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Response Form
PART 4
Response form for the consultation on the proposed new
Building Regulations requirements and approved guidance for electrical safety
Respondent Details Please return by 13 SEPTEMBER 2002 to:
Name: Richard Howard Andrew M Brown
Organisation: Chartered Institution of Building Building Regulations Division
Services Engineers (CIBSE)
DTLR
Address: 222 Balham High Road Zone 3/D2
Eland House
Bressenden Place
Town/City: London London
County/Postcode: SW12 9BS SW1E 5DU
Telephone: 020 8772 3623 020 7944 5756
Fax: 020 8673 3302 020 7944 5739
E-mail: rhoward@cibse.org Andrew.Brown@dtlr.gsi.gov.uk
Organisation type (tick or X one box only)
Academic/ Research Lobby Group
Architect/ Architectural Technologist Local Authority – environmental health
Building Control Body Local Authority – other
Charity Manufacturer
Consultant Media
Developer – commercial Professional Body X
Developer – dwellings Property Funder
Engineer (civil/ structural/ mechanical) Property Management
Government Department/ Agency Test Body/ Association
Housing Association Trade Association
Individual – professional Warranty Provider
Individual – member of the public Other
Is your response confidential? Yes No X
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Response Form
Questions on Legislative Proposals
1. The proposed Requirement
1.1 Is the proposed Requirement sufficiently clear on the hazards to be addressed and the means
by which the risk of exposure to them can be controlled?
Yes.
2. The proposed Limits on Application of the Requirement
2.1 The aim is to limit application to fixed electrical installations in dwellings. Are these proposed Limits
on Application of the Requirement satisfactory?
Yes.
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3. Proposed approach
3.1 Making electrical installations a controlled service would mean that all prospective electrical installation
work would need to be notified to building control bodies unless it is carried out by prescribed persons
or it comprises certain types of minor work (see paragraph 6 below). Do you consider that this
approach is likely to prove effective?
No, but another approach such as an up-to-date “Electrical Installation Certificate” as part of the
conveyancing requirements when people buy or sell a domestic property will be more effective. The
majority of unsatisfactory work is at the DIY end of the market and makeshift repairs will be
unaffected or the legislation would be ignored.
3.2 The Department together with BRAC did consider another option which would reduce the
administrative burden by limiting application of the Requirement to electrical installation work in
connection with building work as currently defined by the Regulations. This option was set aside
because it was felt that it would miss a large proportion of the types of electrical installation work in
dwellings. Do you consider that this or another approach would be more effective than the one
in 3.1?
No, but see comments for item 3.1.
If you have other approaches to suggest, please include them in ‘other comments’ at box 12.
3.3 The Department considered with HSE and DTI consumer safety Divisions the possibility of defining the
prescribed persons mentioned in question 1 by new legislation along the lines of the Gas Safety
(Installation and Use) Regulations. These regulations control who may undertake gas installation work
by identifying Approved Classes of Persons (the CORGI scheme is the only approved class for gas
installation work at present). However after comparing the gas and electrical hazards and the risks of
exposure, and taking account of the Electricity at Work Regulations that already cover the workplace,
we have taken the view that a less rigorous approach of allowing approved competent persons to self-
certify compliance with the Building Regulations is more appropriate for electrical installation work in
dwellings. The hazards and risks are covered in the Regulatory Impact Assessment. What are your
views on this matter?
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Response Form
CIBSE agrees with the concept of suitably qualified persons being able to self certify and welcome the
proposed electrical installation industry scheme. However, the wording in the model completion
certificates included in the document does not require such a formally suitable qualified person for
major commercial/industrial work so it is difficult to justify it for domestic work. The relevant
wording in the model certificates is ”I being the person responsible for the Design, Construction,
Inspection & Testing of the electrical installation (as indicated by my signature below), particulars of
which are described above, having exercised reasonable skill and care when carrying out the Design,
Construction, Inspection & Testing, hereby CERTIFY that the said work for which I have been
responsible is to the best of my knowledge and belief in accordance with BS 7671: …….., amended to
………. (date) except for the departures, if any, detailed above.” It is our view based on experience
that for many domestic installations a competent householder after reading and following relevant
published material or even just BS 7671 could reasonably sign this certificate. This is a conflict that
needs to be resolved.
