From July 2020, it will become mandatory for landlords in England to have their rented electrical installations assessed for new tenancies, and from April 2021 for existing tenancies. Well, that sounds marvellous doesn’t it? What self-respecting landlord doesn't already ensure the safety of their tenants and of course their own property investment from the dangers of electrical shock or fire? After all, nobody wants an electrocuted rent-paying revenue source or a burned-out building, right?
Well, there are enough landlord prosecutions every year to show not everybody cares as much as they should despite the risk to themselves of having their insurance invalidated at best, or being fined or imprisoned at worst… which would, presumably, be an inconvenience, but I'll wager it will be much more inconvenient for their tenant who has seen their worldly possessions go up in smoke, or lost their health or even their life as a result of fire or shock.
So, Joe Landlord needs a piece of paper signed by a qualified person which says that their property is electrically on the level. That qualified person’s signature on an Electrical Installation Condition Report gets a landlord off the legal hook because said landlord can claim “I employed this Electrician-type person to check the electrical safety at the property; they said it passed and I had no reason to doubt their expertise”. Now, a good landlord will want a true reflection of the state of the electrical installation so that they can make informed decisions on future maintenance and upgrades, keep the rent coming in and keep their tenant safe. A bad landlord just wants a piece of paper with some other scapegoat's signature scrawled across it, and they'll want it as cheaply as possible.
Step in operators such as this one recently highlighted on Twitter by that James Beck where a company is advertising for electrical inspectors to test a minimum of four properties a day...
A minimum of four? And with a bonus scheme too for those who manage to pack even more in for these morons. Actually, that base pay doesn’t look too bad for someone who barely has to climb out of his van all day. I might have applied for it if my conscience allowed for me to rip people off and give a false sense of security that all is well when in fact there may be dire safety issues. I mean, it’s nonsense: how thorough can an inspection be with two-hours or less thrown at it? How can every circuit be properly inspected and tested along with the supply, earthing and bonding arrangements and the time to complete the form?
Well it can’t of course. What we have here is what we call a ‘drive-by’ inspection. It’s going to be performed so quickly and with so many limitations that it fails to document anything about the safety of the electrical installation at all, therefore it’s completely unfit for purpose. The chances are that such an inspection will be cheap, say £50 to £100, but even if it costs a fiver, is it worth the paper it’s even written on?
Sadly, to a rogue landlord, yes, it is. For their money, they’re transferring legal liability for the ongoing electrical safety of the installation from themselves to the inspector. For everyone else including the tenants, their visitors, immediate neighbours and the insurers, it’s a shit sandwich as they’re the ones facing the risk that something dangerous or deadly is being overlooked.
It’s no better for homeowners who are making their own decision to have their installation inspected; how do they know they’re hiring the right person for the job and that the report they receive is a true and accurate reflection of the safety of their installation and not just a load of poppycock full of errors or perhaps even fraudulently presented to try and extort further payment for work that isn’t needed? And that’s the problem with a cheap report. If some chancer misreports the installation as being unsatisfactory, then the landlord or homeowner is left either paying out for work which may not really be needed, or paying out for a second opinion. We get this a lot – called in to quote for remedial work where remedial work isn’t required because a report claiming improprieties is itself a bag of nonsense.
Here, I'm going to look at such a beast. I’m going to show you the quality of a report that cost a homeowner £85 whereas my charges based on my present per-circuit pricing would have been £140. You can judge for yourselves later whether that £55 saving was worth it or not.
AFF6
To set the scene then, just before Christmas last year I was contacted by a lady who was worried because she'd had an EICR performed by an "Electrician" and her installation had been condemned as being 'unsatisfactory'.
I’m not going to name the person who performed this inspection as it could land me in legal hot water even though I’m simply presenting the facts of the matter here, but I notice he has both a website and a presence on Check-a-Trade. Yeah, no surprises there. I know there are legitimate people on Check-a-Trade, and I know many find it good for business, but as I reported a few years ago, the problem I have with them is the way they market their members to the public as being vetted, checked and bona fide, yet every time I come across pure cowboy work, you can bet the rogue behind it is on a site like Check-a-Trade or Rated People. The checks these directory services perform are minimal, the review system is skewed to the positive and it’s an easy way for an iffy outfit to quickly set up an online presence and apparent reputation. I see the Check-a-trade logo as a caution sign personally, and if hiring tradespeople myself I'll go out of my way to avoid anyone sporting their logo.
Going back to this fella, and both his website and Check-a-Trade pages claim NICEIC accreditation, and indeed he does show up in a search under the NICEIC domestic installer umbrella. On his website, this chap purports to have "over twenty years’ experience", so we’ve got someone here who appears to have been in the field for some time and is legitimately accredited, at least for domestic installation work.
However, an installation electrician is not the same as an electrical inspector. Someone can be an installation electrician capable of signing off their own work, but if undertaking inspections, then they should be qualified and insured specifically for such, and if accredited, then their Competent Persons Scheme should cover them for it and be assessing their competence.
An installer who is performing inspection work without the requisite qualifications, so, something like the City & Guilds 2394/2395 or the 2391 and/or is lacking professional indemnity insurance may be producing reports that have no legal weight. If it all ends up in court because of death, injury or property damage after something was missed on an inspection, then a lack of specific qualifications for this task would potentially expose the installer to prosecution under Regulation 29 of Electricity at Work Regulations. If the installer has no professional indemnity insurance which is needed for anyone passing an opinion on the ongoing safety of an electrical installation, it may also mean the homeowner’s own home insurance is not valid to cover the cost of any damage following an incident. That leaves the installer open to private prosecution for misrepresenting the services they could offer and for undertaking work they were not insured to be doing.
