scope of EICR inside/outside flat

[ElectricSpecs]

Hi

so I've just had another EICR done and while I was expecting some of the required remdial works - which include a new CU and gas meter earth bond - the electrician has added another item which they didn't mention when they were on site to the required works.

They are saying in addion to a new RCBO consumer unit with surge protectin within the property that the supply going from the meter (which is in a communal hallway) to the flat requires another RCD.

They say this is because it is "twisted pair" wiring and isn't in steel trunking. I note that none of the other properties in the block have any such RCD in the hallway cupboard depsite many of them being rented out.

I've asked my electrician if this is actually in scope as it says on the report that the EICR covers "all power and lighting circuits emanating from consumer unit only". To me this means downstream of the CU. But speaking to the electrician he says i am responsible for the supply from the meter onwards. It seems to me he is testing and upgrading something that is outside the self defined scope of the EICR and that either the scope should be increased or the extra RCD requirement disregaded or perhaps relayed to the managing agents of the block.

On a side point he has also put in the field saying next inspection due in " Every 5 years or time tenancy changes whichever is sooner". The  "tenancy changes" requierement seems totally OTT         to me and is potentially just profiterring. 

I'd be interested to get others opinions on the above

 

[SPECIAL LOCATION]

On a side point he has also put in the field saying next inspection due in " Every 5 years or time tenancy changes whichever is sooner". The  "tenancy changes" requierement seems totally OTT         to me and is potentially just profiterring. 

I'd be interested to get others opinions on the above

No...

Change of occupancy has been standard industry guidance for many many years!

Extract from Inspection & testing guidance notes:-

 

Guinness

 

[ElectricSpecs]

Thanks @SPECIAL LOCATION

Does change of occupancy derive from commercial lets? I'm struggling to see the practical justification of redoing every tenancy.

Your guidline seems to be only "recommendations", which isn't necessarily the same as being law. The actual law [for landlords in England] is stated in The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020, which says the following:

Duties of private landlords in relation to electrical installations

3(b) ensure every electrical installation in the residential premises is inspected and tested at regular intervals by a qualified person;

(2) For the purposes of sub-paragraph (1)(b) “at regular intervals” means—

(a) at intervals of no more than 5 years; or
(b) where the most recent report under sub-paragraph (3)(a) requires such inspection and testing to be at intervals of less than 5 years, at the intervals specified in that report.

So given that the electrician has written "every tenancy change" on the term on the report then based on the last part of (2)(b) it becomes legally binding on the landlord. The period they quote is based on their subjective viewpoint of how long it should be. I imagine the discretionary aspect of the term would have previously been been based on the condition of the installation e.g. wiring that might not last 5 years but now that the new EICR/landlord regs came in this is also being added there. Have I got this correct?

I'm still slighlty perplexed about how a reccomendation can become a law. e.g. on the EICR itself a C2 is a must do legally for a landlord whereas a C3 is a reccomended and is advised but nontheless optional.

It's all a bit ridicilous if this really is legally required evey tenancy change as I have the current tenant moving out within the next couple of weeks and a tenancy can and often does last as little as 6 months (assuming it doesn't end early if say the tenant does a runner). The prospect of very frequent checking is then made worse by the idea of checking a small percentage of the circuits so you could have Electrician 1 test 10% and fail and do remedial it then 6 months later Electrician 2 test a differnt 10% and fail it etc etc

 

[Evans Electric]

You raise some interesting points  Electricspecs .    

I would have agreed with Specs   on the change of Tenancy  but now  I'm not sure .  I would say that the new  laws for landlords  recently issued by the government  would overrule all others  where they state  5 year intervals   .       I recently did one  for a landlord  ...whose  letting agent was demanding  a test every year ...I  lkeft it with them to sort , not my business.   

Back to your EICR   , I would suggest that your property did not require surge protection  unless you asked for it .   

I am guessing that your electrician  is looking at the sub - main from  the meter   ( That he calls a "Twisted pair " )   which is phone cable  by the way,    and if it is buried in the wall the Regs ask for RCD protection .  

However , as you say , it may be the scope of the building management  .....  it s not endangering  your  tenant .  

The reference to "Twisted Pair "  as power cable  is somewhat strange  to be honest .  

