unsafe, which will depend on the condition of the installation. The inspector must apply engineering judgment to determine if it is safe for continued use.
Who can carry out an EICR?
When commissioning an EICR, it is important to check that the person is competent to do so. It is recommended to use a registered competent person to carry out the inspection and testing. Further information can be found at the registered competent person scheme website.
A person carrying out an EICR is required to be competent. The term skilled person (electrically) is used in BS 7671:2018+A1:2020, defined as below:
‘Skilled person (electrically). Person who possesses, as appropriate to the nature of the electrical work to be undertaken, adequate education, training and practical skills, and who is able to perceive risks and avoid hazards that electricity can create.
NOTE 1: The term “(electrically)” is assumed to be present where the term 'skilled person' is used throughout BS 7671.
NOTE 2: Regulation 16 of the Electricity at Work Regulations 1989 requires persons to be competent to prevent danger and injury. The HSE publication HSR25 provides guidance on this.’
It is clear to see from the definition that someone carrying out EICRs is required to have adequate education, training, and experience to do so. An inspection and testing qualification place is a good place to start, but it is also necessary that the inspector has the necessary experience.
Common mistakes observed on EICRs
Section D – Extent and limitations of inspection and testing
The description of the extent of the installation covered by the report is arguably one of the most important sections to complete as it describes what is being inspected and tested.
In order to establish the extent of the inspection and testing, a conversation with the person ordering the report will be required. The person ordering the report will not usually have knowledge of exactly what they need so it is important to understand their requirements and make clear exactly what has and, just as importantly, what has not been tested and inspected and agree this in writing before the work begins.
In some cases, it may be necessary to agree limitations to the report. This should be clearly noted in the agreed limitations section. It could be that the inspection and testing does not cover products such as fixed equipment connected to the installation, it is important this is made clear on the report.
Despite the best intentions of the person ordering the report and the inspector, it can sometimes be the case that on the day of the inspection, circumstances dictate that further limitations are applied to the inspection and testing. If this is the case, this must be recorded in the operational limitations section. The person ordering the report must be made aware of the implications of the limitations, it could be that it affects the inspector’s ability to reach a conclusion to the report for certain aspects.
However, limitations should not be used as an excuse not to carry out the necessary inspection and testing. Statements such as, ‘no access to high-level equipment' are not acceptable and the person ordering the report must be made aware of any implications of not inspecting certain parts of the installation.
Section E - Summary of the condition of the installation
This section is the opportunity for the inspector to describe the condition of the installation in layperson terms to the person ordering the report. It is common to see statements such as ‘good’, or ‘needs new fuse box’ inserted in this section which is not useful. Some would argue that there is not sufficient space on the form to provide the information. However, the forms are only models and additional pages can be used and appended to the report.
Depending on the extent of the installation, it is difficult to see how the condition of an electrical installation can be adequately described using the space already provided on the forms.
On completion of the inspection and testing the inspector will provide an overall assessment of the installation in terms of its suitability for use, this will either be satisfactory or unsatisfactory depending on the classification codes which have been attributed to any observations recorded on the report.
If the inspector has noted any C1 or C2 conditions, it should result in an unsatisfactory outcome of the report.
In some cases, the inspector may not be able to reach a conclusion and further investigation will be required. In which case the observation will be attributed with F/I. The classification of further investigation should not be used to locate the problem, it should only be used where it is reasonably expected to reveal a dangerous or potentially dangerous situation.
If further investigation is required, the person ordering the report should be advised that a potential safety issue has been discovered but due to the limitations of the EICR, a conclusion could not be reached and the issue should be investigated as soon as possible.
Section F - Recommendations
Any observations identified during inspection and testing should be recorded on the report. The observation should be a factual description of the problem, and not as commonly seen a proposal for the remedial works to rectify the issue.
If remedial works are necessary, this should be detailed on a separate quotation. It would be of great benefit to the person ordering the report if the observations were individually quoted to allow the person ordering the report to be able to determine what was required to make the installation safe for continued use.
The inspector is also required to recommend a date for further inspection and testing to be carried out. These dates are often assumed or taken from Table 3.2 of IET Guidance Note 3 Inspection & Testing.
However, it is important to remember that Table 3.2 is titled ‘recommended initial frequencies of inspection of electrical installations.’ The first important word is ‘recommended’, it is exactly that, a recommendation and not a legal requirement. It is also important to note that this is for initial frequencies for new installations. It is worth noting that for domestic rented accommodation and houses in multiple occupation, the recommended maximum period between each inspection and test is five years or change of occupancy, which is often overlooked.
The interval between each inspection and test will require an engineering judgment to be made based on the knowledge and experience of the inspector. The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 states that an electrical test is required for a rented property at a maximum interval of five years, but this could be reduced by the inspector, but this would need to be justified.