There is a concern that the small electrical contractor who is currently outside any voluntary
regulatory scheme now, may shelter behind such clauses as BS.7671:2001, clause 120-02-01 with
respect to innovative designs and materials. It is not clear whether the proposals are for approval of
persons, firms, or persons within firms.
4. Application to extension of existing electrical installations
4.1 The proposals include changes to Regulation 4 which mean that, for electrical installation work,
existing installations must be altered to the extent necessary to supply extensions safely. Are these
new provisions sufficiently clear?
No, the inclusion of Inspection and Testing by an approved competent person must be included in the
provision to guarantee safety.
In addition, the status of Appendix C is not clear. Is it intended that alterations to circuits including
any features included in Appendix C should require the replacement of all equipment not complying
with current standards?
The requirements for extensions to existing installations would benefit from further clarification.
CIBSE strongly supports measures that might reduce the risk of loss or damage to buildings and their
contents by fire and smoke as well as personal safety. However, it is not clear within the Regulations
to what extent existing electrical installations will be required to comply with BS.7671:2001. In many
cases, in order to preserve the character and integrity of historic buildings for example, it is highly
desirable, to retain original fixtures and fittings such as luminaires, control switches, outlets etc.,
which may have been installed to earlier versions of the current IEE Wiring Regulations (or none at
all). Where such situations arose competent and experienced electrical engineers would be
recommended and NICEIC enrolled contractors who are able to resolve any infringement of the
Regulations in ways which achieve a result that is no less safe than required by the current
Regulations.
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Response Form
Questions on Section 0
5. Proposed Performance Requirement
5.1 This indicates that the legal requirement would be met by compliance with the fundamental principles
given in CENELEC Harmonisation Document HD 384.1, as promulgated in the UK by Chapter 13 of
BS 7671: 2001. Is the paragraph a sufficiently clear distillation of the safety requirements and
the fundamental principles in Chapter 13?
Yes, but it is difficult to understand by ordinary persons who have very little training or experience in
electrical installation and maintenance works. The term Approved Competent Person should be
included in the Performance Requirement
CIBSE recommends that the second sentence of clause 2 be changed to “For the purposes of Building
Regulations a fixed electrical installation means those parts of the assembly that are fixed to the
building fabric or permanently wired to parts of the assembly that are fixed to the building fabric.”
This will cover such things as socket outlets and lighting within kitchen units and installations in
detached garages.
With respect to the proposed performance requirements where functionality is interpreted as the
correct operation of controllers, switches and protective devices to achieve safe protection of the
installation, i.e. compliance with appropriate disconnection times, this should be included.
Where functionality infers the correct operation of fixed appliances, customer supplied/specified
components or other components or operations which have no bearing on the safety of the building or
personnel, this should not be included.
Both BS.7671:2001 Clause 13 and the new proposed Regulations stress the importance of designs and
competent designers. For specialised fields of electrical services, innovative designs are frequently
beyond the capability of ordinary electrical contractors as the designs usually require specialist
solutions. It is not clear whether, in the completion of the full electrical installation certificate on page
53 and page 54, the designer (who may be independent of the electrical contractor) will need to be
assessed as a competent person by an accredited agency to EN40011/15. It is unlikely that electrical
contractors will underwrite specialist designs and designers when completing the test certificate.
Unless all parties responsible for a completed electrical installation are assessed, independently, as
competent then the final result may be lacking.
5.2 The approach in BS 7671 is not to address safety directly but to ensure that installations are built in
accordance with technical equipment, installation standards, and methods of inspection and testing
that, as a whole, are considered by experts to achieve a satisfactory degree of safety. Would you
prefer the performance requirements to be identified more specifically and/ or could they be
identified more effectively in another way?
The approach in BS7671 is adequate for the requirements. Any other performance requirements will
run the risk of confusing the person carrying out the electrical works or contradicting BS7671.
More worked examples of a minimum standard would help reinforce a minimum level of safety.