 

[Sharpend]

Reason for change of tenancy is common sense applicable, reason being who knows if a Tenant has interfered with the electrics and potentially  left it dangerous for your next tenant, so it is recommended that an inspection is carried out, the 5 year rule is applied to privately owned properties generally however this doesn’t rule out a person interfering with wiring etc. But the consensus is that the more people that live in a property the more likely it is that alterations etc will be made unknowingly. 
 

as for the cable between meter and the cu, under normal circumstances then the occupant is responsible however in a High rise or block of flats etc where the incomer is located remotely to the individual property then there is a third party involved called a BNO, building network operator ? Who are responsible for this section of cabling, but again the EICR requires the electrician to report on the condition of the supply cables and service head. This doesn’t mean that it’s your responsibility, it’s just a way of getting someone pay attention to it as how often does the DNO turn up and check it!! 

 

[Murdoch]

FWIW I put the 5 year retest date on my EICRs'

HOWEVER I also include the following note "I would recommend that if the tenancy changes before the 5 year re-test, an inspection should be considered"

My justification for this is that you could have 5 x 1 year lets between inspections and lord knows how they have looked after the home.

Having multiple tenancies and NOT inspecting before the 5 year period is penny pinching and potentially dangerous for the tenants........

The submain issue is an interesting point ...............  would say this is the responsibility of the freeholder of the flats ..........

 

[ElectricSpecs]

You raise some interesting points  Electricspecs .    

I would have agreed with Specs   on the change of Tenancy  but now  I'm not sure .  I would say that the new  laws for landlords  recently issued by the government  would overrule all others  where they state  5 year intervals   .       I recently did one  for a landlord  ...whose  letting agent was demanding  a test every year ...I  lkeft it with them to sort , not my business.   

Back to your EICR   , I would suggest that your property did not require surge protection  unless you asked for it .   

I am guessing that your electrician  is looking at the sub - main from  the meter   ( That he calls a "Twisted pair " )   which is phone cable  by the way,    and if it is buried in the wall the Regs ask for RCD protection .  

However , as you say , it may be the scope of the building management  .....  it s not endangering  your  tenant .  

The reference to "Twisted Pair "  as power cable  is somewhat strange  to be honest .  

I probably am mis-quoting him. I thought it was "twisted pair" may well have been "twisted earth". He defininely said twisted something. It's just jargon to me.

Yes but the 5 years legislation in my post above also includes a shorter term reccomended by the tester.

So frustrating that letting agents feel they have the right to get involved and further muddy the waters, especially when these waters are already far from clear!

 

[Sharpend]

The waters are clear, you have a property, you rent it out, you oblige with the requirement to ensure a safe dwelling, your tenant obliges by having respect for said property. The waters only muddy when other parties jump in to take what isn’t theirs to take? 
KISS- keep it simple stupid- comes to mind. Why use an agent? Can you not advertise/manage your own property? 

 

[Evans Electric]

Back to the  " Change of tenancy"   term    .    I always agreed with ithis  ,  seen some places where the tenant has been messing / adding to / changing accessories etc  .

Called  out to one  by landlord ,      fishy smell of burning  , no power  .   Found the main switch in the consumer at the halfway position between On & Off ,  burnt out .   As a board we'd fitted I had a main switch with me , replaced it  then looking round the hall  I see  posh polished switches etc  had been fitted , I knew they were basic white before. 

Tenant denied switching the board off  but I'd bet he  knocked off the main switch to replace accessories  , then didn't switch it back fully.     Also with him changing  accessories  negates  our EICR  that was existing . 

I think landlords should have a  ruling that  gas or electrics are not to be interfered with .   

However if the latest legal position states  5 yrs    and ignores the change of tenancy  then so be it .  As I always say , we are not the Electric Police. 

 

[Murdoch]

ANY landlord that lets multiple tenants change in the 5 year EICR period without it being retested is, in my humble opinion, failing in their duty of care towards their tenants

end of

 

[Sharpend]

^concur, different for long term tenants as they are usually more responsible types? 

 

[SPECIAL LOCATION]

ANY landlord that lets multiple tenants change in the 5 year EICR period without it being retested is, in my humble opinion, failing in their duty of care towards their tenants

end of

+1

^concur, different for long term tenants as they are usually more responsible types? 

Concur with Sharpies concurances! 

Its no different to the principal of hiring an electric power tool from a Hire shop....

You would expect the Hire company to test & check all tools before they are re-issued out to a new customer.....

As you never know if they have been damaged or compromised by the previous customer and could present a danger to life or serious injury to the new user..

