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New EICR "unsatisfactory" - complete rewire required?!?

Former Community Member
Former Community Member
The lighting circuit has no CPC (earth), this is not uncommon in older houses. For that reason all light fittings are Class 2 i.e. plastic with no metal, and there is a clause in the tenancy agreement which forbids tampering with the light fittings (this is a house we own and rent out).


Previous EICRs did not even mention the lighting circuit because of the Class 2 fittings. I have just got a new EICR with an observation "lighting circuits have little or no earth" and classification code C1 ("Danger present, risk of injury, immediate remedial action required"). The overall assessment says "Unsatisfactory" with the comment "Needs updating to current regs". This can only be fixed by a complete rewire of the whole lighting circuit.


This is pointless, there are no earth connections in the plastic fittings.


Any thoughts? Many thanks.
  • Not excusable, report the "Inspector" to body (If  registered). 


    Jaymack
  • I see no reason to rewire the lighting completely if everything is class 2, and the wiring is otherwise satisfactory. It is not compliant with BS7671 (18th) but is not in any way "Dangerous".A competent electrician would simply not fir a class 1 light fitting, or would add an Earth wire to that point. I assume that all the switches etc are also plastic and everything is mechanically protected correctly? I would code this as a C3 (improvement suggested) and so the install would be satisfactory.
  • In an earlier post on this subject, one of the replies even included chapter and verse from the book of rules to back up that this is C3.

    Definitely needs to be reported.
  • Niciec best practice guide (here) has a section 10 on fitting a new CU to an existing building without earth, which strongly recommends against it but then goes on to say it can be done if certain conditions are met.



    Edit They also have a guide to the use of codes in reports  here  and that suggests that
    Absence of circuit protective conductors in circuits having only Class II (or all insulated)luminaires and switches3

     would warrent a C3, improvement recommended.
    This code should be used to indicate that, whilst an observed deficiency is not considered to be a source of immediate or potential danger, improvement would contribute to a significant enhancement of
    the safety of the electrical installation.


    This you should have had for the last several inspections.





    To be fair to the inspector , it cannot comply with 18th edition regs (or indeed any regs since the 14th ), and arguably the new The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020
    here


    can be read in a way that does now require that for rented properties. (read it yourself and see what you think it is asking for exactly )

    The wiring presumably predates the 1966 regs change that brought in compulsory earthing for all circuits, so cannot be exactly brand new, so I presume rewiring is on the radar, but you are not intending to do it just yet. (are all the sockets. and  fittings and lampholders also pre 1966 or has new stuff been tacked onto the old installation ?).

    I agree it is probably safe for continued use, unless there are other problems, but the legal position is not as clear cut as it would be for an owner occupier , or for one that was rented last year.

    Actually I'd go further and say that the The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 may be well intentioned, but are written in a way that leaves open a large can of worms for many people, not just those with 50 year old wiring.


    As an aside it is not totally pointless to add an earth core to the cable once you have RCD protection even if it is not needed at the far end, - in the event cables or junction boxes being subject to  flood,  fire or even attack by mice, it greatly increases the chances of a safe automatic disconnection with the RCD firing before the fault becomes significant.


    regards Mike.
  • C1 would only apply if it were possible to touch live conductors.


    C2 would apply if there were any Class 1 fitting in the circuit (switches or lamp fittings) because if the line conductor came into contact with the exposed conductive parts there would be no automatic disconnection of the supply.


    So in this case C3 seems to apply and under BS 7671 18th Edn the installation has been inspected and tested and found to be safe for continued use.


    Another possible non-compliance would be the absence of additional protection (RCD) in the lighting circuit - this became mandatory in the 18th Edn. Given that a tenant may disregard the clause about lamp fittings, if there is no additional protection, a C2 could be justified. I certainly think that it would lie within the reasonable range of opinion.


    As for re-wiring the circuit, it may not be too difficult if (a) the floorboards may be taken up; and (b) the switch drops are under capping or some form of conduit.
  • There is official government guidance on the new regulations.  They advise that a C3 is acceptable and not a "fail", while C2 and C1 faults must be fixed.


    Of course the guidance isn't the law, but it's unlikely that anyone would be prosecuted if they were following the guidance (in the same was as for building regulations, which are also very vague in places).
  • I am glad that we all agree on this one. This is again an attempt at extortion, or the inspector is not competent and should be reported to his certifying body. There is far too much of this kind of thing going on, see another thread here.
  • Sorry to be a party pooper but.


    I do not believe you can use Double or Reinforced insulation in rented premises as "effective measures" for example "adequate supervision" can be ensured and writing this in to a rental agreement is not an effective measure. See Regulation 412.1.2.


    I have previously said on this forum one of my  clients has 70 warden controlled rental flats with tenancy agreements hat forbid any changes or alterations to the electrical installations. That does not stop the elderly tenants from replacing Class 1 light fittings and installing metal dimmer switches on the lighting circuit even though the circuits have a CPC I find un-earthed light fittings and dimmer switches. 


    A CPC has been required on lighting circuits since 1966 so these un -earthed lighting installations are some 54 years old so overdue  for being bought up to current standards.


    So if I found this in rented premises I would report it and code it C2 as adequate protective measures are not in place meeting the requirements of Chapter 41.


  • Former Community Member
    0 Former Community Member
    mapj1:

    arguably the new The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 here can be read in a way that does now require that for rented properties. (read it yourself and see what you think it is asking for exactly )



    I can't see anything in that that changes the interpretation of classifications.

     
    mapj1:
    Actually I'd go further and say that the The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 may be well intentioned, but are written in a way that leaves open a large can of worms for many people, not just those with 50 year old wiring.



    Quite. If it DOES change the interpretation of classifications there are going to be millions of houses that require immediate rewiring come April 2021!

     
    John Peckham:

    tenants from replacing Class 1 light fittings and installing metal dimmer switches on the lighting circuit



    Tenants should not be touching electrical installations, Class 1 or otherwise. If they do, you really cannot prevent them harming themselves. They may well be exposing live conductors.
  • JPC


    "Tenants should not be touching electrical installations, Class 1 or otherwise. If they do, you really cannot prevent them harming themselves"


    So clearly you cannot use double insulation as a method of protection as the installation is not under effective supervision?