Electrical Safety in Dwellings

7/27/2019 Electrical Safety in Dwellings

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Electrical Safety in Dwellings: summary of the results of

the 2002 consultation

ContentsProposals for new safety requirements for electrical installation work in dwellings2

Summary of responses and actions taken by BRAC...................................................4

The proposed limits on application of the requirement..............................................4

Proposed approach.........................................................................................................5

Application to extension of existing electrical installations........................................8

Proposed performance requirement.............................................................................8

Work that need not be notified .....................................................................................9

Minor work ...................................................................................................................11

Certification of minor work ........................................................................................11

List of minor work........................................................................................................12

Design, installation, inspecting and testing ................................................................14

Accessibility...................................................................................................................15

Material alterations......................................................................................................16

Appendix A: diagrams and notes................................................................................17

Appendix C: guidance on older installations.............................................................17

Draft regulatory impact assessment ...........................................................................17

Other comments ...........................................................................................................19


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Electrical Safety in Dwellings: summary of the results of the 2002 consultation

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Proposals for new safety requirements for electrical installation work in

dwellings

A summary of the results of the 2002 consultation

The Building Act 1984

The Building Regulations 2000

Part P & Approved Document P

Summary

1. This report gives summaries of the responses to the 23 questions posed in Part 4 of theconsultation document published on 21 May 2002 and the other issues that consultees raised.Interleaved with these are summaries of the actions taken by the Office of the Deputy PrimeMinister (ODPM) working in conjunction with the Building Regulations Advisory Committee

(BRAC) to take the comments and suggestions into account in the texts of the legal requirement,the Approved Document and the Regulatory Impact Assessment (RIA) which have now beensubmitted for Ministers' approval.

2. The consultation document on the proposals to introduce into the Building Regulations

requirements for the safety of electrical installations in dwellings can be viewed on this websiteunder Building Regulations and Consultation papers. The list of questions posed in the

consultation document is attached at Annex A.

3. The consultation closed on 13 September 2002 and 490 responses were received from bodies and

individuals of which:

88 were full responses to the 23 questions in Part 4 of the consultation package,

259 were received by post and e-mail, mainly from electrical contractors (206)

143 were forwarded to the Minister by MPs acting on behalf of their constituents,

including many that were from electrical contractors (142).

4. Although the document did not ask respondents to indicate overall support, of those which did,63% of the detailed responses were supportive of the proposals and another 7% were neutral.

95% of all the responses in which an overall opinion was expressed, and 81% of all responses,indicated support for the introduction of electrical installations into the Building Regulations.

5. The proposed approach in the consultation document to indirectly address safety throughreference to BS7671 was generally supported. As a means of controlling compliance with the

Regulations, there was support to make electrical installations in dwellings a controlled servicewhich would require notification to BCBs. However, many consultees were concerned at the

increased workload on BCBs and recognised that self-certification by competent persons wouldassist in alleviating this. They also supported the approach to waiving the need to notify minor

work.

Analysis of responses and actions taken

6. The ODPM received 490 responses to the consultation that took place between 21 May and 13September 2003 on the introduction of safety requirements for electrical Installations in

dwellings. However not all respondents answered all questions. Where percentages are quoted,the value is therefore based on the number of answers by respondents to that question.

7. The following definitions of groups of respondents are used in this analysis:


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Main players: includes the Joint BSI / IEE National Committee JPEL/64 responsible forBS7671, the Health and Safety Executive (both Policy and Legislation) (HSE), the

Department of Trade and Industry (DTI), Institution of Electrical Engineers (IEE), theElectrical Contractors Association (ECA), the National Inspection Council for ElectricalInstallation Contractors (NICEIC).

Government : includes the ODPM, the Department for Trade and Industry (DTI) and theHealth and Safety Executive (HSE).

Industry: includes the Institution of Electrical Engineers (IEE), the Electrical ContractorsAssociation (ECA), the National Inspection Council for Electrical Installation Contractors(NICEIC) and the Electrical Installation Equipment Manufacturers Association (EIEMA).

