EICR unsatisfactory due to 'no RCD protection to lighting circuits'

[braddersman]

Hello - sorry to resurrect old thread but it seems to be along the lines of my issue.

I am a landlord with old Volex CU which only has RCD on sockets - EICR inspection has C2's it as no RCD on lighting circuit but reading this thread and spekaing to my usual electrician from London, it would seem it could be a C3 - can anyone advise me please?

Many thanks

Bradley

 

[brianmoooore]

Is the person who did this EICR a member of NAPIT?
NAPIT produce a "codebreakers" booklet, based on nothing other than their own ideas, which suggest C2 instead of C3 for lighting circuits with no RCD.
An EICR is based on the contents of the 18th edition of BS7671, produced by the IET, not the spurious recommendations of trade organisations such as NAPIT or the NICEIC, and the lack of a RCD in a lighting circuit, that was installed correctly at a time when BS7671 didn't require a RCD, is coded as C3, not C2.
This doesn't mean that I consider it acceptable to have any domestic circuit not protected by a RCD, and although I would code it as C3, I would strongly recommend the provision of RCDs in the notes accompanying the EICR.
A similar argument applies to lighting circuits that do not have a cpc.

 

[Deleted account]

Hello - sorry to resurrect old thread but it seems to be along the lines of my issue.

I am a landlord with old Volex CU which only has RCD on sockets - EICR inspection has C2's it as no RCD on lighting circuit but reading this thread and spekaing to my usual electrician from London, it would seem it could be a C3 - can anyone advise me please?

Many thanks

Bradley

What is the exact wording on the report?

it does make a difference. Also when was the lighting circuit installed. And have any alterations been done to the lighting circuit in the last 3 years.

 

[braddersman]

Thanks gents - I actually have not had the report yet so don't have wording, only verbally but could I get round by having RCBO's fitted to existing CU?

 

[brianmoooore]

This is a possibility IF RCBOs are available to fit your existic CU.
The term 'borrowed neutral' may then come into the discussion, if you're unlucky.

 

[MJPD29]

Hello - sorry to resurrect old thread but it seems to be along the lines of my issue.

I am a landlord with old Volex CU which only has RCD on sockets - EICR inspection has C2's it as no RCD on lighting circuit but reading this thread and spekaing to my usual electrician from London, it would seem it could be a C3 - can anyone advise me please?

Many thanks

Bradley

C2 is perfectly justified in this situation. Its down to the person who is signing the certificate whether to c2 or c3 in this situation.

 

[brianmoooore]

No it is not. BS7671 does not require RCD protection in these circumstances, so it cannot be a C2.
IET decides the rules, not NAPPIT etc

 

[timhoward]

Can we see exactly what the C2's are for please? Ideally a photo of the consumer unit too. We can then give much better advice.

If it's simply missing RCD protection for lighting, then BPG4 (best Practise Guide 4) has that as a C3.

(It's been interesting to me since joining NAPIT that an awful lot of their members distance themselves from Codebreakers, including some of the leadership (in private).
There's in fact a thread on the Napit forum asking how is it that Napit contribute to BPG4 yet publish a book contradicting it! I've yet to buy enough popcorn to read the thread to the end!)

 

[Deleted account]

C2 is perfectly justified in this situation. Its down to the person who is signing the certificate whether to c2 or c3 in this situation.

C2 MAY be perfectly justified. But I disagree it IS justified.

we code to the guidelines layer down. Nowhere does it say in any guidelines or regs lighting circuits without RCD protection in domestic are potentially dangerous.

other factors in the lighting circuit may justify having the lighting as C2 but not just being without RCD protection.

it’s down to the individual tester. Yes but within the guidelines.

I hate showers without rcd protection, but I don’t give them a C2. I can’t. Unless another issue arises that justifies it.

 

[braddersman]

He is having none of it and also says I have to have earth going to switch and light, even if using a plastic fitting - Grrrr

 

[telectrix]

C2 MAY be perfectly justified. But I disagree it IS justified.

we code to the guidelines layer down. Nowhere does it say in any guidelines or regs lighting circuits without RCD protection in domestic are potentially dangerous.

other factors in the lighting circuit may justify having the lighting as C2 but not just being without RCD protection.

it’s down to the individual tester. Yes but within the guidelines.

I hate showers without rcd protection, but I don’t give them a C2. I can’t. Unless another issue arises that justifies it.

i hate showers, period.
1.your smoke gets wett.
2. your Jack Daniels gets polluted by water
3.your Lee Child latest read gets wetted and soggy.

give me a bath every time.