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Response Form
6. Work that need not be notified
6.1 Work self-certified by competent persons. The proposals allow that prescribed persons could self-
certify compliance of their electrical installation work with the Building Regulations. Would it be
sensible to enable non-prescribed persons to decline to notify electrical installation work if it is
to be certified at completion by someone who is prescribed?
Unless there is to be effective policing of this provision, it is of little use since, without a perceived
need to do so, non-approved persons are unlikely to bother to pre-notify. CIBSE do not believe that it
is possible to police it effectively through the building control route, unless there is a significant
financial penalty at the time of depositing of the certificate. However, such a penalty might simply
discourage deposition of certificates.
We do not believe that it is possible to certify a completed installation as complying with
BS.7671:2001 without regular inspection and testing during the installation erection, together with an
examination of designs, calculations and test results.
6.2 Minor work. The proposal to exclude minor work from the requirement to notify stems from
considerations of enforceability, and the improvements in safety that could be achieved compared with
the administrative effort needed. Are you content in principle that minor work need not be
notified? Are you also content that the definition of minor work is sufficiently explicit ?
No, if any work involves making new live and protective conductors or terminals that involves
stripping off basic insulations - these ought to be notified, inspected and tested. Only the assembling
of prefabricated wiring systems1 and fully type-tested factory-built-assemblies will not require giving
prior notice or immediate inspection and test.
We share the department’s sceptical view that minor work would be enforceable but doubt whether
this DIY and ad hoc activity is as benign as described in the response form. Some concern is
expressed that the additional cost and bureaucracy of the proposed scheme together with publication
of diagrams (Appendix C to Approved Document P) and the promulgation/endorsement of DIY
booklets and leaflets will stimulate the DIY and black economy and result in complying contractors
becoming more expensive and less competitive.
6.3 Certification of minor work. Paragraph 5.2 in the draft AD defines minor work for the purposes of the
Building Regulations and gives guidance on the use of the Minor Electrical Installation Works
Certificate system How might the testing and certification requirements for minor work be
improved?
1
e.g., the surface fixing of a prefabricated 5 feet multi-socket outlets extension unit to increase the number of
socket outlets in the same room.
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Response Form
Paragraph 5.2 does not require notification of minor work. Therefore the subparagraphs are
pointless and would be ignored by most people. A more useful approach would be a requirement for a
Minor Work certificate to be completed for all minor work and retained by the client (useful for any
eventual seller’s pack). As noted above, a competent householder could sign the certificate with no
qualms. Subparagraph 5.2.3 should be retained.
The inclusion of minor work certificate in Appendix B can be dated as and when BS7671 is being
amended. Item 5.2.2 appears to legally endorsing a number of DIY manuals and imply that by
extracting a small part of the materials given in the DIY manuals, a number of DIY leaflets from DIY
stores can instruct unskilled ordinary person to carry out electrical installation work without the
direct supervision of an approved competent person - this absolutely contradicts the fundamental
safety principles given in BS7671 and The Electricity at Work Regulations 1989.
BS7671, the IEE On site guide and IEE Guidance Notes are only meant for the adoption of
electrically skilled and instructed persons. They are unsuitable for DIY work adoption. E.g., a lot of
inexperienced electricians have been injured by ‘borrowed neutrals’, there is no mention in even the
IEE On Site Guide as to how to test and re-test to assure that a circuit is actually completely isolated
from the source of energy before carrying out the ‘minor works’. It was left for the Approved
Competent Person to take the necessary precautions to ensure his or her own safety.
6.4 List of minor work. Table 1 is intended to be an exhaustive list of the types of minor work that need
not be notified. Are you content with this approach and are there other types of work that you
would wish to see listed?
No, the list is far too relaxed and will present dangerous risks for ordinary persons. Since they all
have to access live parts/terminals of the 230V electrical systems, the work ought to be supervised by
an approved competent person if he or she is not the person who carried out the work. Only the
assembling of prefabricated wiring systems and fully type-tested factory-built-assemblies will qualify
as an item in Table 1.
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Response Form
Questions on Section 1
7. Design, installation, inspection and testing
7.1 Technical guidance. Section 1 of the draft Approved Document gives the technical goals established
in BS 7671 and makes reference to other publications that give detailed technical guidance on ways in
which the goals can be achieved. The diagrams in Appendix A are intended only to indicate the sorts
of electrical services encountered in dwellings, some of the ways they can be connected, and the
complexity of the wiring and protection systems necessary to supply them. Are you content that this
approach, rather than detailed technical solutions, is satisfactory?
