EICR Code for working RCD with non-functioning test button

[Dartlec]

Doing one more of the flood of EICR today on a rented property before a tenant change, but ran into a slightly interesting case so would appreciate other people's views.

About 6.5 years ago I partially rewired the small kitchen at this property - and since the main fuseboard was a skeleton wylex cupboard job and a pain to replace, I added a small Garage CU with 80A RCD to supply the 32A MCB for the kitchen ring to comply with RCD requirements (The main fuseboard has a 100ma RCD).

Today during the EICR, the newer RCD tested perfectly using the megger, but the test button is non functional - doesn't seem to have any resistance behind it so I'm guessing has mechanically failed.

The issue then becomes what code this is noted on the EICR.

Common sense may say it's best to change it since it could be a sign of failure. However, it passed the tests with no problem and therefore functions correctly as an RCD.

A previous thread discussed a similar topic 6 years ago and most people agreed this should be a C2.

However, the ESC best practise guide states that C2 codes are for situations that aren't dangerous at the time, but "would become an immediate danger if a fault or other foreseeable event was to occur"

This is a TN-S system, and the circuit in question has a low Zs so the RCD is not required to meet tripping limits for the MCB - it is there for additional protection as required by Regs.

If this was an EICR on an older board the absence of an RCD would be no more than a C3, so it seems slightly overkill to list this as a C2 and therefore grade the whole EICR as "unsatisfactory"

My own view is somewhere around a C2.5 for cases like this, or perhaps a C2 but a "satisfactory" rating, both of which are not options based on the guidelines.

Given that we know exactly 0.05% of people press the test button, whether quarterly or bi-annually, and given that an inspection will occur after 5 years, does the non-functioning test button actually have an outcome on the "electrical safety" of the installation, which is what the EICR is for after all?

I have no idea how frequently the test buttons fail in comparison to the rest of the device, or whether one it is always indicative of a developing fault.

EICR aside, assuming that the RCD should be replaced, the further wrinkle is that it was a LAP branded board, RCD and MCB, which I believe are no longer produced, (At the time the customer wanted to save money so a LAP garage unit was the chepest option.) so replacnig just the RCD would either mean mixing and matching (which is itself usually a C3 in my book) or entirely replacing the unit.

How would other electricians deal with that part, given that it's long past supplier's warranty periods? Bite some of the cost themselves as a goodwill gesture? (Obviously not installing LAP brand goes without saying, but given MK and the current situation who knows which brands will be around in 6 years?

Final note - any one know who made LAP stuff - and whether it is still made under a different brand?

 

[Lucien Nunes]

For whatever reason, test buttons seem to have more than their fair share of intermittent contacts even factoring in how infrequently they are used. The test button circuit is independent of the RCD proper, so an RCD with an inoperative test button that tests fine on the MFT is not necessarily less reliable than one with a working test button, unless some physical factor like corrosion or dirt ingress is the cause (in which case the rest of the RCD could very well fail prematurely). But as pointed out above, not only does the test button test the RCD, if used as prescribed it also provides some exercise, which can avoid sticky tripping mechanisms. Therefore, by preventing the exercise taking place, the faulty test button could (in theory, if not in practice) lead to impaired safety, not just lack of proof of that safety. That said, I see the logic in the OP and would also like to be able to code it C2.5.

We've had a discussion about wiring faults that disable the test button in the past. There are multiple ways of implementing a test button circuit on a normal 2-pole RCD. If the schematics on the front of bog-standard 30mA are to be believed, a resistor between the line on one side and the neutral on the other, creating an imbalance without actually leaking current to earth, is the most common. Obviously there are two ways round this could be done; a) Supply line to load neutral or b) Load line to supply neutral. Considering the case of an N-E fault downstream of the RCD with no circulating current, configuration 'a' would be de-sensitised by the fault, since some of the test current would go from supply L to E, never passing through the toroid. Arrangement b) does not suffer from this problem since hard L-E shorts don't persist on a live circuit in the same way as hard N-E shorts. Therefore it would seem to be the better of the two, but IIRC we found both in practice, which would negate any requirement for L & N to be a particular way round unless the contacts themselves were sequenced.