 

[HappyHippyDad]

He is having none of it and also says I have to have earth going to switch and light, even if using a plastic fitting - Grrrr

Good for him. If he changed his mind we'd be moaning. Get the work done, as requested by the only electrician who has been on site and deemed it necessary.

 

[brianmoooore]

He is having none of it and also says I have to have earth going to switch and light, even if using a plastic fitting - Grrrr

Hang on a minute! This was a thread about no RCD, and now it's no cpc.
Same applies though. Lack of RCD and lack of cpc are not C2 per se, if the wiring hasn't been recently modified and was installed to regs.
It's the inspector's decision, but that decision must be made to the guidelines of BS7671, not his personal opinion, or that of a jumped up trade body.
Opinions should be offered in the comments.

 

[Lister1987]

You can’t C2 on a whim.

personal feelings, and maybe the tenant will do this or that cannot go into an EICR.

state fact and code appropriately without prejudice.

I'm with Buzz, I'd C2, while industry guides dictate a C3, they are just that; Guides. The inspector may have used thier engineering judgement, the fact it is going to be let out, the fact that this may involve children or unskilled persons DIY (The latter being thr only one that can be controlled by the letting agreement).

There may be further underlying factors as suggested but even without that you're looking at a 2 bed property with a reasonably high likelihood of being rented to a family and so putting forward the requirement for RCD protection is prudent.

Thr client needs to realise they have responsibilities to take necessary steps to foresee matters that may arise during the time the premises are let.

Aside from the obvious elderly persons market there should be zero reason not to have RCD protection in this day and age. The house is nearly 24yrs old, while in the scheme of things it's not old (compared to houses of the 60/70s) we've had the requirement for RCDs for that past 12+ years, that's half its life, and you're telling me we shouldn't be improving these Installations?

I'm sorry but I'm with the inspector on this one purely on the basis you can't Guarantee the type of tenant and so should be planning for all eventualities, no RCDs in (let) properties in this day and age is frankly irresponsible.

 

[timhoward]

To put this all in context, it's been a requirement since 1966 to have an earth (cpc) on a lighting circuit. The idea that electricity should have a safe way back in fault conditions is very much tried, tested and beneficial.

BPG4 slightly controversially says that if the fittings and switches are class II (plastic) it's only a code C3; this is in fact contravening another part of BS7671 that says class II protection can only be used if the installation is supervised (i.e. not a house).

It should also be noted that BPG1 says:



Even if as a literal interpreter of BPG4 I said the installation was just about satisfactory, my next words would be "but I highly advise the lighting is rewired and RCD protection is provided for all circuits. These investments would last for decades and the cost per month over the lifetime of them is almost nothing.

I've been reminded by @Lister1987 that this is a rental property, all the more reason to get it up to scratch for the tenants safety.

 

[brianmoooore]

I have not fitted a single domestic circuit that wasn't protected by an RCD since around 1980. The customer was given no choice in this. Take it or leave it.
BUT, the coding for scenario in this thread should be C3. It's a statement of fact at that moment in time. What might happen before the next inspection is irrelevant You are there to test to the 18th edition, and the clause referring to installations done to previous editions covers this.
You can recommend what you think is required in the strongest terms, up to the point of refusing to issue the certificate and walking away without payment if the landlord doesn't agree to your recommendations, leaving the landlord to find someone else to test.

 

[Deleted account]

He is having none of it and also says I have to have earth going to switch and light, even if using a plastic fitting - Grrrr

Without seeing his wording I cannot give a definitive responce, but from what you say , he is wrong.

 

[Deleted account]

I missed the bit about no earth and no rcd in the lighting circuit. I though it was just no rcd protection.

this changes things significantly.

is there anything else.

I really need to see the actual wording of report before condemning or agreeing with the electricians EICR.

I may have been a bit premature in my responses.