Users : includes the industry group outlined above plus other users of BS7671 such asdesigners, architects, the Institution of Incorporated Engineers (IIE), the Chartered Institutionof Building Services Engineers (CIBSE), the Association of Consulting Engineers (ACE), theNational Association of Professional Inspector and Testers (NAPIT), Trading Standardsdepartments, the District Surveyors Association (DSA), University Engineers, the Federation

of Small Businesses (FSB) and the Construction Industry Council (CIC).Public: includes respondents who have identified themselves as members of the public, manyalso indicate they are either electricians or DIY enthusiasts.

8. To assist readers, the questions contained in the consultation are repeated in this summary,together with the opinions expressed and how they have been taken into account. Matters raisedby respondents that are unrelated to the specific questions have been included with the responsesto question 12.


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Summary of responses and actions taken by BRAC

The proposed Requirement

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?

9. There was support (90%) that the proposed requirement was clear. Four issues were raised by a

significant number of respondents:-

electrical installations in dwellings may also supply electricity to other parts of the propertyoutside the dwelling, such as garages, outbuildings and gardens. The phrase "In dwellings"restricts the scope of the requirement and should be extended to include these outside areas.

BS7671 defines its scope as also protecting livestock; consideration should be given toinclude animals and/or livestock.

The nature of the danger is stated as fire, but shock is an equal danger and should be included.

The Regulatory Impact Assessment (RIA) indicates that portable electrical equipment is asignificant source of electrical accidents. As protective devices in modern fixed installationsimprove the protection of portable electrical equipment, their leads and the people using them,it may therefore be appropriate to reflect this in the Limits of Application.

Action Taken

10. The draft Approved Document P has been amended to include those parts of electrical

installations that are outside dwellings but fed from the same supply.

11. Animals are not covered by the Building Regulations. It is now made clear that only those aspects

of BS 7671 applying to the safety of people are relevant when seeking to comply with theproposed legal requirement.

12. The RIA takes account of some of the accidents each year that are caused by the use or abuse ofportable electrical equipment. This is because residual current devices in fixed electricalinstallations also give protection to portable appliances, their leads and people using them.

The proposed limits on application of the requirement

The aim is to limit application to fixed electrical installations in dwellings. Are these proposed

Limits on Application of the Requirement satisfactory?

13. The majority of respondents (63%) believe the `Limits on Application' were satisfactory.However the industry was divided over the mention of the Electricity at Work and ElectricitySupply Regulations (now the Electricity Safety, Quality and Continuity Regulations 2002) as thisseems to limit scope to too great a degree.

14. Other comments received included:

The definition of a dwelling was raised by several organisations, in particular the exclusion ofoutbuildings and the doubt over which Regulations would cover common areas in dwellings(such as stairs and landings in blocks of flats).

The distinction between small businesses and small commercial properties is not clear,particularly where a shop or office may be integral with a dwelling. These respondersconsider that a definition in the Regulations would assist.


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The inclusion of portable equipment in the RIA caused many comments which suggest thatthere should be a reference to portable and non-portable equipment in these Regulations,

perhaps a reference to guidance already supported by HSE would be helpful.

Comments from organisations representing small businesses suggested that the introductionof Part P would be a cost to their members.

Action Taken

15. The Requirement and Limits of Application have been amended and references to otherlegislation have been moved to a new section in the Approved Document as useful information.

16. The notes to the Requirement define that all circuits fed by the consumer unit in a dwelling arewithin the scope of Part P, and that the requirement applies to installations in gardens, shopswhich share an installation with a dwelling and to the common parts of blocks of flats.

Proposed approach

Making electrical installations a controlled service would mean that all prospective electricalinstallations work would need to be notified to building control bodies unless it is carried out byprescribed persons or it comprises certain types of minor work (see paragraph 6 below).

Do you consider that approach is likely to prove effective?

17. 61% of all respondents, and all industry respondents, supported the proposed approach. Somemembers of the public did not support the requirement that DIY work on small additions andalterations required certification by a competent person.

18. Further observations included:

DIY and ad hoc work may not be reported and hence the present standard of existing

installations, especially alterations and additions, will not be improved. An additional cost of reporting and certification may discourage additions and alterations

being reported to Building Control Officers.

