EICR - C2 for no local isolation switch for electrical instant water heater

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rogerk101

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I have just had a mandatory EICR done for a rental property.

The electrician issued a C2 for no local isolator switch for an electric instant water heater that is mounted under the bath.

When I asked him which regulation this was contravening he was unable to quote one, but said a fault COULD occur in the heater and someone MUST be able to isolate it without having to walk the 3m required to turn it off at the RCBO in the consumer unit, so he considered it UNSAFE, requiring installation before the property is considered rentable.

Does this sound reasonable?

Can anyone point me to any regulation that could be used to justify his decision?

 
I'd have said code 3 with following reg maybe wrong in my opinion though 

Switching off for mechanical maintenance: 537.3

Mechanical maintenance is work that does not involve exposure to electrical connections. As such this work is often undertaken by ‘ordinary persons’.

Examples: Cleaning, adjusting or replacing parts of a machine. Replacing lamps in a fluorescent light.

Isolating devices must be able to switch the full load current and should be local to the equipment. More often than not the main isolating device is also used for mechanical maintenance for machinery as it’s close by and lockable. Other devices may be used such as, fused connection units, double pole switches and plugs and sockets.

 
If the heater is mounted under a bath, is it behind a bath panel ?

If there is no bath panel I don't think an isolator should be fitted, unless its an IP rated rotary unit

Can anyone point me to any regulation that could be used to justify his decision?


IMHO - You need to email this question to the sparky and see what his reply is

 
If the heater is mounted under a bath, is it behind a bath panel ?

If there is no bath panel I don't think an isolator should be fitted, unless its an IP rated rotary unit
I'd say the isolator should be fitted but either IP rated under bath or in the next room other side of wall with a note saying where to isolate the unit 

 
it's the same as shower switches and cooker switches, you are suppossed to have a local point of isolation. However, a C2 does seem harsh, especially if it's on its own cct. I's not eaxcetly dangerous or poses a threat, so I would have said C3 for that one.

 
I'd have said code 3 with following reg maybe wrong in my opinion though 

Switching off for mechanical maintenance: 537.3

Mechanical maintenance is work that does not involve exposure to electrical connections. As such this work is often undertaken by ‘ordinary persons’.

Examples: Cleaning, adjusting or replacing parts of a machine. Replacing lamps in a fluorescent light.

Isolating devices must be able to switch the full load current and should be local to the equipment. More often than not the main isolating device is also used for mechanical maintenance for machinery as it’s close by and lockable. Other devices may be used such as, fused connection units, double pole switches and plugs and sockets.
It's an instant electric water heater, so no moving parts, so no mechanical maintenance.

Yes, it might be a bit more convenient to just flick a double pole isolation switch once every 15 years when the appliance needs replacement, but that falls into the convenience bucket ... not the safety bucket.

We're dealing with 50A loads for a 12kW heater, so not something Joe Bloggs should be doing. Unless the terminals are well made and correctly torqued up, it could represent a fire hazard. The more connections between the CU and the appliance, the more locations there are for untorqued terminals so the greater the risk of a loose connection.

 
If the heater is mounted under a bath, is it behind a bath panel ?

If there is no bath panel I don't think an isolator should be fitted, unless its an IP rated rotary unit

IMHO - You need to email this question to the sparky and see what his reply is
The heater is mounted under the bath in the upstairs bathroom, and is accessed by removing a service panel in the ceiling in the room underneath it. The spark wants the isolation switch mounted in the ceiling near the access panel. So, if a fault occurs, then you would have to run down the stairs, straight past the CU, which is installed under the stairs, through two rooms with doorways, and then reach up to the ceiling to activate the isolator. It would be far easier simply to come down the stairs, reach into the understairs cupboard and trip the dedicated RCBO for the electric water heater.

What do the instructions for the unit say?
They make no mention of an isolator switch.

it's the same as shower switches and cooker switches, you are suppossed to have a local point of isolation. However, a C2 does seem harsh, especially if it's on its own cct. I's not eaxcetly dangerous or poses a threat, so I would have said C3 for that one.
I agree.

 
The heater is mounted under the bath in the upstairs bathroom, and is accessed by removing a service panel in the ceiling in the room underneath it. The spark wants the isolation switch mounted in the ceiling near the access panel. So, if a fault occurs, then you would have to run down the stairs, straight past the CU, which is installed under the stairs, through two rooms with doorways, and then reach up to the ceiling to activate the isolator. It would be far easier simply to come down the stairs, reach into the understairs cupboard and trip the dedicated RCBO for the electric water heater.

They make no mention of an isolator switch.

I agree.


any isolator should be within 2m max, so I can see where he's coming from  :^O

I see little point in cutting holes in your ceiling under those circumstances. I would be looking at a double pole isolator under the bath. Your RCBO will almost cetainly be single pole, so wouldn't isolate the neutral for maintenance, without turning off the main switch - very incovienient. 

This is one of those 'jobs' where whoever installed said heater didn't do the job right in the first place. 

 
it's the same as shower switches and cooker switches, you are suppossed to have a local point of isolation. However, a C2 does seem harsh, especially if it's on its own cct. I's not exactly dangerous or poses a threat, so I would have said C3 for that one.




fitting isolation switches seems to be lacking by some installers these days from what I encounter

 
The way I see it is that isolation switches are more for convenience than for safety, so the lack of one means it's a C3, because it's an area for improvement. It is not a C2, because it's not potentially dangerous.

 
I recommend you Google the electrical safety council best practice guide no 4, issue 5 and take a read


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