Another way of implementing the test button is with a separate winding on the toroid, energised from L & N of the same side. The same MMF is created in the toroid as with the intended imbalance in the main conductors, although as the test coil can have more turns, the actual current can be lower. This makes it a more suitable method for RCDs with high IΔn values and renders the test function completely indifferent to polarity.

But, and it's a big but, the point PC1966 makes about the relative phasing of any current circulating via an N-E fault current more or less overrides any other considerations. Since this can pass through the N conductor in the toroid in either direction, increasing or decreasing the net imbalance when the device is tested, the test button threshold will always be subject to an error up to IΔn when an N-E fault is present, regardless of how the test circuit is implemented.

But until someone makes an RCD with a built-in finger that pops out like a cuckoo from a clock to press the test button exactly on cue, I don't suppose any of this matters very much.

 

[Dartlec]

For whatever reason, test buttons seem to have more than their fair share of intermittent contacts even factoring in how infrequently they are used. The test button circuit is independent of the RCD proper, so an RCD with an inoperative test button that tests fine on the MFT is not necessarily less reliable than one with a working test button, unless some physical factor like corrosion or dirt ingress is the cause (in which case the rest of the RCD could very well fail prematurely). But as pointed out above, not only does the test button test the RCD, if used as prescribed it also provides some exercise, which can avoid sticky tripping mechanisms. Therefore, by preventing the exercise taking place, the faulty test button could (in theory, if not in practice) lead to impaired safety, not just lack of proof of that safety. That said, I see the logic in the OP and would also like to be able to code it C2.5.

We've had a discussion about wiring faults that disable the test button in the past. There are multiple ways of implementing a test button circuit on a normal 2-pole RCD. If the schematics on the front of bog-standard 30mA are to be believed, a resistor between the line on one side and the neutral on the other, creating an imbalance without actually leaking current to earth, is the most common. Obviously there are two ways round this could be done; a) Supply line to load neutral or b) Load line to supply neutral. Considering the case of an N-E fault downstream of the RCD with no circulating current, configuration 'a' would be de-sensitised by the fault, since some of the test current would go from supply L to E, never passing through the toroid. Arrangement b) does not suffer from this problem since hard L-E shorts don't persist on a live circuit in the same way as hard N-E shorts. Therefore it would seem to be the better of the two, but IIRC we found both in practice, which would negate any requirement for L & N to be a particular way round unless the contacts themselves were sequenced.

Another way of implementing the test button is with a separate winding on the toroid, energised from L & N of the same side. The same MMF is created in the toroid as with the intended imbalance in the main conductors, although as the test coil can have more turns, the actual current can be lower. This makes it a more suitable method for RCDs with high IΔn values and renders the test function completely indifferent to polarity.

But, and it's a big but, the point PC1966 makes about the relative phasing of any current circulating via an N-E fault current more or less overrides any other considerations. Since this can pass through the N conductor in the toroid in either direction, increasing or decreasing the net imbalance when the device is tested, the test button threshold will always be subject to an error up to IΔn when an N-E fault is present, regardless of how the test circuit is implemented.

But until someone makes an RCD with a built-in finger that pops out like a cuckoo from a clock to press the test button exactly on cue, I don't suppose any of this matters very much.

Thank you! I think this qualifies as a comprehensive and knowledgeable reply!

I'm guessing that whoever made these RCDs for Screwfix didn't do anything more than the absolute minimum.


Out of interest, taking the 'exercise' benefit, does flicking the main switch off manually give the same benefit in unsticking the tripping mechanism, or is that separate from the 'switch' disconnection part?

One day I hope to meet a home owner or tenant who says they press the button - it's only been 15 years so early days

It's good to know that my initial view was not completely out of place. I think I'll discuss with the customer, given that his son is to be the new tenant and may want some additional sockets added before he moves in - in which case it may all become moot and I can persuade them to upgrade the main board.

Failing that, swapping the RCD and single MCB for a bigger 'name' will mean I don't need to worry about it for another 5 years.