So if one tool tends to go out on long term hiring.. e.g. several months at a time...

But others are typically only out for less than a week...

Then some items will  & should, be retested more frequently..

If you have the previous test certificate for a property...

(and/or you are using the same contractor who carried out the previous test..)

Then a re-test, say.. 18months down the line, should be quite quick and not to expensive.

As you will not be starting back from scratch every time identifying what accessories each circuit supplies.... 

Guinness

 

[Murdoch]

As you will not be starting back from scratch every time identifying what accessories each circuit supplies.... 

ha ha ha

I've wondered for a long time what technology the cheap people are using to trace all circuits when the do an EICR in 1 hour!

 

[ElectricSpecs]

Thanks for replies.

Seems general consensus is that retest every change of tenant is resonable. I am mindful that most of you on here are electricians and naturally thus see it from the perspecitive of the ultimate electrical safety. From a landlords perspecitve it's more about running a business thus keeping costs down and margins up and risks to acceptable levels while complying with legislation.

I take the point that a tenant may interfere with the electrics though once you start down this road there are lots of risks which it becomes impractical to cover off. Did the tenant leave his collection of poisonus pet snakes in the attic? Perhaps as part of a terrorist movement they left their stash of anthrax/novachoc etc tucked out of sight under the kitchen sink or in the toilet cistern etc. Point being without virtualy knocking the building down and rebulding it you can't be 100% certain that the tenat didn't do or leave something that presents a risk to a future tenant.

Things like changed light switches or sockets should come up on an end of tennacy check out report which would then invite further investigation and thus an EICR for a prudent landlord.

I found the following guidance from NAPIT which confirms it's grey in their eyes:

Q If my property already has a satisfactory Electrical Installation Safety Report which is less than 5 years old, do
I have to get another one done to the 18 th edition of the Wiring Regulations Standard?
A
Not necessarily. You should review your report to see what was recommended on it and consider how your property
has been let since it was carried out. If big differences to the property have occurred, e.g. high turnover of tenants,
DIY work found, flood damage, then it would be prudent to get another electrical safety report done. If no changes
have been made, then your report will remain valid until the next inspection date specified.

Regarding starting from scratch at the next retest - I am sure you would be. For a start there is the 10% test/lack of overlap issue. Then there is the liklihood that we will be on the 19th, 20th etc wiring regs by the time of the retest. Also my experience of the gas saftey is that one engineer passes it one year, another engineer passes it the next year then the following year another engineer raises an issue which relates to the installation and was pre-exisinting thourhg the prior to tests and so fails it.

 

[Murdoch]

Regarding starting from scratch at the next retest - I am sure you would be. For a start there is the 10% test/lack of overlap issue. Then there is the likelihood that we will be on the 19th, 20th etc wiring regs by the time of the retest. Also my experience of the gas saftey is that one engineer passes it one year, another engineer passes it the next year then the following year another engineer raises an issue which relates to the installation and was pre-existing though the prior to tests and so fails it.

That is what C3 codes are for

Eg

right now an installation to the 17th Edition won't have a metal fuseboard - C3

Might not have RCD protection for the lights - C3

People coding these as C2's now are not applying codes correctly IMHO

 

[Sharpend]

Thanks for replies.

Seems general consensus is that retest every change of tenant is resonable. I am mindful that most of you on here are electricians and naturally thus see it from the perspecitive of the ultimate electrical safety. From a landlords perspecitve it's more about running a business thus keeping costs down and margins up and risks to acceptable levels while complying with legislation.

I take the point that a tenant may interfere with the electrics though once you start down this road there are lots of risks which it becomes impractical to cover off. Did the tenant leave his collection of poisonus pet snakes in the attic? Perhaps as part of a terrorist movement they left their stash of anthrax/novachoc etc tucked out of sight under the kitchen sink or in the toilet cistern etc. Point being without virtualy knocking the building down and rebulding it you can't be 100% certain that the tenat didn't do or leave something that presents a risk to a future tenant.

Things like changed light switches or sockets should come up on an end of tennacy check out report which would then invite further investigation and thus an EICR for a prudent landlord.