I’ve already said that the report we’re looking at today is by a business accredited with the NICEIC Domestic Installer scheme. Well, let me refer you to the criteria for membership of that Scheme which states on page eight of their guide “[EICR’s] …are not covered by Domestic Installer registrants. Contractors wishing to provide these will need to apply for our Approved Contractor Scheme.” So, by undertaking inspection work, this chap is outside the boundary of what his scheme membership permits.
Now, I know there will be contemporaries of mine reading this who’ll say “I’ve been doing inspections for years without any piece of paper from the likes of City & Guilds saying I’m qualified for it, and I’ve had no complaints.”
Yeah, okay. I’m just stating the facts here, and the fact is that if any of us who perform inspections miss something we shouldn’t have and it leads to disastrous consequences, then you’ll be hauled up under EAWR, and the first thing that will be asked under Regulation 29 will be for you to prove you were fit, proper and competent to undertake that work and that you exercised due diligence in its undertaking. It’s up to you to make your own risk assessment about the services you offer and whether anything may bite you on the arse.
I can't show you this chap’s website as I'm not going to get myself in a legal quagmire by naming names but I can confirm that on it he boasts of commercial work, NIC approval, worry-free assurance and fully guaranteed work that he takes pride in. And again, there’s a claim again of over twenty years’ experience in domestic and commercial electrics. Looking at the Companies House website, we can see this business has been going since 2011, that’s longer than me and it appears to be a one-man band operation, or at least it’s run from a residential address, so as we go through this report, keep in mind these claims.
So, the homeowner has employed what she believes to be a legitimate, accredited electrical contractor to undertake the inspection work on her property. Little does she know this chap is not authorised by his competent persons scheme to be performing such work, so they’re not vetting him for it and he may not be qualified or insured. This installer has subsequently deemed her electrical installation to be unsatisfactory. When I went to visit the homeowner, I hadn't seen the report, so I was surprised to find that it was a modern house. In fact, it was only built in 2014. For the electrical installation the be walloped with an unsatisfactory stamp by someone in 2019, something must be very wrong. If we’re to believe this report, either there have been amateur modifications since the builder handed it over, or external influences such as fire, flood or rodent damage have compromised the safety of the electrical installation, or it was just improperly bolted together by the builder in the first place. In the case of the latter, the homeowner may have some legal recourse against the national house-building firm or their subcontracted electrical installers who are also a big national outfit.
I should state that I myself haven't undertaken any inspection and testing at the property, but what I saw was an insulated 17th Edition dual-RCD Hager board installed in the ground floor loo. Unfortunately, I didn’t take any pictures on the day, but it’s pretty much what you'd expect for a 2014 property. The CU was plastic as metal consumer units weren't required until January 2016 when 17th Edition amendment 3 came into full force. The consumer unit showed no outward sign of thermal damage, missing covers, poor installation, improper modification or anything else to cause me to go to the minor muscular effort of raising my monobrow. It all looked fine at a glance and indeed even under the bonnet where I took a quick gander. The homeowner was kind enough to furnish me with a copy of the report after my visit, so now that I've set the scene, we’ll have a closer peek at what we have here.
First though, and I am sorry that I keep darting off instead of getting into the meat of the thing, but let me address those reading who take issue with this format. In the past, I’ve taken some stick for having blog posts on this website highlighting the poor work of others. Some people don’t like that, and I understand to a degree why; I’m not the sparkie police, so who the hell am I to be holding up the work of others for ridicule or criticism? And I also understand that I myself may be shot down one day by someone who finds something with my name attached that they don’t like. I’d hope not, and I think there’s little risk of it as I try to be conscientious about my work, but I can’t guarantee everything I’ve ever done is a hundred percent. If I highlight bad examples on my website, on YouTube or on any other platform, it’s because clients should expect better standards and I don’t want to lose business to low-cost chancers. I make no apologies for talking about shitty competitors on my doorstep. As the mafia say, it’s nothing personal, it’s just business. If you’re a competitor who intends to undercut me, do half a job and rob a pensioner, then don’t expect an apology if I come along afterwards armed with a fork to pick the peanuts out of the rubbery turd you left behind. And you can look as sour faced as you want when we bump into each other at the sales counter of the wholesalers. I once had some cry-baby princess getting vocal in CEF on his annoyance at my prior ramblings even though he wasn’t the target. I guess he realised his own standards were low enough that maybe one day he could be, but then, if he recognises that, it’s up to him to up his game to where it should be. I’m not going to avoid talking about poor installers just because it risks upsetting them. So, without any further preamble, here we go with this one.
The presentation of this chap’s report paperwork is... sloppy. He's sent the report in an ODT file format favoured by the likes of OpenOffice and LibreOffice. This means I can open it in Word and edit it. That's not very clever. An unscrupulous landlord could change any information on here. An unsatisfactory report could be changed to reading as satisfactory, and the rogue landlord could then zap it off to his insurers or any other interested party. My own reports go out as PDFs, and while a PDF certainly isn't foolproof, at least it can't be immediately buggered with by the great unwashed without a bit of extra effort.
