wallywombat: 
 

The landlord regs as written are absolute - the house must at all times comply with BS 7671:2018; and if an EICR shows any deviation, it must be fixed within 28 days (so implicitly including C3's). This is of course stupid, so the government guidance backtracks and says it doesn't have to be perfect (so by implication you can ignore C3's). So as long as the landlord isn't in the LA's bad books, ignoring C3's is probably ok.

The writer of the EICR has a completely subjective choice about whether to code deviations from the current regs as as C2 or C3. There is no right answer. The current regs say nearly everything needs RCDs; older regs say sockets likely to be used for outdoors need RCDs; older-still regs don't require RCDs. 

If the EICR writer is aware that the report is for a landlord, then that may help influence their choice of C2 vs C3 - i.e. “is this something that the landlord deserves be fined for if not fixed within 28 days?".

That`s the exact dilemma that I was having between the older regs and the current edition. The problem is getting the compatible RCBOs for the old MEM board, which basically is not worth the money (£150 for 3 RCBOs is a bit silly price). I see in this case be best to change for the new board altogether with everything in place then.

Chris Pearson: 

The acid test must be whether or not you would be happy with no RCD protection in your own home.

I have a similar take, would you be happy about your kids living in this house or flat?

Install a new R.C.B.O. consumer unit, they are not expensive these days. You know it makes sense. Do it correctly and then all can sleep soundly at night. Oh, and R.C.D. protection is not all about appliances plugged into sockets; it covers more than just that.

Z.

You have to discuss it with the customer. A single RCD in the tails is perfectly compliant and costs £30. Why all this “RCBOs SPD New CU etc”? It may be a bit inconvenient, but IF you have done the EICR correctly, it will only trip if there is a significant problem. It has never been a requirement to “update” every installation in the country at each amendment", if it was then JPEL/64 would be subject to legal and intense scrutiny for “vested interests”. The landlord legislation is very badly drafted, although the intention may be good.  

First off, there has to be accessible tails to insert an upfront RCD, within flats this is rarely possible as they are usually concealed. 

Secondly, regardless of if you are inserting an upfront RCD into the tails or replacing the fuse board there may well be issues with isolation whilst working. 

Next there is the lack of segregation of the installation, one small issue takes everything out. 

Also whilst agreeing an all RCBO consumer unit may be over the top, who is going to sign the disclaimer for omitting a surge protection device?

Sparkingchip: 
 

There are no set rules, so you have to make a decision and be able to justify your reasons for coding it as you did.

So, is it a house with a garden and driveway where people may be using electrical gardening tools and equipment or washing a car with an electric pressure washer?

Is it a flat without access to any outdoor areas?

 

I totally agree with what Sparkingchip and others have indicated, It is your judgement, decision on coding based on your knowledge and experience of such matters taking into account standards, regulations and legislation applicable.

I agree the wording of the Landlords legislation doesnt help.

Karolis what experience do you already have of carrying out EICR's? Have you just done a handful, hundreds or thousands? have these been in residential premises, landlord premises, commercial, industrial etc? Have you attended any formal inspection and testing courses?

So forget you are doing for now this EICR on this landlords property. And you were inspecting an commercial or industrial property with the exact same age of installation, method of installation and protection methods, how would you code that installation?

GTB

What you are actually required to do is to list all the concerns as observations on the EICR, actually being expected to code them without firm guidance from “The powers that be” such as the Government as the law makers, the local councils as enforcers and the IET as authors of the Wiring Regulations which is completely unfair.

For the landlords EICRs in particular the government should have set out the expected minimum standards, which I think they thought they had done when they said the installations have to comply with the 18th Edition of the Wiring Regulations, possibly not realising that this then left people saying “well it doesn't comply with the current regulations, but it will be okay because it was okay sixty years ago at the time it was installed, so we don't need to replace the lighting circuits that don't have a circuit protective conductor or old fuse board and add RCD protection as all those issues can be given a C3 code and any electrician who doesn't agree is just trying to rip us off and create work to make money for themselves".

Sparkingchip: 
For the landlords EICRs in particular the government should have set out the expected minimum standards, which I think they thought they had done when they said the installations have to comply with the 18th Edition of the Wiring Regulations …

I don't think that they quite say that. In general terms, the law is not retrospective, so for example, my Alvis needs no direction indicators. It never has.

I wrote to my Member of Parliament and raised my concerns, I have a letter from him saying it will all be okay.

Chris Pearson: 
 

Sparkingchip: 
For the landlords EICRs in particular the government should have set out the expected minimum standards, which I think they thought they had done when they said the installations have to comply with the 18th Edition of the Wiring Regulations …

I don't think that they quite say that. In general terms, the law is not retrospective, so for example, my Alvis needs no direction indicators. It never has.

But the Wiring Regulations aren't law.  The new regulations for landlords are law, and specify the 18th edition.