 

[Sparky704]

RCD protection in accordance with regulations BS 7671 is classed as additional protection & not fault protection.But under regulations relating to the 16TH addition bathrooms containing a bath or shower required RCD protection if supplementary bonding is not in place. Supplementary bonding comprises of a 6mm earth wire earthing all extraneous conductive parts ( metal bath, shower , pipes , towel rail etc) so that under fault conditions where one becomes live they all have the same voltage overcoming risk of electric shock as to get a shock you need to touch between different voltages as in if the bath is 230 volts & the pipe work 130 volts the fault current will be determined my a 100 volt differential.Under the 17 edition the bathroom is described as a special location due to additional risks.I don’t blame the electrician for a c2 as I have attended 2 emergency call outs where pipes where live endangering life which would not have been the case with an RCD. Another thing to consider is where the consumer unit is located. If it is within a fire escape route & made of plastic rather than metal it’s a code 2 as fire regs are incorporated within electrical regs now. With my 33 years experience don’t blame a guy for being cautious when electricity is involved

 

[Pretty Mouth]

Interesting discussion. On the subject of coding:

BS7671 does a reasonable job of telling us how an installation should be. It doesn't, IMO, do a very good job of telling us why an installation should be like that, and what dangers result from a particular non compliance or defect. The chapter on periodic I+T can be read in about one minute. Regarding RCDs for additional protection, it tells us we should code a minimum of C3 (guidance from model form). Other than that, it offers no more guidance on coding, leaving it totally up to the the inspector to decide. This is why I think guides such as BPG4 and codebreakers are necessary.

Codebreakers seems to take a bit of a bashing for coding too harshly, and, while I don't code to the book myself (I prefer BPG4), I do wonder if the criticism is a little unfair sometimes.

For example, I believe codebreakers offers a C2 for lack of RCD protection to cables passing through walls containing metal parts, and for cables buried in walls <50mm. These are both C3s in BPG4. However, there have been deaths that would have been avoided had RCDs been in place for the above circumstances, so I can kind of see why codebreakers is offering a C2.

Also, coding can be confusing. Lack of supplementary bonding in a bathroom, C2. Lack of RCD protection to bathroom circuits, C3. Add RCD protection to the bathroom, and the C2 goes away. So how can lack of RCD protection not be a C2? Difficult logic to get the head around sometimes.

 

[Deleted account]

Interesting discussion. On the subject of coding:

BS7671 does a reasonable job of telling us how an installation should be. It doesn't, IMO, do a very good job of telling us why an installation should be like that, and what dangers result from a particular non compliance or defect. The chapter on periodic I+T can be read in about one minute. Regarding RCDs for additional protection, it tells us we should code a minimum of C3 (guidance from model form). Other than that, it offers no more guidance on coding, leaving it totally up to the the inspector to decide. This is why I think guides such as BPG4 and codebreakers are necessary.

Codebreakers seems to take a bit of a bashing for coding too harshly, and, while I don't code to the book myself (I prefer BPG4), I do wonder if the criticism is a little unfair sometimes.

For example, I believe codebreakers offers a C2 for lack of RCD protection to cables passing through walls containing metal parts, and for cables buried in walls <50mm. These are both C3s in BPG4. However, there have been deaths that would have been avoided had RCDs been in place for the above circumstances, so I can kind of see why codebreakers is offering a C2.

Also, coding can be confusing. Lack of supplementary bonding in a bathroom, C2. Lack of RCD protection to bathroom circuits, C3. Add RCD protection to the bathroom, and the C2 goes away. So how can lack of RCD protection not be a C2? Difficult logic to get the head around sometimes.

The no supplementary bonding in bathrooms is my get out of jail free card when I’m not happy at the lack of rcd protection on lighting circuits. I very rarely come across a bathroom that has adequate bonding.
this is what I would code as a C2 If it also has no rcd protection.

Not just the lack of RCD on lighting.

I will state “inadequate or no supplementary bonding without RCD protection in bathroom” C2.

 

[telectrix]

no beer provided on completion of a EICR is definitely a C2, even a C1 on a hot day.

 

[Sparky704]

C2 MAY be perfectly justified. But I disagree it IS justified.

we code to the guidelines layer down. Nowhere does it say in any guidelines or regs lighting circuits without RCD protection in domestic are potentially dangerous.

other factors in the lighting circuit may justify having the lighting as C2 but not just being without RCD protection.

it’s down to the individual tester. Yes but within the guidelines.

I hate showers without rcd protection, but I don’t give them a C2. I can’t. Unless another issue arises that justifies it.

You can justify a code 2 for a shower as the manufacturing instructions will insist on RCD protection & BS7671 stipulates that manufacturing instructions have to be adhered too.

 

[telectrix]

BS7671 stipulates that manufacturing instructions have to be adhered too.

not entirely correct. " manufacturers instructions should be taken into account" , no necessarily blindly followed. other wise we'd be following B&Q instructions to connect lights in an unenclosed choc. block, stuffed in the ceiling with 2 layers of insulation tape.