Looking at the content, you'll notice first up that I've blacked out identifying details, and it was easy for me to do that because as I said, I could just open this thing in Word and directly edit it.
Purpose for which this report is required: Electrical safety and condition. Performed on 21 November 2019. We have description of premises as Commercial which is wrong of course and estimated age of wiring system ten years. Ten years? I know this housing estate was built in 2014, the commission date is written on the consumer unit, so it's five years. You might think I'm being pedantic in bringing this up, but this person is supposed to be authoring a factual report here, and this is a simple fact to establish. We’re on the easy stuff so far; we haven't even gotten onto the testing yet. Evidence of alterations is marked as a yes. Well, okay, maybe, and again, I haven't inspected or tested the property, so there's no need for me to second guess that, but at least be consistent with the case: we have an uppercase Y in one box and a lowercase y in another. Admittedly, it's no showstopper, but it is poor presentation. Extent of the electrical installation covered by this report: "All circuits fed from main consumer unit in property including outbuilding." Good. So, it appears that this is a report covering all the final circuits. You can see it says so right there. I look forward to seeing how the circuits all check out later.
Agreed limitations: "No underfloors or loft inspections." Okay…, so why not look in the loft? And presumably matey also didn't inspect inside walls to ensure cables were in prescribed zones? That's okay, but he should state all the limitations. Limitations agreed with: not applicable? Well, surely, he agreed with the client that he wouldn't pull up her carpets and knock holes in her walls? Even if there was no explicit agreement, such is still implied. Most people booking an electrical inspection would reasonably expect you not to start swinging a hammer and knocking chunks out of the place. Again, it may seem like a petty point to make, but to me it shows this guy doesn't understand the fields on the form. The homeowner has paid him for his expertise to complete this British Standard document and so far, he's cocking up on the basic basics! Operational limitations: Not applicable. Well, I doubt that. Most of my own reports have operational limitations. As an example, I may omit line to neutral insulation resistance testing on a lighting circuit where 12V halogen downlights are present because disconnecting and wiring out the transformer for each would just take too damn long! It’s the same for a socket circuit with many fixed load accessories such as USB outlets and single-pole unswitched spurs or integrated kitchen appliances I just can’t unplug or that are too heavy or impractical to get behind. Ol’ big-balls here has no operational limitations apparently.
Summary of the condition of the installation: Unsatisfactory. Well to hell with you buddy, because I can edit your report and if this house burns down, I'll send the Health and Safety Executive my doctored copy, then when you get hauled up in court you'll have to prove it ever read anything otherwise. Mwa-ha ha ha! Overall assessment of the installation in terms of its suitability for continued use: Unsatisfactory. Hm. Look at that. He's got an apostrophe in “Its” which is wrong as it’s not saying "it is". The apostrophe changes the sentence to read "overall assessment of the installation in terms of it is suitability for continued use". It may not seem important, but this is supposed to be a British Standard document completed by a competent and registered electrician. Basic errors in English on the very form itself raises questions as to the quality standards this bloke is working to. His own written English may be crap; maybe it isn't even his first language, maybe he did poorly in English at school but perhaps he is nonetheless a great sparkie on the tools, that's not what I'm questioning here, this is an error on the form he’s reliant upon, so what other basic errors are there on the base paperwork he's issuing? We will see more; I can guarantee that.
The next section on the form is Observations, but I'm skipping that particular delight for now, of more immediate interest however is the declaration...
...which contains a name and date, but no signature. Regulation 653.5 states "The report shall be compiled and signed or otherwise authenticated by one or more skilled persons competent in such work." If the homeowner or landlord wants a sparkie to sign off an existing electrical installation as being safe for continued use, then it needs to quite literally be signed off. That signature is the bit where the inspecting electrician commits to taking on the liability and without it, this document may prove useless. Should an incident occur where things get a little 'legal', the electrician here could argue that the report is invalid as he never even signed it. I don't know if he'd get away with that in court, but you can be damn sure his slimy, inhuman solicitor will use it to try and transfer liability back onto the homeowner or landlord. And why, in this section, does it again ask for the overall condition? How many times does it need to be stated? He already said twice in Section E that it was Unsatisfactory, so why does it list it again on this bargain basement paperwork, and why has he left it blank in this section?
I’m going to skip section H, we’ll come back to that later, instead let’s look at Details of approved contractor.
Enrolment number: Not applicable. Why? This chap is with the NIC, he has a membership number so why doesn't he show it? It’s not a straightforward omission as he has gone to the trouble to enter ‘NA’ into the box, so my only conclusion is that he either doesn't know what Enrolment Number means, or he knows his particular NIC membership number is not valid for this kind of work, so he’s hiding it. The former is ignorant, the latter is fraudulent. If you were hiring this guy, which would you prefer to be the case?
On to the (somewhat malformed) Section K and Supply type: TNS? On a 2014 house? I doubt it. I haven't checked, but I'll bet this place is PME. Earth fault loop impedance: 0.36 Ohm? Well, you'd probably want be asking the district network operator to be having a closer look at that if it is PME. The main fuse is apparently a BS1361 type 2 at 80A he says, and with a short circuit capacity of... 6kA? What the...? I remind you, this guy is flashing an NICEIC logo. Has he any idea what these numbers even mean?
Particulars of installation has some curious blank boxes for continuity check on bonding conductors and structural steel. There won't be any structural steel of concern on this brick-built domestic property, so why is that box blank? And we have another formatting error here with water and gas listed as Yes, and most everything else listed with a cross. It’s usually Yes’s and No’s or ticks and crosses, but we have both here. Okay, it’s minor, but it’s scrappy.