I found the following guidance from NAPIT which confirms it's grey in their eyes:

Q If my property already has a satisfactory Electrical Installation Safety Report which is less than 5 years old, do
I have to get another one done to the 18 th edition of the Wiring Regulations Standard?
A
Not necessarily. You should review your report to see what was recommended on it and consider how your property
has been let since it was carried out. If big differences to the property have occurred, e.g. high turnover of tenants,
DIY work found, flood damage, then it would be prudent to get another electrical safety report done. If no changes
have been made, then your report will remain valid until the next inspection date specified.

Regarding starting from scratch at the next retest - I am sure you would be. For a start there is the 10% test/lack of overlap issue. Then there is the liklihood that we will be on the 19th, 20th etc wiring regs by the time of the retest. Also my experience of the gas saftey is that one engineer passes it one year, another engineer passes it the next year then the following year another engineer raises an issue which relates to the installation and was pre-exisinting thourhg the prior to tests and so fails it.

so you are happy to pay the gasman to come and test for safety every year but not the electrician, even though there is a higher probability of someone thinking they are clever enough to interfere with the electrical installation as opposed to the gas? Ok so it’s not law to have it done but I wouldn’t want to be in your shoes when asked why you thought it best not to act on a professionals advice/recommendation if the new tenant gets a bolt or worse. Is the cost of an EICR really as expensive as a court defence? 
 

priorities priorities priorities :C  so instead of making £6k that year you might make £5700 big deal. But it’s ok for us to lose that on paying for our memberships to be able to provide you with the cover and guarantees you’d expect?  
 

it is no wonder Why landlords have a bad reputation. Imagine if every spark told you they were a good registered spark and only when something went wrong you found out they weren’t how would you feel. 

 

[binky]

OK, with regards to the less than 5 year testing, I've always regarded it acceptable to do a quick re-check rather than the full works, provided there has been  no obvious fiddling with the system. This is quicker and therefore cheaper for the landlord and so in theory encourages greater compliance. Prior to recent law changes, some sparks I know just did a visual check, ie look for obvious stuff like broken sockets, or did a thermal imaging check ie looking for hot-spots such as loose terminals - I always considered this nonsense with regards to checking ccts as faults may be buried in walls or under floorboards which thermal imaging wouldn't show. Not sure if law changes allow for such inspections? 

think others have said this already but sub mains don't need RCDs, and surge suppression is only for areas likely to suffer lightning strikes. 

 

[ElectricSpecs]

so you are happy to pay the gasman to come and test for safety every year but not the electrician, even though there is a higher probability of someone thinking they are clever enough to interfere with the electrical installation as opposed to the gas? Ok so it’s not law to have it done but I wouldn’t want to be in your shoes when asked why you thought it best not to act on a professionals advice/recommendation if the new tenant gets a bolt or worse. Is the cost of an EICR really as expensive as a court defence? 
 

priorities priorities priorities :C  so instead of making £6k that year you might make £5700 big deal. But it’s ok for us to lose that on paying for our memberships to be able to provide you with the cover and guarantees you’d expect?  
 

it is no wonder Why landlords have a bad reputation. Imagine if every spark told you they were a good registered spark and only when something went wrong you found out they weren’t how would you feel. 

I'm not happy about the gasman - every year - mainly because of the variable standards out there amongst gas engineers and the vague/subjective rules and risk adversity /blame game mindset that prevails. At least the law in clear on this though, it's simply every year.

I doubt many landlords are making that kind of money every year on a property and if they are you have to factor in their time and effort and the capital invested. These days with all of the changes many lanlords are making small gains, some are making a loss especially as the gov now taxes on turnover not profit! It only takes one bad tenant doing lots of damage or staying for months without paying rent to wipe out years of gains.

Regards the sparks, in my experiance good isn't the same as registered. Some are registered but no good. Is that a disspointing state of affairs for a cutomer? Yes it is.Been there done that.

 

[binky]

Regards the sparks, in my experiance good isn't the same as registered. Some are registered but no good. Is that a disspointing state of affairs for a cutomer? Yes it is.Been there done that.

 that's true of all professions, and a source of much argument amoungst us. 

Personally the only unregistered sparks I would trust are the semi-retired older types who hate paying money to the 'schemes'. 

 

[Murdoch]

Regards the sparks, in my experience good isn't the same as registered. Some are registered but no good. Is that a disappointing state of affairs for a customer? Yes it is.Been there done that.

Maybe change your "sourcing" of trades persons - I always tell people to ask their friends and neighbours AND rarely trust any appointed by a lettings agency ...........  

As for registered - do you mean in England and Wales registered with a CPS?