Alterations may be designed in such a way as to avoid the need to report the work; this was of

considerable concern over replacements, alterations and additions to kitchens and bathrooms(on safety grounds).

Many respondents expressed a concern at the increased workload for Building ControlOfficers to effectively police these Regulations (see Section 12.2).

Action Taken

19. The approach to make electrical installation work in dwellings a controlled service has been

retained.

20. To reduce the work load on BCBs, work undertaken by persons who have been assessed as

competent through a scheme recognised by the Secretary of State, or minor work specified inTables 1 and 2 in the Approved Document need not be notified.

21. Work in kitchens and the special installations and locations given in Table 2 must be carried outby a competent person or notified to BCBs before work commences.

22. DIY work on electrical installations will be a controlled service and those undertaking the work,even minor work, are reminded in the Approved Document that their work must comply with

BS7671, including inspection testing and certification by a competent person.


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It is proposed in Approved Document P that the certificates taken from Appendix 6 of BS7671 andalready required for electrical installation work will be a means of demonstrating compliance with

Part P to Building Control (subject to further discussion under the Competent Persons Initiative).

The Department together with BRAC did consider another option which would reduce theadministration burden by limiting application of the Requirement to electrical installations work in

connection with building work as currently defined by the Regulations. This option was set asidebecause 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?

23. There was support (94%) for the proposed approach. To reduce the immediate workload onBCBs, it was suggested that the requirements should be introduced to apply to new building workfirst and that those for alterations and additions be brought into force later.

Action Taken

24. With the support from the public consultation, the proposals in the draft Approved Document Phave been recommended to Ministers as suitable for introduction into the Regulations.

The Department considered with HSE and DTI the possibility of defining the prescribed personsmentioned 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 identifyingApproved Classes of Persons (the CORGI scheme is the only approved class of gas installation workat present). However after comparing the gas and electrical hazards and the risks of exposure, andtaking account of the view that a less rigorous approach of allowing approved competent person to

self-certify compliance with the Building Regulations is more appropriate for electrical installationwork in dwellings. The hazards and risks are covered in the Regulatory Impact Assessment. What are

your views on this matter?

25. Respondents who are associated with the industry or who have working knowledge of the CORGIscheme supported the draft proposals outlined in the consultation document (75% of those whogave an opinion).

26. There were many comments on this question, they included:

A personal certification scheme (similar to CORGI) will be more bureaucratic and ineffectivethan a company-based scheme but a scheme for individuals rather than firms will besubstantially more expensive and may not be justified by the number of accidents.

There was support from users for a single recognisable identity for a competency scheme (or

body promoting the scheme) although there may be several routes to demonstratecompetency. It was further suggested that the scheme operators be defined in the Regulations.

It is likely that schemes will not improve the standard of either DIY work or work inconnection with kitchens or central heating undertaken by specialists. Small-scale operatorsmay be driven into the grey/black economy.

What is the role of the Certificate (electrical installation or minor works - see pages 49 et seqin the consultation document)? Should it be used to demonstrate to BCBs that the electricalinstallation is compliant with Part P?

Should electrical installation designers, consultants and architects be included in the

legislation as the Electrical Installation Certificate in BS 7671 requires a signature for thedesign to be compliant?

What responsibility will designers, consultants and architects have in the Part PRequirements?


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Action Taken

27. Since the publication of the draft proposals for Part P in May 2002, the ODPM have gained

considerable experience with Competent Persons schemes in other areas of building controlthrough the amendment SI 2002:0440 that introduced the FENSA, CORGI, OFTEC, HETAS and

IoP schemes. It has therefore recommended that there should be further discussions with bodies

who wish to be approved by the Secretary of State as scheme operators for Part P. Thesediscussions under the Competent Persons Initiative will include further examination of thereporting process to BCBs to be consistent with the reporting requirements of The BuildingRegulations 2000 and electrical installation industry practice.


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Application to extension of existing electrical installations

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 thesenew provisions sufficiently clear?

28. The views of the electrical installation industry and Government bodies suggest that therequirement for "supply and earthing" be deleted and the words from BS7671 used for `alterations

and additions' (see BS7671 Regulation 130-07-01). Members of the public and users suggest thatthe text is clear (71% of respondents). There was concern over the interpretation of Regulation 4when applied to heritage buildings.

