EICRs and Coding

The wonderful and murky world of coding! Much debate and discussion has and is going on around coding and EICRs. We even have publications from various CPS’s and individuals with some outstanding guidance and thought-provoking content.

However….. I have an opinion as someone who has worked in this sector for a long time now. It might surprise a few and it might not!

While we can all debate should this situation be a C2, C1, FI or note we are losing sight of why we are made to even debate it in the first place. Now I know as well as many others that some really shoddy practices take place with EICRs and the discussion over coding doesn’t really involve them as usually the aim is remedials and as many C1s as possible. We know that is a load of nonsense.

I am talking about specifically those in the industry that are diligently and honestly trying to make the coding system work. I think sometimes as electricians and/or electrical engineers we can over complicate things. It should be remembered while we are producing these reports and mostly, we understand them the great many receiving them do not. We are left having to explain the coding system and why we have arrived at those codes.

A few particular aspects of this cause me concern, particularly to do with metal enclosures, fire escape routes and fireproof fixings. Now please keep in mind I am not talking about the justification for using all of these things on new installations but the approach to coding them on older installations.

If we apply the understanding of GN3 and BS7671 a lot of codes issued as code 2 for some of the above situations could and maybe often should be C3 at most. However, many of the additional guides and publications from industry bodies suggest using code 2 and give very valid reasons for doing so.

But and this is an important but for me, it puts all the liability on the coding electrical contractor and responsibility for remedial work on the client/duty holder.

I will use a motor trade analogy and I often hate these kinds of analogies, but I think it will make sense… When seat belts were introduced it wasn’t originally a reactive requirement on all older cars, however laws were introduced to make mandatory wearing of seat belts. Responsibility on owners and drivers as technology and safety standards improved. However, when a serious safety defect is identified in a car manufacturers products they often go to great expense with huge recalls. Toyota most recently had a global recall about just that. Manufacturers taking responsibility for manufacturing safety issues.

Now if we flip back on to the electrical industry are, we saying fireproof enclosures are a safety improvement and development with time? Are they a safety requirement at all? If not, why do have to install fire resistant enclosures in new installations? Or is this a manufacturing failure with poor terminations in plastic enclosures? Poor regulation, training and badging by CPS bodies? Should the liability for remedial work not lie with them or at least the survey to determine if remedial work is required lie with them? The motor industry is not waiting for MOTs to find them.

The same for fireproof fixings, is this a development of safety through time or is it a failing in the guidance and regulations gone by? Should it be the responsibility of EICR inspectors and testers to first find and then encourage rectification of such things?

Firefighter safety for example is massively important in my opinion. Entanglement is a hugely important safety issue. Is waiting potentially 5 years for an EICR the right way to approach making sure we have those measures in place? Is it the building owner’s responsibility for that if prior regulations were followed?

In my opinion the whole while we are arguing and debating should it be a C2,C3 or FI we are ignoring the real elephant in the room. Who is writing and amending these regulations? Is it those who if we are most truthful hold a large responsibility for the regulations and quality of operatives and materials? If so, surely that is a huge vested interested.

All of the liability currently is set on inspectors and testers along with clients and that doesn’t sit well with me.

Could the coding waters be muddied to divert attention and responsibility from those who should really be stepping forward to actively deal with these things?

I spoke about the use of plugs in concrete substrates the other day and the reliability of them in fire conditions. Now while we absolutely adopt best practice on new installs and do not use them. Should we be dismantling containment on EICRs to verify fixings? Are we really qualified to make judgements on what is adequate fixing for cabling, containment and accessories under fire conditions? Particularly legacy fixings that will be almost impossible to verify as per manufacturer’s instructions.

Electricians are buried under more and more regulation and grey guidance that we have to interpret and use engineering judgement. This just diverts or stops the real road of liability for me. At the moment on an EICR, particularly on large installations I would use an FI code for a structural engineer to make an assessment of legacy fixings in premises with the issue of entanglement in mind.

Going back to fire in consumer units are we saying plastic consumer units are dangerous or not? Only under the stairs or with Mrs Smith Hello Magazine collection pilled around them? Is it really up to electricians to make that judgement?

If an issue with poor terminations is in place surely a recall process of competent and able electricians verifying correct tightness of terminations would be the solution? Not simply leaving EICRs and those applying codes to argue and debate with those in the industry and clients.

It is easy to sit and say well this is clearly an xyz code or that is why it is a code 2. We can talk and discuss and back slap our own intelligence all we like. But nothing changes other than our own ego.

I am on the side of the practising electricians and will continue to be vocal in my support of them and apprentices.

We need to empower inspectors and testers to use engineering judgement and having clear concise industry guidance behind them. Give them confidence to carry out that work and not wait for the coding police to pull them apart.

Feel free to disagree, I certainly am not a know it all smart arse!