Ugh. We're onto the checklist. I've pulled these apart in previous blog articles, but okay, let's sift through this particular pig.
Again, I haven't performed my own inspection and testing of this property, so I'm going to give him the benefit of the doubt as much as I can here, but the distributors earthing arrangement is likely not TNS. Item 3.7 Accessibility and condition of other protective bonding connections; he's put a Y here to indicate he's verified something, but what? The main earthing conductor has been verified in item 3.4 and the main bonding conductors in item 3.6, so what other bonding conductors would be in a 2014 domestic build? I'll bet you there's no supplementary or any other kind of bonding in this domestic dwelling.
Item 4.4: Condition of the consumer unit enclosure in terms of fire rating. That gets an N in the box. We'll come back to that later. Item 4.11: Presence of non-standard (mixed) cable colour warning notice at or near consumer unit. He's marked this down as though it's missing and should be there. I’ve previously publicly stated that I find the two-colours wiring label to be a waste of space. It hails from when the UK harmonised on wiring colours with Europe about fifteen years ago, so on a single-phase installation, colours switched from red and black to brown and blue. Older installations may therefore be wired to two colour standards, red and black for pre-2006(ish) circuits, brown and blue for anything newer. Do we really need a label to point that out? If you don’t know what you’re looking at or how to identify the function of any given wire, then what the hell are you doing cocking about with the electrics? As for this 2014 house, you’ll find no red and black wiring, so no, the two-colour label is not needed, therefore this should be coded as being Not Applicable.
Item 4.19 RCD's provided for fault protection he has coded as Yes. The next item, 4.20 concerns RCD's for additional protection, also a Yes. Here he has confused the two. A dual RCD board with 30mA RCD's fitted like we have here, or the devices in an RCBO board, have residual current protection for additional protection only. A domestic electrical installation usually relies on earthing as the primary means of shock protection. The job of the RCD is to provide an electromechanical back-up to that earthing and to quickly cut off the power if you're getting a zap. It’s a belt and braces thing. RCD’s cannot be relied upon as sole protection, regulation 415.1.2 says so, and that’s because RCD’s are electromechanical devices which can and do fail, but they can be used as additional protection to back up a primary means of shock protection such as good earthing.
An RCD provided for fault protection is different. That is there to cut the power where the earth impedance may be too high for a breaker or fuse to act in a timely enough fashion such as on a TT installation. But this is not a TT installation, he’s said so himself on his own report, and no RCD's installed here are providing fault protection, only additional protection, so the fact he's put a Y in item 4.19 is indicative of his ignorance of what he's looking at.
Item 5.2: Cables correctly supported throughout their length… he has passed. Wait a minute, isn’t that a limitation? This has to do with premature collapse and, more pertinent to this report, cables not being under mechanical strain, but he can only verify any surface mounted cables he can visually account for. All other cables are hidden within the fabric of the building, so how can he say this is a definitive pass when he can’t see most if not all of the wiring? Maybe he’s only saying yes to any surface mounted cabling he can see, but there’s no comment supporting that. Unless he’s dug out the walls and pulled up the floors, this is a limitation and should be listed as such.
Item 5.4 concerns non-sheathed cables in conduit, ducting or trunking, but the 18th Edition EICR model form goes on to ask about the integrity of that conduit or trunking where present. Below is an example from my Easycert forms which lists it as item 5.4.1 although the model form doesn't award it a number.
It's not present at all on this chap's paperwork. Is this supposed to be an 18th Edition form? This EICR was performed a year and a half after 18th Edition came into being. Certificates and report paperwork can deviate from the model forms presented in BS7671, but they should not contain any less information. The model forms are a minimum on what should be presented to the client, so if this chap is omitting stuff that BS7671 says should be listed, then that's… a bag of… bobbins. Item 5.10 again refers to cable runs, this time protection for cables under floors, above ceilings and in walls which he has marked as not applicable when they are once again limitations and should have been detailed as such at the start of the document. One limitation he did list, if you recall, was that he would not be peeping under any floorboards, so it should be coded as such on the checklist here.
Item 5.17, condition of accessories he has as a No-no, albeit without comment. We'll see shortly he does state in the observations that this is because of a damaged socket outlet in the kitchen, but then he's got 5.18 suitability of accessories for external influences also as a No, yet there's no comment and no mention of why in the observations. Presumably it's related to the above concern about the kitchen socket, but why no detail? If something is listed on the schedule of inspections as not being compliant, then the idea is to say why it’s not compliant in the observations, otherwise how is anyone else looking at this report supposed to know what on earth it refers to?
Item 6.2 isolation and switching. This is interesting as Isolation and Switching doesn’t appear on the 18th Edition model condition report, nor is it on Easycert, however it is a valid section on the 18th Edition Electrical Installation Certificate, so on this paperwork we have some kind of odd crossover with isolation and switching shoehorned in. That’s okay, additional information can be beneficial, but capable of being secured in the OFF position where appropriate being marked as Yes? Something like a rotary isolator can indeed be locked off, but I doubt there’s one here. Shower and cooker isolators tend not to have any means to lock off. The only thing I can think of which this might relate to here is the Hager main switch which has holes for attaching a lock-off device, but otherwise I’m not sure what he’s referring to and he doesn't say.