 

[Lucien Nunes]

I don't think operating the lever is equivalent in terms of exercise, because it does not move the armature of the tripping solenoid. Of all parts of the linkage, correct and free movement here is most impotant as (on a traditional non-electronic RCD) the sensitivity depends directly on it responding to a relatively small magnetic force. Once it has released the trip-free linkage, there's a strong spring to do the rest of the work.

 

[pc1966]

As Lucien said, the only way to really exercise / test the RCD is by simulating a trip event so the magneitc part is moved. Having said that, cycling switches and MCBs periodically as part of a general check is not a bad idea as it will show up some sticky mechanisms that need replacing, and keep some from going bad in the first place.

For socket circuits you can trip without a functioning test button with some of the fancier plug-in socket testers that also have a button to divert current L-E to simulate a fault, sort of like the MFT test but without timing it, but again hardly anyone is going to do that!

 

[davesparks]

some of the fancier plug-in socket testers that also have a button to divert current L-E to simulate a fault,

And if the RCD doesn't work, or if there is no RCD installed then the current continues to flow and the tester gets quite hot relatively quickly, until the tester stops working, or it did on the early versions anyway.

It also requires someone to be daft enough to stand there holding their finger on the button, sadly I have a mate with the required level of daftness so have watched this happen first hand.

 

[pc1966]

That is a good point, as 30mA corresponds to around 7W which is going to toast fairly soon. I guess they could put in a PTC thermistor next to the main current setting resistor to save damage but as you found out they are normally built very much down to a price.

 

[Vortigern]

I would say F.I. and move on. I know a couple of others have suggested this and I agree it seems logical?

 

[pc1966]

But what further investigation is there to do?

The unit has a fault. It may or may not imply longer term safety issues, but no one is going to dissect the RCD to find out and put it together and back in service if it is deemed to just be the button's circuit. So realistically you have two choices:

• Code it as C3 and most likely it will be ignored for 5 years until the next EICR.
• Code it as C2 and the landlord has 28 days or whatever to replace it.

My own feeling is the only acceptable choice becomes C2.
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I know that may seem a little incompatible with the coding of no RCD on older installations as C3 when not for outdoor sockets, etc.

But to me it is a bit like the arguments on MOT testing of older cards. If you have a 60s car it probably had seatbelts as an extra-cost option as they were not yet mandatory. So if you presented such a car for MOT without seatbelts it would pass, but if it had seatbelts fitted that were faulty it would fail.

 

[Vortigern]

I suspect all cases of "test button not working" should be investigated.

But what further investigation is there to do?

Perhaps you could answer that question yourself?
In any event my view is you are not there to repair just report. In order to deal with a non working button you would have to work out why it is not working. For instance I have come across this a few times. Where the RCD did not operate under test or the test button. Puzzled I approached the RCD in question and switched it off manually. After this I found it operated under test and the test button worked. My investigation showed (to me) that due to lack of operation of test button and age/dust/contaminants the mechanism was stuck and manual operation cleared the "stickiness" If it had not worked I would have concluded it was shagged and got a new one. Investigation concluded.

 

[pc1966]

Perhaps you could answer that question yourself?
In any event my view is you are not there to repair just report. In order to deal with a non working button you would have to work out why it is not working. For instance I have come across this a few times. Where the RCD did not operate under test or the test button. Puzzled I approached the RCD in question and switched it off manually. After this I found it operated under test and the test button worked. My investigation showed (to me) that due to lack of operation of test button and age/dust/contaminants the mechanism was stuck and manual operation cleared the "stickiness" If it had not worked I would have concluded it was shagged and got a new one. Investigation concluded.

That is a fair point that it should not be a case of "pressed once, did not work, replace".

However, in the OP's case they have tried it out several times and found it would trip with the MFT test but not the button. So here I would say they have done as much investigation as it reasonable to do.

 

[Vortigern]

much investigation as it reasonable to do.