Action Taken

29. The requirements for supply, earthing and bonding have been clarified.

30. The requirements for "alterations and additions" are being examined by Government lawyers and

may be changed better to align with BS7671, consistent with the powers provided in the BuildingAct 1984.

Proposed performance requirement

This indicates that the legal requirement would be met by compliance with the fundamental principlesgiven in CENELEC Harmonisation Document HD 384.1, as promulgated in the UK by Chapter 13 ofBS7671: 2001. Is the paragraph a sufficiently clear distillation of the safety requirements and thefundamental principles in Chapter 13?

31. 61% of respondents supported the view that Chapter 13 of BS7671 summarises the safety

requirement satisfactorily. However the organisations representing the industry believe that the

whole of BS7671 should be referenced in paragraph 1 of Section 0. To be consistent with theindustry view to reference the whole of BS7671, the CENELEC HD 384 series of standardsshould be referenced for EEA equivalence.

32. It was suggested that the hazards in paragraph 1.1 be spelt out to include `electric shock, fire andburns'.

33. The industry responses (30%) note that functionality in clause 1.3 is not a requirement of BS7671certification and sub-paragraph 1.3 of Section 0 should be deleted as it has no bearing on safety.

Action Taken

34. The paragraph conveying the Secretary of State's view has been changed to focus on the

fundamental principles in Chapter 13 of BS7671:2001. The reference to HS384.1 has beenremoved as the fundamental principles section in the HD does not address alterations and

additions.

35. Equivalence of electrical installation standards of other EEA states is retained.

36. The reference to functionality has been dropped as it is not a safety issue.

The approach in BS 7671 is not to address safety directly but to ensure that installations are built inaccordance with technical equipment, installation standards, and methods of inspection and testingthat, as a whole, are considered by experts to achieve a satisfactory degree of safety. Would youprefer the performance requirements to be identified more specifically and / or could they beidentified more effectively in another way?


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37. There was substantial support (95%) for the reference to comply with the whole of BS7671 assuggested in para 5above.

Action Taken

38. The standard Building Regulations approach has been retained. This is:-

to determine the legal requirement in functional terms,

to go one step further into detail by providing the Secretary of State's view that compliancewill be achieved by following the fundamental requirements in BS 7671 Chapter 13, and

to confine references to detailed technical ways of compliance to the approved guidance

Work that need not be notified

Work self-certified by competent persons. The proposals allow that approved competent personscould self-certify compliance of their electrical installation work with the Building Regulations.Would it be sensible to allow non-approved persons to proceed with electrical installation workwithout giving prior notice if it is to be certified at completion by someone who is approved?

39. It should be noted that the printed consultation document uses the words "approved competent

persons" and the web site question 6 states a "competent person". Both have been taken to meanthe same for this analysis.

40. Two key issues were identified in the responses:

Is self-certification by competent persons the principal route to demonstrate an electricalinstallation is compliant with Part P?

Can electrical installations be inspected and tested to enable an Electrical InstallationCertificate to be issued at the completion of the work without inspection(s) of the electrical

installation during the build process?

41. The industry comments were generally in favour of the principal of self-certification, however the

public suggested that certification is not necessary. There were a significant number of responseswhich suggested that a definition of "competent or approved person" and "competency" should be

included in the Regulations. Guidance on the status of the designer, consultant and architect in thedefinition was requested.

42. Where the installer is not to be an approved competent person, clarification of the status andresponsibilities of a third party inspector was requested and, in particular, the liabilities incurredwhen signing a certificate.

Inspection on completion

43. The responses from the industry and users, including the building industry, expressed concernover a single inspection on completion of the electrical installation work. It was noted thatBS7671 requires inspection of electrical installation works during construction as the electricalinstallation may not be accessible when covered up during the further building and finishingprocesses.