Item 8.1 Additional protection by RCD for low voltage circuits serving a location with a bath or shower. He's failed that, but this is a dual RCD board installed to 17th Edition Amendment 2: all circuits have RCD protection. There's no comment and again, nothing in the observations, so what is this, a typo? It’s the same for the next item: circuits passing through zone 1 and zone 2. Well, I'll bet there's no 240V cabling passing through zone one or zone two in that new bathroom, let alone any wiring lacking RCD protection. So maybe that's two typos? But then, there's item 8.2 Where used as a protective measure, requirements for SELV or PELV are met. Again, he's put No, but there's no further mention of why or what he means by that. And what's with all this Yes/No nonsense anyway, the coding is supposed to be PASS, C1, immediately dangerous, C2, dangerous in the event of a fault, C3 improvement recommended, FI for further investigation, LIM for limitation or Not Applicable/Not Verified. There’s no “yes or no” option. What’s all this supposed to mean? As far as SELV and PELV are concerned, we're talking here about a form of shock protection applicable to a circuit. There are no SELV or PELV circuits in this installation I’m sure. There may be individual items of equipment which use SELV such as an LED driver, but the circuit its driven from isn't SELV. The first item here should have been a pass, and the other two not applicable.
Item 8.4 is interesting: use of supplementary bonding conductors he has as not applicable. That's what I'd expect here; we shouldn't need supplementary bonding as this is a modern installation where the earth fault loop impedance should be within prescribed limits for all circuits, all extraneous conductive parts are bonded at source and all circuits have additional protection via RCD's. So how come in item 3.7 earlier he had accessibility and condition of other protective bonding conductors as passed? So, which is it? Do we have additional bonding conductors or don't we? He's passed them as though they're here, but then stated they're not applicable later in the same form.
We're nearly there. Item 8.5: 230v socket outlets sited at least 3 metres from Zone 1: Passed. Sigh. Are there any socket outlets in the bathroom? No, or at least, I very much doubt it. The house builder wouldn’t have installed one, and if a subsequent occupier did, then it will for sure be within three metres of zone 1 and therefore not a pass, but a C2 condition. I haven’t seen the bathroom on this three-bedroom semi, but I can guarantee it’ll be so small that everything is within three metres of zone 1, so how is he saying socket outlets in the bathroom are over three metres from zone 1? He probably means socket outlets are in other rooms, but then that's bugger all to do with the bathroom and bugger all to do with what this item on the checklist is asking about. You *can* have a socket outlet in a bathroom *if* it's a flippin' big bathroom *and* that outlet is over three metres from Zone 1, but if there are no sockets in that room, then it's just not applicable. I mean, think about it, in most houses, there is usually a socket outlet within three physical metres of zone one because it's in an adjacent room. Regulation 701.32.1 allows Zone 1 to be delimited by walls, doors, partitions etc. It is perhaps a minor point in this instance, but again it indicates an unfamiliarity with the form.
Right, let's skip back to his observations now that we've seen the checklist. A C1 or C2 coding will cause the report to fail and the electrical installation to be deemed as being unsatisfactory while a C3 or "improvement recommended" is merely an advisory. We know this chap has failed the installation for electrical safety, so let's now see why.
Number one. "The fuseboard is non-fire retardant". Oh, for goodness sake, there's only one retardant evident here, and it ain't the consumer unit. I've blogged and vlogged about this before, but let's put it to bed here for once and for all: plastic consumer units are not an inherent danger. What this chap has done is worry the homeowner into thinking an expensive consumer unit upgrade is required merely because the existing unit is made of plastic. Well newsflash asshole, plastic consumer units were permitted on domestic installations in the UK up to January 2016, so a house built in 2014 can legitimately have a plastic consumer unit enclosure. When installing electrical circuits and equipment, you install to the standard enforced at the time of design, that is to say if you planned a new build to 18th Edition amendment 1 which is in force at the time of writing, then even if amendment two came out before you built the thing, you could still subsequently install it to the Amendment 1 standard and sign it off as being compliant. This is why, when a big change like 17th Edition amendment 3 came along and said plastic consumer units are out and they must be all metal from 2016 onwards, house builders rushed to buy the old plastic stocks cheap and continued fitting them for months after the changes came in to effect under the reasoning that it was all designed to an older standard that was valid and in force during the planning stage. That's not the case here though; this build was legitimately designed, installed and signed off long before 17th Edition Amendment 3 was shat out.
Oh, you want evidence that I'm not talking nonsense? Open your blue book to page 13. It's that. Early. On.
Note by the Health and Safety Executive - not the IET, not BSi, but the HSE, those same folks that will be prosecuting you for breaching the Electricity at work Regulations should you ever kill anybody. And the boffins at the HSE say "installations which conform to the standard laid down in BS7671:2018 are regarded by HSE as likely to achieve conformity with the relevant parts of the Electricity at Work Regulations." Now, this is the important bit here... "Existing installations may have been designed and installed to conform to the standards set by earlier editions of BS7671 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."
That's on page 13, at the start of the blue book. As previously pointed out, what it means, in plain English, is that any new modifications you undertake need to be to the regulations in force at the current time, but older installations only need to comply with the standards in force at their time of design and you’re not going to be hauled up under EAWR just because you passed the inspection on an older installation after finding it to be in good condition. And of course that makes sense, you wouldn’t demand a twenty year old house be fully rewired just because it has 16th Edition wiring colours.