No, this approach is unsafe and potentially dangerous for the untrained DIY enthusiasts. Since
Appendix A does not contain all the possible electrical works, and the diagrams are only intelligible to
an approved competent person or an instructed person under the supervision and guidance of an
approved competent person, the inclusion of such examples will create a false sense of security and
competence in untrained persons about to carry out any electrical works. It will be better to replace
this Appendix with the following sentence:
“Typical diagrams of arrangements for the supply of electrical appliances, earthing and
bonding with an electrical installation can be found in Guidance document - e.g. the Pictorial
Index section in the IEE On Site Guide. However, the IEE On Site Guide is only a simple guide
to the requirements of BS7671 and persons who perform any electrical works should consult
BS7671 to satisfy themselves of compliance.
1
It is expected that persons carrying out work in accordance with the IEE On Site Guide will be
competent to do so – i.e., an approved competent person.
e.g., the surface fixing of a prefabricated 5 feet multi-socket outlets extension unit to increase the number of
socket outlets in the same room.
7.2 Should we make electrical installations in dwellings more resilient against flooding, in what
circumstances and how best might this be done (see Section 1 paragraph 8)?
Yes. In addition to the proposed paragraph. For any new built dwellings, either the Electrical Installation
working drawings detailing any special provisions/precautions which have been prescribed in the event of
flooding should be submitted to Building Control for approval or the arrangement is self-certified by an
approved competent person.
It should be borne in mind, however, that applying requirements to all dwellings would incur considerable
unnecessary cost as many dwellings will not be in areas at risk of flooding. The Environment Agency has
maps which could be used as a basis for requirements for dwellings at risk. The obvious principle is to use
distribution routes above likely flood level, such as above ground floor ceilings, as routes within walls are
both more difficult and create a higher risk of damage.
7.3 Will the forthcoming Electricity Safety, Quality and Continuity Regulations 2002 have a bearing
on the proposed limits on application in this consultation (see Section 1 paragraph 9)?
Yes. This can readily be satisfied by the owner of the premises to produce the latest certification of the
installation in compliance with BS7671 certified by an approved competent person.
The main bearing of the Electricity, Safety, Quality And Continuity Regulations will be in the
responsibility for providing an efficient main earthing terminal. For many buildings located in rural
or isolated positions, the provision of a secure earthing terminal by the electricity supplier, (especially
in TT installations) would significantly increase safety in these properties
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Response Form
7.4 Technical references. The references in the draft Approved Document comprise BS 7671: 2001, the
IEE On-site Guide, and a set of IEE Guidance Notes. Bearing in mind that much electrical work is
carried out in DIY projects (see the Regulatory Impact Assessment), it has been considered prudent to
include DIY manuals in the references. Appendix B contains blank copies of the BS 7671 and IEE
certificates that builders and householders might otherwise find difficult to get. Are you content that
the references given, the acceptance of DIY manuals, and the inclusion of blank forms is
satisfactory?
No, the inclusion of items 10.1 to 10.6 inclusive is unsafe and potentially dangerous for persons who
are not certified competent. Items 10.1 and 10.2 have clearly stated that (See the fourth paragraph in
the IEE On Site Guide Preface) it is expected that persons carrying out work in accordance with these
two items will be competent to do so – i.e., an approved competent person.
This paragraph should be replaced by a sentence merely to refer the readers to Part 1 of BS7671 in
which Chapter 13 the Fundamental Principles guarantee the safe functioning of the resulting
electrical installations
The IEE Publications should remain the only primary guidance and standard material. The
disincentive to their use is the cost (as with most other British Standards) which is generally believed
to be significantly overpriced. Those who rely on DIY manuals, DIY store instruction leaflets,
magazines and similar publications (including ‘reader’s tips’) may generally result in misguided or
inferior installations.
7. Design, installation, inspection and testing (continued)
7.5 Accessibility. The draft Approved Document contains guidance on the accessibility of socket-outlets
and protection devices (fuses, circuit breakers and residual current devices). Is this guidance
satisfactory?