44. Builders identified the three stages of an electrical installation as each requiring inspection.

45. The NICEIC suggest that a Periodic Inspection Report (not included in the consultation documentbut available on the IEE web site at www.iee.org.uk/technical ) is the only certificate that can beissued if there is no inspection other than at completion.
http://www.iee.org.uk/technicalhttp://www.iee.org.uk/technical


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46. The public respondents rejected the need for independent inspectors and expressed concerns thatthe added costs of an independent inspector on one or more occasions would deter the DIY

worker and those working in the grey/black economy from notifying work at any time. Thiswould defeat one objective of Part P of improving the standard of additions and alterationsundertaken by people or firms that are not approved competent persons.

47. Some respondents indicated that Inspection(s) during the build process might not be justifieddependent on the nature of the work.

48. Overall, there was support (65%) for electrical installation work to be covered by Part P to benotified to Building Control before the work commences unless the installation and the inspectionand testing is undertaken by a competent person.

Action Taken

49. No decision has been reached on this matter. It has been left for resolution as part of the furtherwork on developing the competent persons scheme system. Ministers issued a ParliamentaryWritten Statement on 15 July. This is available at www.parliament.the-stationery-

office.co.uk/pa/cm200203/cmhansard/cm030715/wmstext/30715m04.htm#30715m04.html_sbhd3
http://www.parliament.the-stationery-office.co.uk/pa/cm200203/cmhansard/cm030715/wmstext/30715m04.htmhttp://www.parliament.the-stationery-office.co.uk/pa/cm200203/cmhansard/cm030715/wmstext/30715m04.htmhttp://www.parliament.the-stationery-office.co.uk/pa/cm200203/cmhansard/cm030715/wmstext/30715m04.htmhttp://www.parliament.the-stationery-office.co.uk/pa/cm200203/cmhansard/cm030715/wmstext/30715m04.htm


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Minor work

Minor Work. The proposal to exclude minor work from the requirement to notify stems fromconsiderations of enforceability, and the improvements in safety that could be achieved comparedwith 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?

50. There was substantial support (76%) for minor work not to be notified. However there was some

confusion between the title `Minor Work' and the `Minor Works Certificate' in BS7671. It wassuggested that `Electrical Work exempt from Notification' be used for work which need not benotified to Building Control.

51. There was also consensus that the draft limit of electrical work exempt from notification is too

extensive. There is a support in the industry that the limit above which notification is requiredshould be a single or double socket outlet on one circuit. Concern was expressed by severalrespondents that the design of the installation might be such as to circumvent the requirement tonotify.

Action Taken

52. The title "minor work" in the Approved Document has been changed to "work which need not be

notified". Work identified in Table 1 in the draft Approved Document which need not be notifiedto BCBs has been clarified and further notes added.

53. Work in kitchens and special installations and locations defined in a new Table 2 in the ApprovedDocument is now considered to attach such additional risks as to warrant requiring notification.

Certification of minor work

Certification of minor work. Paragraph 5.2 in the draft AD defines minor work for the purposes of theBuilding Regulations and gives guidance on the use of the Minor Electrical Installation WorksCertificate system. How might the testing and certification requirements for minor work be improved?

54. There was support (81%) for all new, additions and alterations to electrical installations (notifiedand non-notified) to be inspected and tested. It was suggested that paragraph 5.2.2 in the draftApproved Document should be more positive than "where prudence and these ...". Part 7 ofBS7671 requires all installations to be inspected and tested, this should be reflected in paragraph

5.2.2.

55. Other issues raised included:

If only competent persons are intended to sign certificates (pages 49 et seq in the AD), then

paragraph 5.2 should state this clearly.

It was recognised that DIY and work not undertaken by a competent person may be of a

poorer standard and should therefore be included in the inspection, testing and certificationprocess.

A frequency for periodic inspection (as competent in IEE Guidance Note 3) should beincluded in the Approved Document (normally every 10 years or change of ownership for adwelling).

A special exemption for electrical work associated with boiler installation was requested.

It was noted that the European word used for this work in paragraph 5 is now conformity and

not certification.


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Action Taken

56. The requirement to inspect and test new and altered electrical installations in accordance with

BS7671, Part 7 is outlined in clauses 10.1 and 10.2. In particular, all work undertaken by peopleor firms that are not members of an approved competent persons scheme must have an appropriate

certificate issued by a suitably qualified person.