So, should this inspector be failing a 2014 consumer unit for not complying with a 2016 regulation? Christ, no. The analogy I always use is of a Jaguar E-Type car from 1965. Imagine you have one and you take it for an MOT to test it for road worthyness in 2020. Do you think the MOT station will fail it for not having airbags? Of course it won't. Airbags weren't a requirement when the Jag rolled off a Coventry conveyer belt over fifty years ago. That Jag passes its MOT *if* it complies with the standards it was built to. Do the lights work? Does it stop when it's supposed to? Does it roll on the handbrake? Are any body parts hanging off? Are the emissions within tolerance? Are the mirrors intact? etc. etc. If it's within the factory specifications, then it can continue on 21st century roads even though the driver knows he's not as safe as he would be in a modern automobile, but is prepared to accept that risk because he wants to pull some fanny in his flashy mid-life crisis Jaguar. Of course, if Jaguar wanted to remake the E-Type today, it would have to have airbags, ABS, impact bars and comply with all other modern standards.
That being the case, going back to our consumer unit: are we surprised that a 2014 installation doesn't meet 2016 requirements? No, we’re not. Is a 2014 consumer unit so horrendously old, out of date and dangerous that we now need to write it off? Bollocks do we. Let's flip this: what are the dangers of this plastic consumer unit? Well, it might not contain a fire, right? So how will it catch fire? Is the IP rating compromised so that external influences may affect it? Are there any loose connections which may cause a fire? Are there any openings that would help a fire to spread? Is the insulation of any final circuits compromised to the point where arcing may occur? Are any circuit breakers incorrectly rated for the wiring they're supposed to protect? Let's check this very report shall we?
Item 4.22 Confirmation that all conductor connections, including connections to busbars are correctly located in terminals and are tight and secure. Yes. Okay, so no loose connections, and I presume he's checked the terminals are torqued correctly.
Item 4.3 Condition of enclosure in terms of IP rating. He says he's checked this, and again, the answer, literally, is Yes. So no missing blanks or open cable entries then.
Item 4.5 Enclosure not damaged/deteriorated so as to impair safety. Again, this is a Yes. No splits, cracks, holes, indications of thermal damage or any other such issues.
Item 5.3 Condition of insulation of live parts: Also passed to the positive. No breakdown in insulation resistance reported here.
Item 5.6 Adequacy of protective devices; type and rated current for fault protection: Yes. The correct protective devices are installed.
Item 5.8 Coordination between conductors and overload protective devices. Passed once again. The protective devices in use ought to act in an overcurrent fault to prevent the wiring form overheating.
Well, then, what's to catch fire? Am I missing something? He's stating that everything is good in the CU including the enclosure itself, so why should it be at risk of spontaneous combustion?
Okay, so let's say a fire could somehow start in the CU despite passing all these checks. Is its plastic construction going to be a problem? Well, that depends largely on its location. Is it under wooden stairs? No, they don't stick consumer units under stairs anymore. Is it in a sole escape route? No, it's in the downstairs toilet. So, now, I'm going to reference two sources that say this isn't a problem. The first is the charity Electrical Safety First whose Best Practice Guide 4, page 15 states a plastic consumer unit is a C3 'imporvement recommended' coding only if it is not inside a non-combustible enclosure and is located under a wooden staircase, or within a sole route of escape from the premises.
They do go on to say that it would be a C2 condition if unsatisfactory connections are found, but matey here has confirmed that connections within the CU are sound. So, under these conditions where it is neither under wooden stairs nor in a sole escape route, Electrical Safety First say it is not noteworthy on a report.
The second source is the NAPIT codebreakers book which on page 24 also confirms that a plastic CU in a domestic premises showing no signs of thermal damage and not located in a sole escape route is not applicable as being recorded on any inspection report.
So, you don't have to take my word or my interpretation for it, Electrical Safety First and NAPIT are backing up what I say here.
His C2 coding as item number one is demonstrably bollocks. He’s contradicted his own findings on the schedule of inspections and has needlessly worried the homeowner about the safety of the installation. And you know, there’s a reason why new regulations aren’t enforced on older installations: a good many of them are in properties where the homeowner cannot afford a newer, better standard. Old fuse boxes for example are not inherently dangerous. You’ll find nothing in the blue book stating a rewirable fuse box must be replaced, and indeed BS3036 remains a valid standard to this day, you’ll find it’s still listed in Appendix 1. So long as it’s in good condition, hasn’t been improperly modified and contains suitably sized fusewire, it’s still doing the job it was installed for back in 1975 or whenever. Sure, it’s not ideal, but an old installation in good maintained condition shouldn’t be catching fire any more than a modern consumer unit, so a homeowner who simply doesn’t have the funds for a better standard shouldn’t be made to worry unless there’s something demonstrably wrong for them to be worrying about. It’s the same when you come across some old chuffer whose house hasn’t changed since 1986. When you can see that in the next five years he’ll either be in a retirement home or pushing up the daisies, is it worth worrying him into the cost and upheaval of upgrading his electrical installation if it’s old but still safely working? The house will be sold and gutted when he’s out of it; so let the new owners bring it up to date. Even the lack of RCD protection for internal circuits on an older installation is just a C3 because again, it wasn’t a requirement at the time of design. It’s definitely worth recommending a board upgrade to the homeowner, but it’s not for an inspector to put the willies up them with a danger coding on something that’s safe because it has good earthing and overcurrent protection, but is not built to modern standards. You tell them what the costs are and what the benefits are, and the liability goes back to them. They decide whether they want it and can afford it or if they’re prepared to continue living to the older standard. Anyone blanket-coding pre-18th Edition installations as C1 or C2 just because the consumer unit is plastic, overload protection is via fuses rather than breakers or no RCD is present for additional protection on internal circuits is wrong, but we see it all the time.
