EICR Unsatisfactory - need advice

[ProDave]

I am glad the forum was able to guide you in the right direction to get it resolved and I hope your exchange of contracts happened today.
 

 

[Risteard]

C3 - if it conforms to original install but not to current, so is advisary. like a plastic consumer unit.

Whether it complied at the time of installation is immaterial as to whether it is safe or unsafe. For example, if in an escape route there were no non-combustible supports for the wiring system (assuming that it wasn't required when installed - which will be a matter of opinion referencing other Regulations), and we now know that several firefighters have died as a direct consequence of this, then it is completely unreasonable to state that it is safe to remain in service as is.

 

[Risteard]

U is 230V also.

I don't agree. N/A is correct for a single phase supply.

 

[Risteard]

So do we take it the EICR has now been ammended to "satisfactory" with just a few C3's?  If so that's the result you want.

Well impressed at the DNO turning out that quick. I guess he reported it to them as a "dangerous condition" that's normally the only way to get them out so quick.
 

Why should it be amended to "Satisfactory"? It's not a certificate but a report - it shouldn't be amended but simply a statement of the facts as they presented themselves at the time of the inspection. I would not amend an EICR to read "satisfactory" later but would merely certify whatever remedial works I had carried out.

I also agree with FI being uesd for DNO equipment - I have done this once as there were apparent deficiencies with DNO equipment which I could not interfere with to verify and therefore further investigation was required - by the DNO and not me obviously. It can be the only sensible and appropriate code for the situation.

My NICEIC Area Engineer is also adament that DNO equipment is to be commented upon as per the inspection schedule. It's in black and white on the inspection schedule after all.

 

[Andy™]

My NICEIC Area Engineer is also adament that DNO equipment is to be commented upon as per the inspection schedule. It's in black and white on the inspection schedule after all.

its also in black and white in 110.2 (i) that its not part of 7671

 

[Murdoch]

its also in black and white in 110.2 (i) that its not part of 7671

Nice one Andy. Just got my byb to check ....

 

[Risteard]

its also in black and white in 110.2 (i) that its not part of 7671

I agree that there's a certain contradiction there but it's certainly not the fault of the Electrician correctly coding it as he sees fit. He did what he had to do.

 

[Andy™]

i would comment, and if it was dangerous call DNO, but i wouldnt give an unsatisfactory report for it. bit like saying its unsatisfactory because the front door is broken

 

[ColleyCibber]

i would comment, and if it was dangerous call DNO, but i wouldnt give an unsatisfactory report for it. bit like saying its unsatisfactory because the front door is broken

The Electrical Safety First best practice guide 4 on EICR coding specifically lists one of the example uses of FI as flagging up deficiency in the network operator's supply. 

You can have a conversation about what may or may not constitute an FI, but the point that you can and where appropriate should FI the network operator's supply seems completely clear to me.

Applying common sense, you're not doing a very good report if the DNO supply has an issue that could render the installation dangerous and you sign it off Satisfactory, are you? Unless the supply head is declared specifically out of scope...which rather defeats the object.

 

[Andy™]

Unless the supply head is declared specifically out of scope...which rather defeats the object.

it is declared out of scope. see post 127...

if its dangerous then call DNO. they are legally required to fix it and will usually be there same day (usually within a few hours) and often fix it straight away. so what would be the point in writing an unsatisfactory report? or maybe you would rather give an unsatisfactory report then charge to go back look at the repair and issue a satisfactory one?

 

[Murdoch]

The Electrical Safety First best practice guide 4 on EICR coding specifically lists one of the example uses of FI as flagging up deficiency in the network operator's supply. 

You can have a conversation about what may or may not constitute an FI, but the point that you can and where appropriate should FI the network operator's supply seems completely clear to me.

Applying common sense, you're not doing a very good report if the DNO supply has an issue that could render the installation dangerous and you sign it off Satisfactory, are you? Unless the supply head is declared specifically out of scope...which rather defeats the object.

You need to remember that the ESC is part owned by the NICEIC and they think they write the rules!

And the scope of any EICR is agrees between the person ordering it and the inspector. It could be 1 circuit!

 

[Risteard]

i wouldnt give an unsatisfactory report for it.