57. The requirements for inspection and testing are further outlined in paragraphs 17 to 22 of theApproved Document.

58. In accordance with item 2 of Table 1, it is not necessary to notify the provision of a simpleconnection to an existing ring main or radial circuit, including the provision of a further socketoutlet or fused spur for a supply for a boiler not be notified. The additional wiring does howeverrequire inspection, testing and certification by a member of an approved competent personscheme or, where the people or firms are not members of such a scheme, by a suitably qualifiedperson. .

List of minor work

Table 1 is intended to be an exhaustive list of the types of minor work that need not be notified. Areyou content with this approach and are there other types of work that you would wish to see listed?

59. There was support for a list of work not requiring notification, however most respondents (73%)

suggested that the list should be more restricted than the draft list included in the consultationdocument.

60. The areas singled out for specific comment were:

As currently listed, new or replacement electrical work in kitchens, bathrooms and bedrooms

could be installed as work not requiring notification to a Building Control.

There was concern that an unrestricted number of socket outlets could be installed on anexisting circuit, in particular in a kitchen.

To comply with the Amendment Number 1 to Regulation 433-02-04 of BS7671:2001 (which

requires an assessment of the current in any part of the ring), it is suggested that minor workbe limited to the addition of ONE single or ONE double socket outlet to a circuit for item 2 intable 1. For consistency, a single fused spur should be added to the list in item 2 of table 1,work which need not be notified.

Also as drafted, a replacement 10.5 kW electric shower could be replaced by a person or firm

that is not an approved competent person without any testing. Some respondents consideredthat this would be dangerous.

Main and supplementary bonding are safety requirements which should only be worked onand tested by a competent person with appropriate test equipment. Items 4 and 5 in table 1,

page 38 of the consultation document on bonding should be deleted from the list of workwhich is exempt from notifying.

There was a suggestion that fitting of a residual current device (rcd) be exempt from the needto notify as an encouragement for these accessories to be fitted.

The replacement of a cable in item 6 and note 2 to table 1 as a like-for-like item may bedifficult in the future with the change in all cable specifications to take account of the changein cable core colours in fixed installations (this also applies to replacing imperial standardcables).


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Action Taken

61. Table 1 and its associated notes have been amended to take account of comments.

62. All electrical installation work in kitchens must be notified.

63. An additional Table has been added to the Approved Document which lists special installations

and locations which require electrical installation work to be notified to BCBs.

64. Changes in the Table 1 have been made to improve enforceability.


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Design, installation, inspecting and testing

Technical guidance.

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 waysin which the goals can be achieved. The diagrams in Appendix A are intended only to indicate thesorts of electrical services encountered in dwellings, some of the ways they can be connected, and thecomplexity of the wiring and protection systems necessary to supply them. Are you content that thisapproach, rather than detailed technical solutions, is satisfactory?

65. There was agreement (94%) that the approach using the goals of BS7671 is correct. Thoseorganisations representing the industry and many other organisations and individuals suggest thatthe diagrams in Appendix A should be deleted with the comment that they "may give DIYworkers or inexperienced persons confidence to use them as wiring diagrams". There is

inadequate data in Appendix A for this purpose.

Action Taken

66. The approach to using BS7671 has been retained.

67. A statement in the text and a watermark on the background of each diagram in the ApprovedDocument states that the diagrams are only illustrative and must not be used as installationdiagrams.

Should we make electrical installations in dwellings more resilient against flooding, in whatcircumstances and how best might this be done (see Section 1 paragraph 8)?

68. There was no general consensus to make a requirement to provide protection against flooding inan electrical installation and the industry suggests that no special provision should be made in Part

P. Where a risk of flooding is identified for a dwelling, chapters 32 and 52 of BS7671 giveappropriate measures for the electrical installation and guidance from the electricity providershould be sought for the supply arrangements.

69. Several respondents suggested that a general comment (not a requirement) could be included for

dwellings which were identified at risk from flooding that cabling should be installed from firstfloor level and none should be installed on or below the ground floor surface.

Action Taken

70. It is considered necessary to mention flooding as one of the important consequences of climate

change. However para 13 now states that "the electricity distributor and installer may be required

to take into account the risk of flooding" and a cross-reference to general guidance on flooding isgiven.

