With BS7671 18th Edition amendment 2 hurtling forth like chunky projectile vomit from the drunk bloke sat immediately behind us on a bus, and with it being about as warm, welcome and, somewhat oddly, the same shade of mushroom brown, I take a look at one particular bugbear of the wiring regs and what I intend to do about it going forward regardless of what those clowns busy juggling their balls in the IET circus tent send my way when they shiftily lift a hard earned hundred quid and an (out of date) rubber johnny from my wallet for the all-new brown book at the end of March!
So, here I'm wittering on about the humble test and inspection notice as defined in Regulation 514.12.1. I'm going to cover what I don't like about the thing, how I wish to see it changed and my all new one-label-to-rule-them-all solution!
I guess then, we'd better start with what regulation 514.12.1 actually says...
How can such a plain notice be so offensive to one's eyeholes you may well ask? Well, its simplicity is its downfall, and the limitations of this label was something I lamented in my feedback to the IET when the draft for public comment was open on amendment 2 at the end of 2020.
While appearing to be straightforward and innocent enough, despite being written in IET English which is a tortured form of the everyday language the unwashed and increasingly dumbed-down masses can relate to, it's clear that your electrical installation ought to be periodically inspected and tested, and those date fields allow it to be shown when that last occurred and when it should next be undertaken...
..or does it. Does it really? Does this notice actually indicate anything of use to anyone at all? Imagine we've just turned up to a site we've not been to before and find a shoddily installed grotty birds-nest of a consumer unit or distribution board with this notice and a couple of dates scrawled upon it. Let's assume there are no other identifiers or any paperwork for whomever has worked on this installation previously which is common enough. The presence of this notice indicates one of five things:
1. It applies to a change of consumer unit or DB or an additional one having been added.
2. It applies to a full or partial rewire of the property.
3. It applies to one or more new circuits only and not any wider work.
4. It applies to an inspection and testing having been undertaken and not any physical installation work at all, or...
5. ...some idiot simply found it on the label sheet that came with the consumer unit and they slapped it on without filling out the date fields.
Already we're in the dark as to what this damnable notice is supposedly telling us about this installation in the absence of any accompanying certificate or report that shares the date some asshole has scrawled upon it. We could go hunting for that information, if there was anything in this regulation requiring the person completing the notice to identify who they or their organisation are, but there isn't... so fuck knows who was wielding the pen when the date fields were completed, if they were filled out at all.
An average sticker sheet yesterday. The basic inspection and testing notice is highlighted.
As this notice comes in sticker form with any new consumer unit, how do I even know it relates to any professional installation or reporting work at all? This installation could be a DIY effort, there having been no professional inspection and testing performed in any way, shape or form.
Indeed, Joe Homebase or Jock Punchclock could have picked up a replacement consumer unit from Screwfix and bolted it to the wall without using any specialist equipment to check the adequacy of earth fault loop paths, insulation resistance, ring continuity, suppliers earthing, adequacy of protective devices & bonding arrangements or anything else! Nonetheless, the bugger's fished the sticker out of the box, scribbled today's date on it, then arbitrarily scrawled on a future date perhaps a whole decade away because he's that sure he’s aced the workmanship. After all, electrics is piss as any pub loudmouth, plasterer or bathroom tiler will tell you.
And that's the problem with an anonymous and ill-detailed inspection notice. If you don't know who slapped it on, what kind of work it relates to and what level of professional competence they had, if any, then its presence can serve as a false sense of security.
Someone renting a property might see this label affixed to the consumer unit and assume their landlord is on top of their electrical safety, or someone might buy a new property and assume a label that's in date means it's been professionally checked over and needs no further checks anytime soon, even if the seller didn't hand over any related paperwork.
Another issue here is with the “Recommended date of next inspection”. If this notice is being applied on initial verification for new work, that's likely to be five or ten years in England and Wales depending on the nature of the property, unless there's a reason for a more frequent regimen which may be the case in commercial installations. On a periodic inspection for an existing installation however, we run into a problem. If the electrical installation is in such a dangerous state that one is required to mark it as being unsatisfactory for continued use, what date should then be entered into the ‘next inspection’ field?