Anyway, let’s move on then to item number two, “The circuits are not all marked correctly on the fuseboard”. He really should say consumer unit as fuseboard is an out of date term, but personally, I’d grab the label printer out of the van and would correct that quickly enough without bothering to report it. Maybe he forgot his label printer on the day, I dunno, we’ll have a look at how the circuits are labelled when we come to the schedule of test results later. I’ll give him the benefit of the doubt that something isn’t right, but if the labelling is wrong, how come item 4.9 on the inspection schedule for ‘correct identification of circuits and protective devices’ has been passed?
What am I supposed to go on here, the inspection schedule which says it’s okay, or the observations which says it isn’t?
Item three: "No extraction fan in downstairs toilet". Well… yeah. It’s a toilet. With an opening window. Building regulations do not require a fan in a W/C where there’s an openable window sized to 1/20th of the floor area. This is known as purge ventilation and can be found in the Electricians Guide to the Building Regulations or in Approved Document F downloadable from the government’s planning portal which states on Page 24: “For sanitary accommodation only, as an alternative, the purge ventilation provisions (windows)… can be used…”. It doesn’t apply to bathrooms, laundry rooms, kitchens, utility rooms, but it does apply to a W/C which is what Part F defines as sanitary accommodation, and the house builder bloody well knew that, which is why a fan wasn’t fitted. But what as ventilation got to do with an electrical condition report anyway? It's out of scope and basically none of his business.
Item four: "The house ring is marked up as garage". Maybe that relates to item two about mislabelling? I dunno, but again, on the schedule he says all circuits are correctly identified, so... it’s a bit weird.
Item five: "Damaged kitchen socket" – a C1 or Immediately Dangerous! How exciting! I didn’t see this socket on the day, nor did I take any pictures on site, and you know, I regret that because I didn’t know I was going to pen this article and it could have been more complete, but I was in a rush, it was just before Christmas and I literally popped my head in the place to speak with the homeowner while on my way to another job. It was later that she sent me this report; all I knew on the day was that the consumer unit had been condemned as a fire risk, so I looked no further than that on my brief visit. I’ll take matey’s word for it that a kitchen socket is damaged and presumably exposing live parts if it’s immediately dangerous, but could he not have made it safe on the day? If I come across a broken accessory, I’ll replace it with one off the van. Sure, I charge for that, but if I can point to something that’s obviously defective and hazardous and tell the homeowner that their installation is going to be marked as unsatisfactory because it’s immediately dangerous, then they always let me go ahead and perform a quick remedial. Maybe he happened to have no sockets on the van, but personally, I wouldn’t want to walk away from a C1 if it can be made good inside of a few minutes on the day.
Item six: "Access to security alarm spur is poor". I’ve not seen it, but how poor can it be on a relatively new build? Maybe the client has erected something that obscures it? Let’s go back to the inspection schedule, section five “Distribution/final circuits”, item 5.19 “Adequacy of working space / accessibility to equipment”....
Well, it’s another pass here. And again, there’s nothing in his limitations to say he couldn’t gain access to this spur on the day, so presumably he did manage it and it was just awkward for some reason? I've no idea, he doesn’t give any detail. Maybe the test results will say something.
Incidentally, on the 18th Edition model form, Item 5.19 is for suitability of accessories for external influences, but that’s item 5.18 on his form. The numbering on this form all goes to cock after item 5.6, so if you’re looking at these numbers and finding they don’t match what you expect, well, that’s why.
Item seven: "Smoke alarms need replacing". Why? Smoke alarms tend to have a ten-year lifespan, so on a 2014 house I wouldn’t expect them to require replacement by 2019. What replacement date is printed on the alarms? I normally note it on the report, but there’s just no detail here, and again it's not really part of the scope for EICR's.
Now for the fun stuff, the Schedule of Test Results. I love pulling these apart. I can’t wait to see what tests you get for 85 quid. I hope you’ve got some beer and popcorn to hand for this because I… uh….
Oh, you’ve got to be kidding me?! This report ends after the inspection schedule?
Yes, it’s actually wholly missing a page; perhaps arguably the most important page. The page which should show the circuit listing, the protective device and wiring types, the ratings, the earth fault impedances, the insulation resistances, the RCD trip times, the ring continuity resistances, basically the data which shows whether this installation really is good or bad, the very meat and two-veg of the thing; the whole bloody point of bothering to do it at all. And it’s not here! Maybe he’s listed a limitation regarding the lack of test results….
No. There’s no limitations relating to testing to indicate why the data is missing. Let’s skip back to Section H, Schedules and Additional Pages which I overlooked earlier.
We can see that Schedule of Test Results for the Installation is marked as ‘not applicable’. Well, of course it’s applicable, it even says so right there in the same box: “The pages identified are an essential part of this report. The report is valid only if accompanied by all the schedules and additional pages identified above.” Quite incredibly, his own form invalidates itself right there in black and white. Earlier, in Section D he claimed the extent of the electrical installation covered by this very report included all circuits fed from the main consumer unit including an outbuilding!