 

[Sparky704]

Is the person who did this EICR a member of NAPIT?
NAPIT produce a "codebreakers" booklet, based on nothing other than their own ideas, which suggest C2 instead of C3 for lighting circuits with no RCD.
An EICR is based on the contents of the 18th edition of BS7671, produced by the IET, not the spurious recommendations of trade organisations such as NAPIT or the NICEIC, and the lack of a RCD in a lighting circuit, that was installed correctly at a time when BS7671 didn't require a RCD, is coded as C3, not C2.
This doesn't mean that I consider it acceptable to have any domestic circuit not protected by a RCD, and although I would code it as C3, I would strongly recommend the provision of RCDs in the notes accompanying the EICR.
A similar argument applies to lighting circuits that do not have a cpc.

C2 MAY be perfectly justified. But I disagree it IS justified.

we code to the guidelines layer down. Nowhere does it say in any guidelines or regs lighting circuits without RCD protection in domestic are potentially dangerous.

other factors in the lighting circuit may justify having the lighting as C2 but not just being without RCD protection.

it’s down to the individual tester. Yes but within the guidelines.

I hate showers without rcd protection, but I don’t give them a C2. I can’t. Unless another issue arises that justifies it.

 

[Sparky704]

BS7671 stipulates that manufacturing instructions have to be adhered too.

not entirely correct. " manufacturers instructions should be taken into account" , no necessarily blindly followed. other wise we'd be following B&Q instructions to connect lights in an unenclosed choc. block, stuffed in the ceiling with 2 layers of insulation tape.

BS 7671 (IET Wiring Regulations) Regulation 510.3 places specific responsibility on the installer, requiring that assembly manufacturer’s instructions are taken into account.( meaning adhered to)

 

[Sparky704]

BS 7671 (IET Wiring Regulations) Regulation 510.3 places specific responsibility on the installer, requiring that assembly manufacturer’s instructions are taken into account.( meaning adhered to)

Basically if you installed a shower & somebody got electrocuted , they may try to sue the manufacturer. An investigation would take place & the manufacturer would void their guarantees as the installer did not follow the install guidance.Then the installer would be in court with the BS regulation I have referenced being used to incriminate them. RCD for a shower is a must. I’ve attended a live hose in the past

 

[brianmoooore]

I've installed a few electric showers without any form of RCD protection. Mainly because, at the time, few would have known what a RCD (or RCCB) was, let alone find somewhere l could buy one from.

 

[telectrix]

BS 7671 (IET Wiring Regulations) Regulation 510.3 places specific responsibility on the installer, requiring that assembly manufacturer’s instructions are taken into account.( meaning adhered to)

taken into account does not mean adhered to. what if the instructions are incorrect, like fitting a 3A fuse to a bathroom fan to protect the fan assembly itself? we protect the cable/s accordingly. if the fan itself needs protection then it should be incorporated within the fan.

 

[Sparky704]

C2 MAY be perfectly justified. But I disagree it IS justified.

we code to the guidelines layer down. Nowhere does it say in any guidelines or regs lighting circuits without RCD protection in domestic are potentially dangerous.

other factors in the lighting circuit may justify having the lighting as C2 but not just being without RCD protection.

it’s down to the individual tester. Yes but within the guidelines.

I hate showers without rcd protection, but I don’t give them a C2. I can’t. Unless another issue arises that justifies it.

I've installed a few electric showers without any form of RCD protection. Mainly because, at the time, few would have known what a RCD (or RCCB) was, let alone find somewhere l could buy one from.

The regulations changed when the 17 edition was enforced

 

[Sparky704]

taken into account does not mean adhered to. what if the instructions are incorrect, like fitting a 3A fuse to a bathroom fan to protect the fan assembly itself? we protect the cable/s accordingly. if the fan itself needs protection then it should be incorporated within the fan.

If the instructions are incorrect the liability is with the manufacturer

 

[Sparky704]

If the instructions are incorrect the liability is with the manufacturer

You are responsible up to the point of utilisation, the 3 amp fuse is the point of utilisation.As I said before if you install the fan & manufacturer instructions state a 3 amp & you leave the 13 amp in the fan it seizes & catches fire due to an overrated fuse, you are liable under the health & safety act where it states “ you are responsible for what you do”

 

[telectrix]

You are responsible up to the point of utilisation, the 3 amp fuse is the point of utilisation.As I said before if you install the fan & manufacturer instructions state a 3 amp & you leave the 13 amp in the fan it seizes & catches fire due to an overrated fuse, you are liable under the health & safety act where it states “ you are responsible for what you do”

my point entirely. if a fan seizes, it should incorporate protective device/s to counter this. we should not have to provide protection for their poor quality design. it's like having to fit an automatic gas cut off valve should a chip pan catch fire.