This would be better covered by Part M with a reference to the need to comply with Part M during
any work, rather than citing just one provision of Part M. This need not conflict with any eventual
aim of spreading the content of Part M through the other parts of the Building Regulations.
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Response Form
Questions on Section 2
8. Material alterations
8.1 Technical goals. Paragraph 19 in the draft Approved Document gives guidance on how to comply
with the proposed new version of Regulation 4 (see box 4 above). Are you content that the guidance
is sufficient?
Yes. However, a general statement should be included – “Material alterations should normally be
carried out only by an approved competent person”.
The guidance is generally sufficient bearing in mind that, for important historic buildings, flexibility
will be required inevitably.
Questions on Appendix A
9. Appendix A: Diagrams and notes
9.1 The purpose of these is to give readers who are not qualified in electrical engineering information
about the scale and complexity of the electrical installations commonly to be found in dwellings,
whether newly built or upgraded to modern standards. They are not intended as substitutes for the
detailed technical guidance given in the references listed in paragraph 10 of the draft Approved
Document. Are the diagrams and notes clear and comprehensive enough, and how might they
be improved?
These may be suitable for qualified electrical personnel, but need to be more detailed information for
DIY. Diagram 1 is too compressed and is difficult to read and understand.
We offer the following comments on diagram 1:
1 The bedroom with shower cubicle should show the zone 3 limit.
2 The bathroom should show zones 1 and 2.
3 It is very unusual for a central heating system to be on the first floor.
4 The garage socket outlet should be protected by an RCD but the garage lighting should
not be on this RCD protected circuit. It is difficult to see how this can be achieved in the
example.
The diagrams may also result in contradiction and confusion with other guidance materials. The
Appendix can be improved by referring the readers to an authoritative guidance document – e.g. the
IEE On Site Guide
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Response Form
Questions on Appendix C
10. Appendix C: Guidance on older installations
10.1 Appendix C offers guidance on the types of older installation that might be encountered in alteration
work and what improvements may be needed. Is there any other information that you believe
should be included in Appendix C?
The status of Appendix C is not clear. The materials given in this Appendix appears to suggest that
the new Building Regulations Part P is intended to function partly as an electrical installation guide
which should be left with the IEE, CIBSE, NIC-EIC and ECA bodies.
It would be useful to include information on past and current changes in the colours of conductors,
especially in view of the changes currently coming into force and the confusion and danger the
changed use of black may cause.
One page 67, in the section on non-13 A socket outlets, not all such socket outlets received unfused
plugs. There was at least one widely used system where one pin actually consisted of a cartridge type
fuse.
There could usefully be a reference to the use of former gas piping as conduit in dwellings converted
from gas to electric lighting.
This Appendix presents a number of examples of ‘safety hazards’ and implies that electrical
installations designed and installed to earlier editions of the IEE Wiring Regulations are unsafe.
Just a Appendix A is designed to be consulted by ‘non-electrically qualified persons’ so Appendix C
will become a reference document, easily misinterpreted and could be of great concern to owners and
curators of historic properties, for example:
a) The ability to distinguish between main earthing, supplementary earthing and equipotential
bonding.
b) The use of PME or other supply means to a dwelling.
c) Double pole fusing. This has been a common feature in many historic buildings which sometimes
employ historically important and rare fuse boards. The none-compliance can be easily rectified.
d) Non-standard round three pin socket outlets. These are commonly used, normally a 5 amp
version, for lighting and standard lamp outlets in historic buildings. Provided that they are
correctly connected in the system they are perfectly safe. The consultation document, in its
seeming condemnation of round pin socket outlets could be easily misinterpreted.
e) Green sleeving or unprotected protective conductors produce a minimal risk which appears to be
overstated.
f) Accessories on wooden mounting blocks. These blocks, in plain or decorative form feature in
many older buildings and represent an integral part of the internal décor. The reference in
BS.7671:2001 clause 521-05-01 relates to ignitability characteristics P of BS.476 Part 5. I
understand that this Standard is unclear and possibly subject to revision. In any event my
research shows that the vast majority of mounting blocks and pattresses were manufactured of
teak with oak and mahogany as options together with, of course, fibrous plaster and metalwork.