So, we have another contradiction. Section D says he’s inspected and tested all final circuits, Section H says the results of the testing is not applicable, and the page which collates those results is absent entirely. As for that box which says Schedule of Circuit Details for the Installation, page number eight, I have no idea what that refers to. Page eight forms the end of the checklist and the test instrument serial number, so there’s nothing to see there.
The homeowner paid £85 for this and it’s worthless! It's incomplete, unsigned, error ridden, badly presented, draws the wrong conclusions and is useless for insurance or legal purposes. All they’ve got for their money is the worry that their installation is inadequate, and now they either have to pay this bloke to bring it up to what he believes to be the right standard, probably by forking out for a new badly installed metal consumer unit they never even needed, or they have to cough up for someone like me to undertake a legitimate inspection all over again. I would say it’s not worth the paper it’s written on… but they didn’t even get a physical copy, just a shitty Word document. Is this the standard you’d expect from someone claiming over twenty years’ domestic and commercial experience and who has been in business since 2011? Frankly, I’m amazed. When I looked up the company, I expected it to have only recently been incorporated and for this rubbish to have been authored by some rookie who did a five-day course before last Christmas and now thinks he’s the full cock and balls.
£85 is cheap for an EICR, but it’s not an EICR if no testing has taken place and the report is unsigned, incomplete and can’t be used for anything. That’s just £85 pissed up the wall. They’d only have paid an extra 55 quid had they employed me, but it would have been a complete and accurate document they could have flung out to estate agents, letting agents, insurers, solicitors, local authority, other sparkies or any other interested party because it would have had my name, my signature and my NIC and ECA enrolment numbers on it, and I’m backed up by my being qualified though City and Guilds 2394 and 2395 initial verification and inspection and testing qualifications, my professional indemnity insurance and my approval through the NICEIC Approved Contractor scheme to specifically undertake inspection and testing work.
Maybe the homeowner got the wrong end of the stick and what they paid for was a ‘visual inspection’ rather than a full report? Some contractors offer a service where they perform an at-a-glance inspection without getting invasive on the installation just to see if anything obvious to the trained eye needs dealing with. I don’t offer such because it seems pretty pointless and someone okaying an electrical installation they’ve merely briefly looked at can give a false sense of security and miss serious underlying and immediate issues. But maybe that’s what was offered here? Personally, I don’t think so. When I spoke with her, the homeowner was under the impression that a proper inspection and testing had been performed for the money, and the paperwork here makes no mention of it being limited to a visual once-over only.
The bottom line then: An inspection and testing job on a domestic electrical installation for a three-bedroom property should take half a day or more, at least, that’s how long it takes for me and Nige to undertake such, and remember there are two of us, both qualified and each armed with a calibrated multi-function tester so we can split the task. If you employ someone purely on a cheap price to perform such work, and they’re out of there in an hour or two, then they’re cutting corners for a fact. Also, everyone has to make money, so if you employ someone cheap, you can bet they’ll use it as a loss-leader and they’ll fail your installation on something so they can make up the money selling you remedial work. Rogues want to make a quick buck on a quick inspection and supplement it with a shopping list of remedials. Once you’ve effectively paid them to fail your installation, they’ve got you by the balls: you either cough-up what they say to put it right, or you’ll be forking out for a second opinion; so spend the extra and get a decent opinion in the first place.
If electrician X has a good reputation and appears to know their bananas over electrician Y who is cheap, poorly presented and isn’t accredited for inspection work with their own competent persons scheme, if they’re a member of such, then don’t risk the bargain basement option. This homeowner has an £85 Word document with formatting and factual errors and a whole page missing, and other than being entertainment for this article, it’s friggin’ useless.
There was a recent podcast on the e5 Group channel where they talked about this requirement for landlords to have inspections, and I agree with what they said about the way in which things will probably go. We suspect short courses will spring up where any bored painter and decorator or… whatever will decide he wants to break into the electrical industry and will attend a two-week course or something which rubber-stamps them as being bona fide inspectors only. Not installers, just inspectors. They’ll then go around working for outfits like the one that James Beck identified attending four or five drive-by inspections per day and passing poor judgement on installers who have years of experience and reams of relevant qualifications over them. We can all see it coming to pass, and they’ll be a bloody menace to the industry when it happens.
It’s only when someone is injured or killed that any one of these particular menaces will be stopped as again, they’ll be hauled up in court under EAWR and questioned on their knowledge and experience for performing inspection work, which will be found to be lacking. They’ll be fined or something, but only because some other poor bastard will have been electrocuted. The only other way they’ll be caught out is when a customer of mine, or that any other conscientious electrician, calls up to say an installation I fitted in the past has just been condemned as being unsatisfactory, in which case, that inspection report had better be watertight, because you know I’ll come over like a fucking iceberg to their Titanic.
And you know, I’m not whiter than white, and it’s quite possible I’ve put in installations in the past that a bona fide inspector may take some issue with, I mean, hopefully not, but if I’ve done wrong and someone can demonstrate why, then I’ll take that on the chin. However, if a report criticising my work is anything like as bad as this nonsense, I may well choose to get legal about it and make it into a defamation case because I won’t stand for some inexperienced Check-a-Trade wanker claiming that I didn’t do my job properly when I can pull out the blue book and point to black and white statements that show I did.
AFF8
This article is also in video form on my YouTube channel, but with much stronger language used throughout (i.e. NSFW).