71. IEE have agreed to give guidance on flooding in the IEE On Site Guide and IEE Guidance Notes.

Will the forthcoming Electricity Safety, Quality and Continuity Regulations 2002 have a bearing onthe proposed limits on application in this consultation (see Section 1 paragraph 9)?

72. DTI comment that Section 1, paragraph 9 of the ESQCR02 gives the supply authority the powerNOT to connect an installation if it is NOT safe. Compliance with BS7671 can be demonstratedthrough an Electrical Installation Certificate.

73. A reference in Part P to the ESQCR02 may encourage discussions between rural and heritage

sites on earthing with their electricity provider.


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Action Taken

74. Paragraphs 30 to 38 in a new Section 3, Other Legislation, outlines the requirements of the

ESQCR02 in respect of dwellings.

Technical references.

Technical references. The references in the draft Approved Document comprise BS 7671: 2001, theIEE On Site Guide and a set of IEE Guidance Notes. Bearing in mind that much electrical work iscarried out in DIY projects (see the Regulatory Impact Assessment), it has been considered prudent toinclude DIY manuals in the references. Appendix B contains blank copies of the BS 7671 and IEEcertificates that builders and householders might otherwise find difficult to get. Are you content thatthe references given, the acceptance of DIY manuals, and the inclusion of blank forms is satisfactory?

75. There was overwhelming support for the primary reference to be BS7671.

76. The industry supported the referencing of the IEE On Site Guide and IEE Guidance Notes as

these are maintained compliant with BS7671. These texts are supported by the industry throughthe IEE consultation process which agrees the guidance and keeps the publications in line with the

latest edition of BS7671.

77. There was no consensus to include references to DIY manuals. The contracting industryrecommend that there should be no reference to texts other than the IEE texts, whilst independent

respondents suggest that any guidance is good and may give information which may improve thequality of DIY and other electrical installations. It was noted by several respondents that most

DIY manuals do not give guidance on inspection and testing or test instruments and their use. Itwas also noted that it is unlikely that DIY enthusiasts will have access to appropriate instruments.

78. There was support for the use of the model forms specified in Appendix 6 of BS7671. Theseforms are widely reproduced in IEE and other documents and freely available in two computer

formats on the IEE web site (www.iee.org.uk/technical ). It should be made clear that test

schedules should accompany all Electrical Installation Certificates, Minor Works Certificates andPeriodic Inspection Reports when they are handed to the `person ordering the work'.

Action Taken

79. The references in Approved Document P for further information and guidance are now reduced tothe IEE On Site Guide and IEE Guidance Notes 1 to 7.

80. The forms required in the Approved Documents are available in BS7671, IEE On Site Guide, IEEGuidance Note 3 and in pdf and WORD formats on the IEE web site (access is free to thesepages).

Accessibility

The draft Approved Document contains guidance on the accessibility of socket-outlets and protectiondevices (fuses, circuit breakers and residual current devices). Is this guidance satisfactory?

81. Many respondents noted that guidance on the positioning of socket outlets and switches for newdwellings is given in Part M of the Building Regulations. There was a consensus (79%) that thereshould be a reference to Part M, but it is not necessary to reproduce the text of Part M in Part P.Several bodies suggested that guidance should extend to include easy access to consumer units indwellings.

Action Taken

82. Approved Document M is referenced to provide guidance on the positioning of socket outlets andswitches.
http://www.iee.org.uk/technicalhttp://www.iee.org.uk/technical


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83. Approved Document P requires the consumer unit to be positioned for easy access.

Material alterations

Technical goals.

Technical goals. Paragraph 19 in the draft Approved Document gives guidance on how to complywith the proposed new version of Regulation 4 (see box 4 above). Are you content that the guidance is

sufficient?

84. There was support (95%) for the guidance given in paragraph 19 of the draft Approved

Document. To be consistent with earlier comments, there should be a reference to BS7671 and theaddition of a clause to ensure that the material alterations require inspection and testing forcompliance, together with any other circuits which may have been affected, as specified inBS7671.