There is no record of these mounting blocks or pattresses ever causing a problem and contend
that they comply, in all respects, generally.
g) Metric Cables There is no evidence that the continued use of imperial sized cables present any
danger. It would be most unusual if Voltage drop mentioned in the Consultation Document
would have any significant safety implication. Whilst the number of appliances connected to old
installations has increased the individual load per outlet has usually been minor, e.g lamps,
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Response Form
computer terminals, communication equipment etc.
h) TRS/VRI/Lead Sheathed Cables. The section correctly identifies those cables as a possible source
of risk. Deterioration can occur and is sometimes the result of the loss of essential oils. Some
cables are coloured red and not always black as stated. Installations should be regularly
inspected as some undisturbed installations can show signs of deterioration and yet withstand
normal insulation resistance testing.
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Response Form
Questions on the Draft Regulatory Impact Assessment
11. Draft Regulatory Impact Assessment
11.1 Do you have any comments on the benefits and costs identified in the RIA?
The Risk Assessment is in our view problematic in paragraph 19, as there is much anecdotal evidence that fires which
cannot be attributed to any particular cause tend to be attributed to an electrical origin. This means that the figure of
12,500 is unreliable. However, since this affects mainly the figure for fire damage to property it does not affect your
major conclusion. It is somewhat surprising however that your RIA excludes the cost of fire damage to property since
it should surely include all costs and benefits resulting from the proposed legislative change.
The following labour rates are suggestions of the CIBSE Electrical Services Group:
The electrical working industry under the guidance of NIC-EIC or ECA may produce a
standard (labour cost) price list for electrical works2 that must be carried out by approved
competent persons:
a) addition of socket outlets including self-certification and testing – f20.00 per circuit
b) addition of lighting outlets including self-certification and testing – f20.00 per circuit
c) addition of extra lighting or socket outlet circuits including self-certification and testing –
f35.00 per circuit
d) Annual inspection and testing including the issuance of BS7671 certification – f40.00 per
dwelling
The proposed Building Regulations will place a duty of care on the approved competent
persons and they will be legally accountable for the safety of all the electrical installations in
England and Wales. It is therefore necessary for such approved competent persons to
undertake certified training and pass appropriate tests/assessments. The benefit of this new
Regulation will be improvement in the quality of the electrical workers in the industry. If there
is enough work in society creating a continual demand for more workers, it will attract the
younger generations back into this important industry and reverse the downward trend of less
and less people engaged in this particular skill base. This will eventually maintain a large skill
base in electrical safety works in our society.
Self-Certification by approved competent persons in electrical installation work is already successful
in commercial and industrial premised and ought to be adopted for domestic premises too.
2
The work will involve disturbing the fixed wirings systems. E.g., cutting into existing wires to install junction
boxes or pulling single-core cables in conduits.
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Response Form
11.2 The Department will be carrying out a survey of the impacts these proposals would have on
small businesses during the consultation period, as indicated in paragraph 49 of the draft RIA.
If your company would be willing to participate in this survey please let Andrew Brown know
within the first two weeks of the consultation period. His contact details are in a letter at the
front of the consultation document. The aim is to select about five firms for the survey, so there
can be no guarantee that expressions of interest will be taken up.
Not applicable to CIBSE.
Other questions
12. Other comments
12.1 Do you have any other comments?
The guidance on positioning of power sockets and light switches in a defined horizontal and
vertical bands leads to their being installed back to back in adjacent rooms. This can serious
affect sound insulation between the rooms.
The inclusion of minor work certificate in Appendix B can be dated as and when BS7671 is being
amended. NIC-EIC and the ECA also have their versions of minor work certificates and other
format of certification equally acceptable to Electricity at Work Regulations and BS7671. The
inclusion of such examples may result in contradiction and confusion with other guidance
materials offered by these professional bodies at a later date.
Many of the information, technical terms and diagrams can only be interpreted correctly by an
approved competent person, a large number of the diagrams and certification forms are
duplicating information already contained in authoritative document the Electricity at Work
Regulations refer to. The Building Regulations should not take up the role of providing examples
and illustrations on electrical installation arrangements. Appendices A, B and C are far too
technical for the electrically unskilled and should only make reference to authoritative guidance
document for further information.