If any observations are classified as ‘danger present’, the inspector should try and remove the danger where possible. The observation should be attributed with a C1 classification code and an electrical danger notification letter should be issued to the person ordering the report without delay. It would not be considered acceptable to provide the information on the report and issue it several days later. This is necessary to satisfy the Health & Safety at Work Act 1974 and the Electricity at Work Regulations 1989.
Attributing classification codes to observations
The best source of information available for guidance on attributing classification codes is Electrical Safety First Best Practice Guide 4, BPG 4 is an industry-wide agreed document, contributed to by many organisations including the IET.
Ultimately it is the inspector’s engineering judgment to attribute the correct classification code, BPG 4 is a useful guide to provide a starting point for making that judgment. It is difficult to see how an inspector could deviate from this guidance without providing adequate justification.
A consumer unit made from combustible materials needs replacing
If a consumer unit is made from combustible material (e.g. plastic), BPG 4 recommends that the presence of a plastic consumer unit is worthy of a note, but does NOT warrant a classification code. If the consumer unit is located under a wooden staircase or within a sole route of escape from the premises, a C3 classification code is recommended.
Either way, this would not result in an unsatisfactory outcome.
A bathroom light needs to be replaced as it is not IP65 rated
The IET’s On-Site Guide is a good source of information, minimum IP rating for a luminaire installed in zone 1 of a room containing a bath or shower is IPX4, protection against splashing water.
The minimum IP rating for electrical equipment installed in zone 1 of a location containing a bath or shower is IPX4.
A bathroom fan needs to be 12 V extra-low voltage
Again, the IET’s On-Site Guide is an excellent source of information, Table 8.1 states that ventilation equipment installed in zone 1 of a bathroom is permitted to be 230 V, providing it is RCD protected and meets the minimum IP rating of IPX4.
230 V low voltage rated bathroom fans are permitted in zone 1 of the bathroom.
All circuits must be RCD protected
RCD protection is required for all socket outlets, a C3 classification code is recommended in BPG 4 where the socket-outlet is unlikely to be used for portable equipment outdoors.
A C3 classification code is recommended in BPG 4 for the absence of RCD protection for cables buried in walls at a depth of less than 50 mm, without mechanical protection.
BS 7671:2018 introduced requirements for additional protection for AC final circuits supplying luminaires within domestic (household) premises. If this is observed to be absent, BPG 4 recommends that a C3 classification code is attributed.
C3 classification codes do not result in an unsatisfactory outcome.
However, absence of RCD protection for a socket-outlet likely to be used for portable equipment for use outdoors or for circuits in a location containing a bath or shower would warrant a C2 classification code, which would result in an unsatisfactory outcome.
Rewireable fuses are no longer acceptable
Rewireable or semi-enclosed fuses to BS 3036 as they are referred to in BS 7671:2018+A1:2020, are indeed still permitted providing the appropriate correction factor (0.725) is used when determining the size of the conductor. In fact, Table 533.1 identifies the sizes of tinned wire for use in semi-enclosed fuses.
However, a ‘fuse box’ is unlikely to contain sufficient provisions for RCD protection where necessary and depending on the deficiencies observed, it may be more cost-effective to replace for a modern consumer unit.
Some ‘fuse boxes’ may contain an asbestos pad which effectively served as a flash guard. In the event that a fuse wire needs to be replaced, it is likely to release asbestos fibres, which would not be considered acceptable. For information on replacing an asbestos-containing fuse box, see HSE a33 datasheet. IET Wiring Matters article asbestos guidance for electricians provides general information on asbestos likely to be encountered by electricians.
The installation does not contain a fire alarm or emergency lighting system
Inspection of fire alarm and emergency lighting systems do not generally form part of an EICR. However, power supplies and wiring of emergency lighting systems will be part of the fixed wiring installation and should be included.
Fire alarm and emergency lighting systems are required to be inspected in accordance with BS 5839 fire detection & alarm systems for buildings and BS 5266 Emergency lighting, code of practice for the emergency lighting of premises respectively.
Whilst deficiencies observed on fire alarm and emergency lighting systems during the inspection may be worthy of a general note, a classification code should not be attributed.
An EICR is a factual report on the condition of an electrical installation and suitability for continued use.
The inspection and testing of an installation must only be carried out by (electrically) skilled persons with sufficient knowledge and understanding of electrical installations.
BPG 4 is an excellent guide to classification codes for common observations in domestic installations.
The EICR must be compiled in such a way that the person ordering the report can understand it. The condition of the installation should be accurately described to allow the person ordering the report to make an informed decision on the repairs to be carried out, based on the risk to the users of the installation.