The OP has not made clear at what stage he is at in the EICR. If he was talking about while doing the EICR, in my view this should have been noted and a code attached. As he asked what code I assume he is in the process, in which case he should not have investigated but just put a code and brought it to the attention of the person ordering the work. After that if the person asked he should have investigated the fault observed. I think as Lucien has elucidated exhaustively the possible mechanism that may cause the trip to operate with the test button it is not within the scope of an electrician to investigate the cause due to this being a step too far for our pay grade. I suppose sending it back to the manufacturer might throw light on it? Or we just take the pragmatic approach of replacing it. It might be that a type A is needed due to hysteresis in the case of the test button not producing enough fault current for all I know, would not be too sure of how to test for that though. I could assay that if there were a number of computers/electronic equipment it could well be the case but that is merely an educated guess.

 

[telectrix]

just wondering if the tests were carried out with all loads removed from RCD. (apologies if this has been said before, but i've not read all posts ).

 

[davesparks]

I would say F.I. and move on. I know a couple of others have suggested this and I agree it seems logical?

What needs investigating? The test button doesn't work, not much to investigate is there?

 

[Vortigern]

What needs investigating?

See post no. 51 and earlier

 

[Dartlec]

The OP has not made clear at what stage he is at in the EICR. If he was talking about while doing the EICR, in my view this should have been noted and a code attached. As he asked what code I assume he is in the process, in which case he should not have investigated but just put a code and brought it to the attention of the person ordering the work. After that if the person asked he should have investigated the fault observed. I think as Lucien has elucidated exhaustively the possible mechanism that may cause the trip to operate with the test button it is not within the scope of an electrician to investigate the cause due to this being a step too far for our pay grade. I suppose sending it back to the manufacturer might throw light on it? Or we just take the pragmatic approach of replacing it. It might be that a type A is needed due to hysteresis in the case of the test button not producing enough fault current for all I know, would not be too sure of how to test for that though. I could assay that if there were a number of computers/electronic equipment it could well be the case but that is merely an educated guess.

The job is a local one to me, for a private landlord (1 property) that I've done some work for before, so I tend to deal with those differently than if it was a letting agency/3rd party, or an hours drive away, when I'd note the relevant code and then move on.

I did the testing and inspection on Thursday and am in the process of putting the report together. The new tenant is not due to move in till the end of the month and is actually the landlord's son, so there is some possibility they will want some work doing before or shortly after he moves in. (The master bedroom currently has 1 double socket)

My thought process was that if I could code the issue as C3 I could issue the satisfactory EICR, but either swap the RCD once the current tenant moves out (it will be empty for a few days), or if they need further work incorporate a new main CU in the job and remove the issue that way.

If the issue is C2, then I will likely hold off issuing the EICR until it's corrected, to avoid the complication of the landlord having to use the EICR and an EIC together in future to prove compliance.

It wasn't possible to completely unplug every device during testing (appropriate LIMs noted), so I may go back once it's empty with an RCD and double check, then swap it out if necessary.

I'm very glad I posted though, as there have been some very helpful and insightful comments and it's always good to know what the general thinking of other electricans is.

It's definitely possible to learn far more from the practical experience and vast knowledge of others than any electrical book - If only most internet forums worked like that

 

[Dartlec]

Just adding a note here for anyone in future who might find it useful.

According to the paperwork I dug out at the job, LAP switchgear was apparently made by Havells, who still exist. There are even some Havells MCBs still available new, and RCDs which look identical.

Looks like they have stopped manufacture though, as lewelectrical claims to have all the remaining UK stock.

I'll likely replace them with a more available brand, but might get someone out of trouble in the future...

 

[suffolkspark]

Just adding a note here for anyone in future who might find it useful.

According to the paperwork I dug out at the job, LAP switchgear was apparently made by Havells, who still exist. There are even some Havells MCBs still available new, and RCDs which look identical.

Looks like they have stopped manufacture though, as lewelectrical claims to have all the remaining UK stock.

I'll likely replace them with a more available brand, but might get someone out of trouble in the future...

Yea bloody havells pulled out of the uk just after I put 6 3 phase boards in a leisure centre ?‍? as it's clearly the same rcd both visually and by your paperwork I'd just grab one off that site

 

[stevethesparks]

Perhaps you could answer that question yourself?
In any event my view is you are not there to repair just report. In order to deal with a non working button you would have to work out why it is not working. For instance I have come across this a few times. Where the RCD did not operate under test or the test button. Puzzled I approached the RCD in question and switched it off manually. After this I found it operated under test and the test button worked. My investigation showed (to me) that due to lack of operation of test button and age/dust/contaminants the mechanism was stuck and manual operation cleared the "stickiness" If it had not worked I would have concluded it was shagged and got a new one. Investigation concluded.