Regulation 653.4 requires the inspector to make a recommendation supported by an explanation, and if we look at the model form for an Electrical Installation Condition Report in Appendix 6 of BS7671, it gives a caveat to the next inspection date which reads "Subject to the necessary remedial action being taken, I/we recommend that the installation is further inspected and tested by...” whenever.
So, in the event of an installation being deemed as unsatisfactory for continued use following inspection and testing, the date shown on the notice as a recommendation for the next inspection is what applies only assuming the duty holder follows the recommendations for remedial work given on the report and bothers to undertake them!
Again, if you're a tenant or someone who has just become the duty holder for an electrical installation, perhaps because you've bought a new house and no related paperwork was handed over, you'd look at the next inspection date on this sodding notice and would assume all is well and no action is needed until sometime in the far distant future, but what this notice doesn't tell you is that the next inspection date only applies if the installation passed as being satisfactory for continued use and, if it didn’t, then it’s caveat emptor mother fucker!
It's this kind of ridiculuum, overlooked for years yet so easy to fix which makes one wonder how fit-for-purpose the IET still are to be sticking their short wick between the brown flaps of the all-new regs book. If these doddery old fuckers could put some thought into the thing instead of sitting in their masonic lodge passing around the Cognac, then street shitheads like me wouldn’t have to pop up on the interwebs pointing out the patently obvious!
This notice is also to be applied where a new circuit has been installed. Let's say we're adding a new socket circuit to the above consumer unit. The CU already has a notice which, for the sake of argument, relates to when it was last inspected. Our new circuit is required to be signed off on a certificate as required in section 644 of BS7671. The Electrical Installation Certificate has a checklist asking for the presence of a periodic inspection and testing notice, and Regulation 514.12.1 states that this notice be fixed in a prominent position at or near the origin of every installation upon completion of the work.
Post new circuit and with additional notice applied
This means on or around your consumer unit there may be more than one of these notices, each with different dates. It's not uncommon to see such where someone has scribbled on something like "Circuit 2, new kitchen socket circuit only" or "DB2 only" or similar, to indicate their label relates only to a new part of the installation that they have explicitly inspected, tested and certified, and that their last and next inspection dates don't relate at all to the wider installation.
There are however no fields on the notice given in 514.12.1 to express this kind of useful and important detail, and reliance is on the diligence of any installer to take it upon themselves to volunteer that information. If another installer lacks that diligence, they may well slap on a sticker at source that relates only to the new work so they can tick the box on the certificate to say the notice is present, but again, someone looking at this notice with no context would naturally assume it applies to the installation as a whole and not just a particular portion of it.
A few years ago, and recognising some of the deficiencies with this goddamned thing, I had a load of custom labels printed that went beyond what Regulation 514.12.1 asked for. A third field was added that give a certificate reference, my company identification was provided including contact details, and my NICEIC and ECA membership numbers as relevant at the time were provided.
All well and good, and I still have a pile of these friggin’ labels, however I've now left the ECA so their logo and membership number shouldn't be on my stationery anymore which made me go back to the drawing board to design the ultimate, the daddy, the jutting cock and, indeed, wiry-haired balls of T&I labels.
And here is the monster, or version 0.9 Beta of it. A hell of a size the bastard is too at 190 x 70mm, but remember it doesn't have to be on show; it can be placed inside the lid of a consumer unit if desired. I know some readers will cry about that and say it needs to remain visible, but I'd rather have it inside the lid where it remains available to the next person poking about than to whack it askew onto the outside where Jill or Jasminder homeowner will peel it off for looking ugly and fucking with their feng-shui.
Let's cover the meat and two-veg to show how this bitch is totally badass…
There's no change to the IET English at this time and we still have a field for date of inspection, albeit slightly reworded as 514.12.1 has it as "date of last inspection", but I see no reason to include the word "last". As on my old labels, we have a field for giving the certificate or report reference that this notice applies to, and my company contact details are provided for any past clients to request a copy of that paperwork if they've mislaid theirs. It makes the dates and further information on this notice traceable and auditable.