Why wouldn't you if it renders the electrical installation unsafe? It's not really relevant whose duty it is to rectify it - if the installation is unsafe then it is unsafe and the client must be informed of that.

 

[Andy™]

it does not render the instatiion covered by 7671 unsafe, and DNO would be called who would fix it anyway

like i said, it would still be noted

 

[Risteard]

what would be the point in writing an unsatisfactory report? or maybe you would rather give an unsatisfactory report then charge to go back look at the repair and issue a satisfactory one?

Because that was how the installation was when you inspected it. I'm certainly not going to wait all day on the DNO for free to issue a satisfactory report. They can put it in writing to the customer that the apparent deficiency has been surveyed and has now been left in a safe condition or alternatively that it did not have whatever issue was suspected. Then that covers it. Why do you need a piece of paper to state satisfactory?

This clearly states the issue has been dealt with - once again I point out that an EICR is not certifying anything so it's pointless getting hung up on whether it states "Satisfactory" or "Unsatisfactory" once remedial works have been carried out and certified as appropriate (or a letter from the DNO or whatever if it is their issue).

it does not render the instatiion covered by 7671 unsafe

Of course it would. The safety measures for the BS7671 installation would potentially be defeated by the defect.

 

[ColleyCibber]

it is declared out of scope. see post 127...

Please explain then why best practice guide 4 tells you to code it FI where appropriate then, if it's outwith the scope of the report.

 

[Sidewinder]

Please explain then why best practice guide 4 tells you to code it FI where appropriate then, if it's outwith the scope of the report.

Tried to find where BPG4 suggests that a potential fused N should be coded as an FI & failed.

I could only find two examples of FI in BPG4:

FI – Further investigation required
• Characteristics of electricity supply (such as voltage or external earth fault loop impedance) do not conform to supply industry norms
• Presence of circuits that cannot be readily identified or traced.

I also failed to find anything in the ESC FAQ's relating to this.

So, whilst I believe that if one feels that there is an issue with the DNO kit, it should be coded FI, there is no formal guidance, that I have managed to find.

I'll post some more shortly.

 

[ColleyCibber]

We need to be clear in our thinking here. There are two entirely separate points :-

1. Is the network operator supply within the scope of the report in terms of being able to FI?

2. If so, is a suspected possible fused neutral in the supply head legitimate FI?

I'm open to having a discussion about 2. but it's difficult to see any merit in discussing 1. when BPG4 categorically answers it Yes. I'm not likely to be persuaded that, rather than code based on BPG4, I should code based on the word of some bloke on the Internet who says BPG4 is part of an NICEIC conspiracy.

 

[Sidewinder]

I don't agree. N/A is correct for a single phase supply.

OK, we'll have to agree to disagree then, I think!

I totally get where you are coming from, & I'll give you that one.

I use it to make a point of showing that there is only a single phase supply at the premises.

I agree that U is line to line voltage, thus if you only have a single line conductor, there is only one voltage that you can measure, which is U0, however, it's what I have always done, and don't ever recall being questioned over it tbh.

Off to check what I actually have put on my certs in the past, because that was I admit a knee jerk comment based on what I have said above!

We need to be clear in our thinking here. There are two entirely separate points :-

1. Is the network operator supply within the scope of the report in terms of being able to FI?

2. If so, is a suspected possible fused neutral in the supply head legitimate FI?

I'm open to having a discussion about 2. but it's difficult to see any merit in discussing 1. when BPG4 categorically answers it Yes. I'm not likely to be persuaded that, rather than code based on BPG4, I should code based on the word of some bloke on the Internet who says BPG4 is part of an NICEIC conspiracy.

The wording of an FI given in BPG4 does not cover the equipment, only the supply.

There in lies several issues with the current way that BS7671 & EICR's have been structured.

BS7671:

"110.2 EXCLUSIONS FROM SCOPE

The Regulations do not apply to the following installations:

(i) Systems for the distribution of electricity to the public" 

So, is the DNO equipment part of the system for the distribution of electricity to the public?

If it is, then BS7671 has no right to be commenting upon it, as by its own scope it is excluded.

However, the model forms go on to include checks and inspections on the distributors equipment, notably, without any regulation numbers against them, which almost all of the other checks in the list do have against them.