 

[Deleted account]

You can justify a code 2 for a shower as the manufacturing instructions will insist on RCD protection & BS7671 stipulates that manufacturing instructions have to be adhered too.

I generally don’t look at manufacturers instructions when doing EICRs.

 

[Lister1987]

Interesting discussion. On the subject of coding:

BS7671 does a reasonable job of telling us how an installation should be. It doesn't, IMO, do a very good job of telling us why an installation should be like that, and what dangers result from a particular non compliance or defect.

Forgive me Pretty Mouth but if we as Electricians can't summise dangers of non-compliances (or why regulations are the way they are, why they came to be) then I can't help but think we need to put down thr tools, hit the books and learn and understand.

A mechanic for example, will generally know and understand why and what defects are highlighted in an MOT, or the MOT Requirements.

It does give excellent points for discussion and peer development however

 

[Pretty Mouth]

Forgive me Pretty Mouth but if we as Electricians can't summise dangers of non-compliances (or why regulations are the way they are, why they came to be) then I can't help but think we need to put down thr tools, hit the books and learn and understand.

Sigh.

I expect comments such as this perhaps from some of the more jaded members of our community, but it's disappointing to see it coming from a newcomer such as yourself. At best it serves to irritate, and it adds absolutely nothing to the discussion.

Nobody knows everything about our work. There are some people who know a lot, a heck of a lot. There are even some people who think they know it all. But nobody, absolutely nobody knows it all.

 

[Lister1987]

Sigh.

I expect comments such as this perhaps from some of the more jaded members of our community, but it's disappointing to see it coming from a newcomer such as yourself. At best it serves to irritate, and it adds absolutely nothing to the discussion.

Nobody knows everything about our work. There are some people who know a lot, a heck of a lot. There are even some people who think they know it all. But nobody, absolutely nobody knows it all.

Im not suggesting everyone know everything, what I'm saying I would like to think the vast majority on here would take time to get understanding of something so fundamental.

I'm curious as to why it comes as a disappointment to you? We are always learning and further our understanding are we not? If we're not trying to understand why we do certain things then we are just blindingly following a book no?

I'm all for discussion with peers, even as a newcomer I have plenty of time for those that have been on that tools since Tesla was an itch on his dad's testicles cough @telectrix .

 

[Lister1987]

Sigh.

I expect comments such as this perhaps from some of the more jaded members of our community, but it's disappointing to see it coming from a newcomer such as yourself. At best it serves to irritate, and it adds absolutely nothing to the discussion.

Nobody knows everything about our work. There are some people who know a lot, a heck of a lot. There are even some people who think they know it all. But nobody, absolutely nobody knows it all.

Im not suggesting everyone know everything, what I'm saying I would like to think tht vast majority on here would take time to get understanding of something so fundamental. If you don't understand Part 4, how can you implement it's protective measures?

Interested to know how/why I've disappointed you as I enjoy peer discussion.

 

[loz2754]

Forgive me Pretty Mouth but if we as Electricians can't summise dangers of non-compliances (or why regulations are the way they are, why they came to be) then I can't help but think we need to put down thr tools, hit the books and learn and understand.

A mechanic for example, will generally know and understand why and what defects are highlighted in an MOT, or the MOT Requirements.

It does give excellent points for discussion and peer development however

From where I'm sitting, the point @Pretty Mouth made was in line with the point you are making, which is this:

The regulations tell us what we need to do but very little on how to do it, so we call upon our own training and experience, and that of others on forums like this and other available information such as best practice guides. Then we are in a position to make informed decisions when it comes to coding.

So why the somewhat harsh tone?

 

[pc1966]

You are responsible up to the point of utilisation, the 3 amp fuse is the point of utilisation.As I said before if you install the fan & manufacturer instructions state a 3 amp & you leave the 13 amp in the fan it seizes & catches fire due to an overrated fuse, you are liable under the health & safety act where it states “ you are responsible for what you do”

This 3A fuse will allow 8A (i.e. around 1.8kW within the fan) for around 2 minutes, but somehow will stop a fire?