The one important question that must be asked to a large number of Approved Competent Persons
– did they ever have received an electrical shock while carrying out electrical work as given in the
present list of minor works, we believe that at least over 60% of them would have replied yes. Can
we afford the general public ordinary persons be exposed to such risks?
If the intention of the proposed Building Regulations is to permit “ordinary persons3” to carry out
minor electrical works, a suggested list of minor electrical works is as below:
Description Mandatory Protective
Item measures to be adopted
3
An ordinary person is defined as a person with little technical knowledge or experience to enable him or her to
avoid dangers which electricity may create.
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Response Form
1 Replacement of ceiling roses by following the
colour codes of cables
2 Replacement of 13A socket outlets/light switches Isolation of Main
by following the colour codes of cables Switch and carry out
3 Replacement of 13A fused-outlets by following appropriate
the colour codes of cables Voltmeter tests before
4 Addition of lighting outlets by a plug-in type making contact with
pre-fabricated4 wiring system live conductors
5 Addition of 13A socket outlets by a plug-in type
pre-fabricated wiring system (prohibited in
bathrooms and locations containing a shower
cubicle -under the current edition of
BS7671:2001)
The basis of the above list is that they do not require testing or inspection and any additional
wiring can be removed safely and relatively quickly should it be proved to be functioning
incorrectly.
It should be noted that BS7671 will be amended from time to time to take into account of further
progress of the international work and other research developments, the proposed Building
Regulations must not directly or indirectly prescribe any electrical installation arrangements that
may conflict with such future developments, e.g., the already agreed EC harmonization of cable
colours of fixed wirings, the likely adoption of permission of adding 230V 13A socket outlets in
bathrooms.
The success of the Proposed Building Regulations Part P will be largely dependent on self-
certification by approved competent persons. The CIBSE Electrical Services Group welcomes the
Self-Certification Process by approved competent persons. It is suggested that Part P should
contain the clauses on page 6:
Electrical Installations
A. All works involving electrical installations must be carried out by approved competent persons
who are suitably qualified and can produce documented evidence to substantiate this.
B. All works carried out must comply with the latest BS 7671 Requirements for Electrical
Installations (I.E.E wiring regulations 16th edition).
C. Full circuit diagrams, certification and test results to be provided to the owner of the dwelling by
an approved competent person for any electrical additions, alterations and to existing
installations.
D. Full circuit diagrams, certification and test results to be provided for any new installations, these
must be signed and produced by an approved competent person carrying out the installation.
E. All certificates must be BS7671 approved forms showing the approved competent person
qualifications1 and capacity 2.
4
A plug-in type pre-fabricated wiring system is a system whereby the ordinary person will not need to disturb
the existing fixed wirings. E.g., a 5-feet long 13A multi-socket outlets extension unit plugs into an existing 13A
socket outlet with the flexible cable fixed above the skirting behind a sofa will provide extra socket outlets for
the living room safely. To comply with BS1363, the multi-socket outlets extension unit would has already
passed the insulation test, continuity test, polarity test and is protected by a 13A fuse against overcurrent as well
as electrical shock situations.
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Response Form
Qualifications should be specifically related to electrical installations. E.g., Individuals who are CEng/EurIng registered
members of CIBSE or IEE, Contractor firms who are fully paid up members of either N.I.C.E.I.C or the E.C.A.
2
Capacity should be in one of the following categories: Consulting Engineers or Installation Contractors or others approved
by Building Control
There is some scepticism about the proposals in general among some CIBSE members. The risk to
loss of life from the fixed installation is relatively small and any savings completely unpredictable.
One view is that the result will be for a large number of contractors to ‘disappear’ from the market
and transfer to the black market.
In order to improve safety then all aspects of electrical installation work and subject inspection and
test need addressing. The draft Specification for ‘Competent Electrical Contractors’ and ‘Competent
Registration Schemes’ concentrate on contracting and does not cover independent designer
competency or their associated costs.
Page 16 Paragraph 6. The proposals define the fixed installation as including cookers/ovens/shower
fittings etc. BS.7671:2001 applies up to the point of supply and not to the appliances themselves.