If it fails the first time ie before freeing it - its failed.

 

[Vortigern]

f it fails the first time ie before freeing it - its failed.

so what do you put on your EICR?

 

[stevethesparks]

so what do you put on your EICR?

It would be a C2

 

[Vortigern]

As a matter of interest in the above scenario how would you justify that. What would be the likely danger? The test button does not work what harm can result from that?

 

[Lister1987]

a box is a box. when i shuffle this mortal coil, i don't care if they put me in a £500 coffin with velvet lining, or a plain box made from an old Ikea wardrobe. both will burn at a similar rate.

You're giving them too much credit Tel, Scousers will just use cardboard boxes ?

 

[telectrix]

You're giving them too much credit Tel, Scousers will just use cardboard boxes ?

that's just the posh ones . most Scousers settle for a body bag and a sea burial (dumped in the Mersey on the ebb tide).

 

[snowhead]

I wish I'd bought a pallet of popcorn 2 days ago, I could have made a fortune selling it on this thread..

And I'd have done as Tel on post#13, change everthing in the Lap box

 

[stevethesparks]

As a matter of interest in the above scenario how would you justify that. What would be the likely danger? The test button does not work what harm can result from that?

Well as it would have been tested an FI wouldn't be required.
A C1 is out of the question - unless their were other circumstances.
A C3 would in all honesty be forgotten about - "Improvement recommended" I couldn't live with that if the future failure led to a possible death.
So C2 it is, from then on its out of my hands and up to the person receiving the report to do something about it.
If it stuck once, it will more than likely stick again.
Everyone to their own.

 

[telectrix]

whatever you do, do not bin the RCD with the non working test button, with 65 posts, it has achieved celebrity status and will get a guest invitation to Loose Women,then a knighthood for being absolutely useless.

 

[stevethesparks]

Its the consumers only method of testing such a device. Are they to call an electrician every six months to verify its still working?

 

[suffolkspark]

Its the consumers only method of testing such a device. Are they to call an electrician every six months to verify its still working?

No, it's going to be ignored for 5 years + whichever way

 

[Vortigern]

Well as I said above, I had a sticking test button and the RCD did not work on test. Once I had manually operated it, it worked and has been checked since and still works. Maybe I should have replaced then? After all it was a bit old, Merlin Gerin.

 

[telectrix]

Well as I said above, I had a sticking test button and the RCD did not work on test. Once I had manually operated it, it worked and has been checked since and still works. Maybe I should have replaced then? After all it was a bit old, Merlin Gerin.

just shows that it's important to test by pressing the --- on a regular basis. i still recommend shorter interlvals than 6 months. i have a feeling that the 6 month requirement came in as customers could synchronise it with resetting the clocks twice a year. another case of pandering to numpties above safety.

 

[Risteard]

just shows that it's important to test by pressing the --- on a regular basis. i still recommend shorter interlvals than 6 months. i have a feeling that the 6 month requirement came in as customers could synchronise it with resetting the clocks twice a year. another case of pandering to numpties above safety.

Six monthly is a common recommendation around the world. As you suggest when the clocks change is the logical time to do this. Although if the so-called EU has its way then it's hard to know when to recommend. Not too sure why we had the quarterly recommendation in the past.

 

[pc1966]

Not too sure why we had the quarterly recommendation in the past.

For outdoor ones with a dedicated RCD, or plug adaptors, it was always a case of "test before use" so you have high confidence it is still working.

So presumably it started with a debate on how long between testing for board-mounted RCDs to gave acceptable fault detection given the move from dedicated outdoor sockets/adaptors to the widespread use of them on all domestic socket circuits. I have seen some RCDs that say test monthly, but that is just not going to be done, and other say "test regularly" but don't always say what that means (to give wriggle room in court?).