What is new is this “Scope of Inspection” section which gives information as to what this notice pertains to. As stated previously, it can only legitimately be one of four things: a replacement consumer unit/distribution board (or an additional one having been added), a partial or full rewire, a condition report, or a new installation, addition or alteration, that is to say, either wholly new as in a newly built property, or one or more new circuits added to an existing installation. More than one field can be ticked, so we can have a partial rewire and new CU indicated for example, and if we've added a new circuit or secondary consumer unit, we can give limited detail on it such as "Supply to outbuilding".
Condition of installation is an important field missing from the current requirements of BS7671. Obviously, for initial verification it will always be “Satisfactory”, otherwise no notice or certificate can even be issued, but on a periodic inspection, the inspector gets to state whether the installation on the day passes muster or not and initialling the requisite field on the notice serves to identify who that inspector was in any given organisation making it traceable.
Of course, inspections always have some form of limitations, so where we're saying an electrical installation is safe for continued use, we do so with respect to the extent and limitations given on the report. Here, that’s stated implicitly on the notice itself because those who don’t know, wouldn’t otherwise know. Similarly, if we're indicating that remedial action is now required to correct any shortfalls in the safety of the installation, we state on the notice that the duty holder, i.e., the homeowner, landlord etc., is now responsible for acting without delay on any danger issues as highlighted in our report. We also make it clear that the recommended next inspection date given on this notice is only valid assuming no fire, flooding, incompetent tampering or otherwise has taken place since it was last looked at, and where remedial work has been undertaken, it has itself been certified. It's important that certification is provided for any corrective work identified on any condition report as the overall body of paperwork serves to show what the problems were, that they are now resolved and who accepts the responsibility for the safety of the installation between the original inspector and the sparky who undertook the remedial work, especially if they're from different organisations.
If I undertake an inspection, I accept the responsibility for the things I say have passed, but not for anything I’ve reported to the duty holder as a failure or that someone else has subsequently come along and fiddled with. If someone else fixes the things I say need fixing, but runs off without signing off what they’ve altered, then the best I can do is perform a reinspection, charged for of course, to see if the electrical installation is now satisfactory in my professional opinion.
But who am I to be performing this work anyway? There are plenty of installation electricians and downright fraudulent blaggers offering inspection and testing work when they're not insured, qualified or accredited to be doing such, and some of the comedy paperwork they produce has been dissected on the Cowboy Competition blogs of this website in the past.
Well, here's my NICEIC registration number and the address of the registered competent person website where the validity of my membership can be checked and where it can be verified that I am indeed rubber-stamped to be performing inspections in the first place.
I recognise that this customised notice is, in Pot Noodle terms, a bit of a king-size Bombay Bad Boy, so to save a little sticker space, I've also slapped on the stupidity of Regulation 514.14.1, the two-colours notice...
..albeit in a tiny text form:
Yeah, that's not actual size in real life, and it's been slightly reworded to state "Legacy installations may contain wiring colours to two versions of BS7671...", but changes to this bollocks was another recommendation I made on the DPC for amendment 2 which will likely be ignored by the bores at the IET. We're supposed to stick this daft waste of sticky-backed plastic onto any installation that shares red and black conductors with the brown and blue we've been installing since the mid-Noughties. It's a pointless label that needlessly fuglies up any installation and which basically says, in IET English, that you should correctly identify your conductors before working on an electrical installation.
Well, isn't that part of your basic safe isolation and common operating procedure anyway? Isn't that something so patently shitting obvious that it doesn't need saying? I think the worry is that an electrician from foreign climes might come over here and be confused as to what they're seeing, but different countries have different rules, regs, voltages and ways of wiring quite outside of the basic core colours and a better label would simply state:
Courtesy of John Rogers: https://twitter.com/colourbyrogers
Instead, for some reason we instead get the two-colours notice which says, in a fucktarded way, the core colours you find on this overcrowded, depressing and grey island are different to what you may have seen in other territories.