There seems to be some confusion.
Page 17 Paragraph 8. It appears that the proposed new Regulations are primarily directed towards
alteration work in existing dwellings. Electrical safety is covered by the Electricity At Work
Regulations which imposes obligations on both electrical contractors and property owners/occupiers.
The direction of this proposed legislation is solely towards contractors and would only be partially
effective. It duplicates the obligations placed upon contractors since both existing and proposed
Regulations involve compliance with BS.7671:2001.
Page 17 Paragraph 9., Contrary to the assertions in this paragraph the proposed requirements are
unclear upon the obligations for designs and designers. Failure to comply with BS.7671:2001 does not
automatically mean that installations are ‘unsafe’ or ‘defective’, especially when they comply with
earlier versions of the IEE Wiring Regulations or other international Standards, e.g. USA. Problems
sometimes arise when extensions complying with BS.7671:2001 are made to older installations erected
to earlier Regulations. There seems to be a clear directive that all old installations should be brought
up to BS.7671:2001 standards.
Page 18 Paragraph 14. There seems scant evidence that, with the fall in the number of electric shock
injuries and fatalities over the past 30 years, risks have increased. Since the higher risks are
attributable to more appliances, portable and fixed, it is difficult to appreciate how the proposed
Regulations, directed to fixed installations, will improve safety significantly. Attention should be
directed towards appliances, flexible leads, plugs and adapters.
Page 18, Paragraph 17. This data is rather irrelevant.
Page 19 Paragraph 18. It is often the case that electrical fires are so described when the prime cause
is mechanical failure, mechanical friction and similar occurrences, where the standard or quality of
the fixed electrical installation has no bearing upon losses.
Page 21 paragraph 28. The by-products of these Regulations would also include:-
Additional costs to designers and consumers.
A reduction in the number of contractors in the market place.
An increase in non-pr4oductive regulatory personnel.
Additional bureaucracy and red tape.
Whilst harmonisation with Scotland may be politically beneficial, it is understood that the proposed
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scheme differs significantly from the Scottish scheme and that the introduction of the scheme into
Scotland produced no improvement in electrical safety whatsoever.
Page 21 Paragraph 29. Whilst any improvement in safety and a reduction of damage to buildings is
to be welcomed it is evident that the greater majority of injuries and losses are attributable to pure
accidents, incompetent amateur modifications, old and neglected installation which are never
inspected and tested.
Page 21 Paragraph 32. The expected improvement in quality would not ‘trickle down’ to the
grey/black economy which, by its nature, arises to avoid tax, regulation and other legislation.
Imposing more Regulations, especially where past freedoms are curtailed, and inspection/form filling
and bureaucracy are introduced, could lead to a massive increase in the black economy, especially as
those who meet the Regulations would need to recover increased costs from their customers making
them more uncompetitive.
Page 21 Paragraph 33. The use of RCDs is generally well known by the public. Greater emphasis
on the use of these together with regular inspection and testing should produce greater benefits at less
costs that the current proposals.
Page 22/23 Tables 1a/b and 2. These clearly show that the risks and benefits from appliances are
much greater than those from fixed wiring and perhaps deserve greater attention.
Page 22 Paragraph 38. This section excludes consulting engineers, engineering designers, architects
and others who may be responsible for the design/specification element of electrical installation work
and will incur costs. Is it intended that they become ‘competent designers’ able to self-certify their
element of the work under the proposed Regulations?
Page 24 Compliance Costs. These seem to exclude any cost attributable to independent designers.
Page 24 Paragraph 44. How is ‘appropriately qualified persons’ to be defined? Will electrical
contractors be expected to determine the ‘qualifications and competence’ of independent designers or
will independent designers require to be separately assessed by an organisation accredited to
EN40011.
Page 25 Paragraph 45. Costs for sub-contracting out appear to have been seriously underestimated.
Inspection would be on site frequently to ensure no work is covered up before inspection. This
method is not an approved method by the NICEIC and could be unworkable.
Page 26 Paragraph 49. It seems only small businesses are addressed. What is the situation with
respect to larger projects, e.g. Local Authority Housing where independent consulting engineer
designers are employed?
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