Thus, you cannot code them against a BS7671 regulation as there is no regulation to code them against.

The issue is, that the EICR requires you to check them & comment upon their condition as to whether this is satisfactory or not.

Thus you are stuck in the middle.

You have to check them and comment on them.

You can't check them against a BS7671 reg as they are excluded from the scope of BS7671.

A defect in the suppliers equipment may well be dangerous, and/or render the installation under BS7671 unsafe or inadequate.

However, it is not within the remit of BS7671, but BS7671 forces you to check it and comment on it.

IF you code it against BS7671, you can't quote a reg number, because there are none.

If you give it a C1, C2 or FI then you have to mark the EICR as unsatisfactory, according to the supporting documentation to BS7671.

If someone asks you which regulation are you coding the C1 or C2 against, there isn't one, because the equipment you are commenting on is excluded from the scope of BS7671 by reg 110.2i.

Now a fused N, may make the installation dangerous, damage to the head or meter may well be at the level of a C1, but, it is outside the scope of BS7671 because of reg 110.2i.

The issue is that BS7671 requires that you inspect and comment on it.

Now you have a moral duty (& almost certainly one under EAWR) to report such dangerous or potentially dangerous situations to the DNO, or metering operator (god luck with the MO), the DNO will almost certainly be there, probably within the hour, especially if you tell them that you consider it so dangerous that you have either isolated or cut their seal and pulled the main fuse & made safe, thus the consumer is off supply.

However, there are no regulations to back this up in BS7671.

Bit of a circle.

However, you must inspect, and comment on it.

GN3 states that an FI must be marked as “unsatisfactory” as it may result in a C1 or C2.

A C1 or C2 must be given “unsatisfactory”.

I can’t give page numbers because there are none, I don’t have the book, don’t ask.

It’s section 5.4.

ESC BPG4, states that an EICR must be done in accordance with the version of BS7671 in force at the time of the inspection. Pg8.

Now that would be the BYB, which requires checking the DNO kit, even though it is excluded from the scope of BS7671.

Now also on Pg 8 of BPG 4, it states that:

“The periodic inspection and testing procedures should identify any damage, deterioration, defects and conditions within the installation that give rise, or potentially give rise, to danger. The procedures should also identify any deficiencies for which remedial action would contribute to a significant improvement in the safety of the electrical installation.”

Along with:

 “Only observations that can be supported by one or more regulations in the edition of BS 7671 current at the time of the periodic inspection should be recorded. The particular regulation number(s) need not be entered in the report (unless specifically required by the client), but should serve to remind the inspector that it is only compliance with BS 7671 that is to be considered. Observations based solely on personal preference or ‘custom and practice’ should not be included.”

 

[ColleyCibber]

Eggsactly. So you either stand on ceremony clutching BS7671 saying "Not in scope!" and pretend you can't see something that might reasonably bring scope for danger, or you consider your duty of care in terms of a holistic approach to the safety of the installation (and maybe ask yourself if you fancy explaining in court in front of the grieving relatives why you didn't FI the thing that BPG4 arguably told you to report).

 

[Murdoch]

Eggsactly. So you either stand on ceremony clutching BS7671 saying "Not in scope!" and pretend you can't see something that might reasonably bring scope for danger, or you consider your duty of care in terms of a holistic approach to the safety of the installation (and maybe ask yourself if you fancy explaining in court in front of the grieving relatives why you didn't FI the thing that BPG4 arguably told you to report).

No you don't pretend anything - you complete the EICR within the scope of the INSTALLATION - i.e downstream of the meter and I would comment on anything that would appear dangerous about the incoming supply.

A couple of years ago I did a CU change - the metre tails were old and fabric covered, and they were in a poor state. I duly fitted an isolator with shiny new 25mm tails to my board and advised the client to ring the supplier - which he did and they said ................... they weren't concerned about the state of "their" tails.. So in this instance you "ColleyCibber" would give an unsatisfactory and the supplier wouldn't fix it - what would you do then?

As far as I'm concerned its another fine mess the IET and others have got us into.  We have to apply some common sense - which to me is don't give an "unsatisfactory" to an aspect of the installation which I or another general spark can't rectify.