If you don't know the UK wiring colours pre and post harmonisation, you are, by the very fucking definition in chapter 2 of BS7671, not *skilled* to be getting up to your elbows in UK electrical installations you TART. Why does any of this have to be stated on a bloody label?
Fine. Whatever. If amendment 2 doesn't take my advice to drop the bullshit two-colours notice, it's now been incorporated here in slightly reworded small print on my own customised T&I label which reads “Legacy installations may contain wiring colours to two versions of BS7671” in a kinda-covers-my-arse way that doesn't wholly comply with 514.14.1 and ends up thrown-up everywhere whether relevant or not. But it's stupid anyway.
So, fuck ‘em.
One of the drivers for my making this change is because I'm often too embarrassed to apply my custom label to consumer units I've inspected where the workmanship is shoddy as shit or where old age and a lack of maintenance sees something distinctly cranky hanging off the wall. My label may have been adhered to a CU on an installation I have found to be unsatisfactory for continued use, simply to indicate when my inspection took place and when the next inspection ought to occur by if all the observations of danger are corrected, but the duty holder may not bother acting upon my sage advice, and the next guy who comes along might assume that the shitty installation in front of them with my name now slapped across it is actually the result of my own work, or one that I passed off as being fit for purpose despite obvious visible problems, whereas if they’d have got hold of the accompanying paperwork, they’d see I’d bitch-slapped it down as a load of old wank that urgently needs sorting out!
A customised label can almost serve to drag one into disrepute when it's applied to an installation of bad workmanship or poor maintenance even though it relates to a report where such failings are catalogued. Because of this, I get a bit naughty on some EICRs performed on iffy installations and I wholly omit the inspection and testing notice entirely because I don't want my company’s drunken name publicly showing anywhere near the horror work of some amateur. The duty holder knows the inspection has been undertaken and they have the paperwork, but my old labels didn't always get whapped on unless we've undertaken remedial work or, if they do get slammed into place, I'd sometimes scrawl on the notice that it does not denote a pass and further work is required.
My new layout makes it clear at-a-glance to any interested party be they a duty holder, tenant, another sparky or whomever just where the installation stands. Eventually, I'll send it off to a printer to run off a bunch of good quality UV resistant labels, but I'm waiting to see what amendment 2 poo's out as it's sod's law the IET English will be tweaked in some kind of useless half-arsed dippit-twat way that fails to address the underlying problems that daily effect those of us out in the real world.
Following feedback from my publishing of this rant on that YouTube, several suggestions were forthcoming on how to improve my custom notice from the likes of Marco, Jon Ringwood and Andi Archer, those changes having been incorporated into my Beta label here. Others suggested distinct pass and fail labels as opposed to a catch-all like this which would save space and improve simplicity, although I like the idea of a one-solution-serves-all approach. I was also asked about incorporating the RCD test notice, but this requires a larger font as it's meant for the duty holder more than the sparky and ought to be more legible.
Speaking of which, I realise the font size of this – especially the reworded two-colours bullshit, doesn’t meet the font size requirements in BS7671, but again, if you’re a sparky about to pull the cover off a live board, you shouldn’t even need notices about wiring colours, let alone ones written in a massive typeface. Either you know your shit or you know you’re shit, and you accept the consequences accordingly.
I suspect amendment 2 won’t change the notices but will allow them to be omitted on domestic installations because modern homes have consumer units on show in places like hallways, utility rooms and W/Cs, and most homeowners don’t want a utilitarian box humming on the wall with a bunch of warning labels clashing with the wallpaper. We’ll find out next month.
This nonsense is available in video form on YouTube and Odysee, albeit with my label in version 0.9 Alpha form. Once I find what amendment 2 has to say about this notice, I’ll tweak 0.9 Beta here into finalised version 1.0 and send it off to the printer for some decent labels to be reproduced. In the meantime, if you want to make your own custom label, feel free to download this PDF* of mine and use an editor such as the free GIMP to insert your own logo and details.
Bad language abounds in the video form, the script for which forming the text of this article.
*Download my crap at your own risk kids. I'm typing this on a Saturday night and I'm too drunk to care if it doesn't work for you.
Update 14/04/22 Post amendment 2!
So, the new brown regs book plopped onto my doormat at the start of April, and those demented pensioners at the IET haven't changed a thing with the old and inadequate T&I label...except to say it's no longer required in domestic applications, and neither is the RCD test notice. Regulations 514.12.1 and 514.12.2 pertaining to each got a note permitting their omission so long as information had been handed over to the duty holder on initial verification. Curiously, periodic inspection and testing wasn't mentioned!
Anyway, the long and the tall of the thing is that if a suitable 'handover pack' or service record contains all the pertinent instruction, unsightly labels need not be applied to offend the eyeline within a dwelling. To that end, I've been busy authoring a guides of my own containing detail such as the devices installed, how to test them and how to troubleshoot them.
Also of note is new regulation 514.16.1 which wants to see a notice warning of the presence of any surge protection, although giving no advice as to how that notice is to read and permitting it too from being absent in homes. Happily, we also see the scrapping of 514.14 the Two-Colours notice along with Appendix 7 on harmonisation.
All this means further final tweaking of my own label which I still intend to get printed and apply inside the lid of any CU I install, inspect and test. I believe this information should be present as not everybody will have a service record to hand with the details of dates and test procedures. I have authored such myself and shall be supplying it to my clients, but you cannot rely on it not being misfiled, lost or wholly ignored. Also, there are installations where a tenant should be aware of what’s electrically lurking under their roof beside them, home buyers who never received an information pack from the seller and people whose spouse ‘handled that kind of thing’ but who is perhaps no longer with us.
Anyhoo, without any more of this pesky ado, let’s look at what’s changed for the final version:
Firstly, the font of the main message has been shrunk down. Editions and amendments prior to the brown book always did use a ridiculously huge typeface for sample notices which was near impossible to abide by as there wouldn’t be room to apply such large labels. Also, label sheets from the manufacturers and the output of label printers meant the recommended font was largely ignored for something more practicable. Amendment 2 addresses this with a whole new appendix giving advice on font size, colour and typeface as well as label size and colour while referring to 514.9.2 which recommends compliance with various labelling standards.
But I’m throwing all that out, domestically at least. And why not, seeing as it’s now permissible to omit the information that's contained on my label entirely? The presence of my custom label is better than no label at all, yet amendment 2 permits no label at all, so I can do whatever I like.
A quick run through the changes then...
The previous version had a caveat in the Next Inspection date field, and this has been reworded for clarity. The Next Inspection date of course applies only if you haven’t suffered flood, fire, Russian nuclear missile attack or allowing your dickhead mate who tells you “electrics is piss” to monkey around with the bloody thing.
It's a bit tricky to see here as I have to squash it down to fit the formatting of this site, but the above is more legible in real life label form as the RCD notice:
“Devices with a (T) TEST button should be tested six-monthly. Pressing the button should mechanically operate the device. Seek expert advice if it fails to operate or to reset afterwards”
Many would argue that it’s hard to read and isn’t written in the all-new but still very tortured form given in 514.12.2, but again, we’re permitted to omit this information completely and I have the detail in my new handover guide, so the fact it’s here at all is a bonus, not a failing.
The information panel containing the installer details, registration number and verification website address has been overhauled to make room for...
Seeing as new regulation 514.16.1 wants something that indicates the presence of an SPD, even though we don’t have to provide that indication domestically, here’s a new section where the Present box can contain a tick or cross and the Type box will be 1 or 2 for an SPD installed at the source of the installation.
Love it, hate it, but there we have it. As before, I have it in PDF form** with my logo excised for anyone who wants to download it and tweak it for themselves.
**As with any website download, do it at your own risk folks!