Action Taken

85. The definition of `Material Alteration' is the subject of legal interpretation and drafting.


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Appendix A: diagrams and notes

The purpose of these is to give readers who are not qualified in electrical engineering informationabout 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 Approved Document.Are the diagrams and notes clear and comprehensive enough, and how might they be improved?

86. Overall about 66% of respondents supported the inclusion of Appendix A in the style shown inthe draft Approved Document, often commenting that further information may assist in making aninstallation by non-competent persons safer. Several commented that further information shouldbe included to assist the DIY worker such as cable rating tables and guidance on earthing.

87. However the industry is opposed to the inclusion of Appendix A as they believe that theinformation in the diagrams is compressed and not adequate if used as the only source ofinformation for a wiring project.

Action Taken

88. Appendix A has been retained and improved as an indication to builders and others that areunfamiliar with the scope of wiring systems in dwellings of what may be expected. However

warnings are given in the paragraph in Section 0 that introduces them, and alongside the diagramsthemselves, that the diagrams are NOT wiring diagrams.

Appendix C: guidance on older installations

Appendix C offers guidance on the types of older installations that might be encountered inalterations work and what improvements may be needed. Is there any information that you believeshould be included in Appendix C?

89. There was less support from respondents for the inclusion of Appendix C (40%) than there wasfor Appendix A. Several comments suggested that further information on fuses and miniature

circuit breakers would be helpful. Others suggested that, in conjunction with Appendix A, itwould give residents a false sense of danger because of age and also a false sense of confidence toundertake the work themselves. Interpretation of wiring rules at heritage sites and rural dwellingswould be particularly prone to the judgement that old-age equals unsafe installation.

Action Taken

90. Appendix C has been retained as helpful advice to those who are not experienced electricians,

recognising the extent of work that is carried out by DIY workers.

Draft regulatory impact assessment

Do you have any comments on the benefits and costs identified in the RIA?

91. The RIA was criticised by 89% of those who gave an opinion on the document. The primaryconcern was the inclusion of accident figures from portable and non-portable appliances whenApproved Document P is only applicable to fixed electrical installations. Table 1a in the RIAshows that 76% of fatal accidents and 74% of non-fatal accidents will not be directly affected bythe introduction of the Part P proposals as they are not part of the fixed installation and henceoutside the scope.


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92. The public respondents focussed on the cost of the small number of accidents attributable to fixedinstallations (approximately 24% of fatalities and 26% of non-fatal accidents) and suggested that

the savings in Table 2 in the RIA should exclude portable and non-portable appliances, making asaving of only 38m rather than 104m for an average of 2.6 deaths and 447 accidents per year.Whilst commenting on savings, some respondents queried the source of the 20% saving inaccidents quoted in paragraph 33 of the RIA.

93. There was also a suggestion that the costs of compliance with Part P were optimistic, as only the

direct costs of certification have been included and not the preparation cost for certification visitsand the time costs for the visit. Estimates for the total costs to achieve certification can be muchhigher, depending on the size of the company being certified.

94. If BCBs are also involved in the certification process for non-competent persons, there may be a

further cost that is not included in the RIA. For the DIY worker and non-competent persons, therecould be an additional cost of inspection and certification by a competent person. There were

several comments which suggest that the inspection and testing will not be done and that some ofthis work will be carried out in the grey/black economy.

95. It is noted that portable and non-portable appliances which are plugged into fixed installationsnow obtain some protection from modern protective devices, in particular residual current devices(rcd) in the fixed installation. The requirement in BS7671 is that any socket outlet which mayprovide power for equipment (fixed, portable or non-portable) outside the dwelling must now beprotected by an rcd.

Action Taken

96. The RIA has been revised to take account of respondents' comments and later information.

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 yourcompany 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 the letter at the front of theconsultation document. The aim is to select about five firms for survey, so there can be no guaranteethat expressions of interest will be taken up.

Action Taken

97. The results of the small business litmus test will be included as Appendix A to the FinalRegulatory Impact Assessment when it is published, signed by Ministers, alongside the draftStatutory Instrument to bring the new requirements into force.


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Other comments

Do you have any other comments?

98. There were four issues which received a substantial number of comments:

12.1 - Comment and support for the Electrotechnical Assessment Scheme.

12.2 - Building Control.

12.3 - Portable and non-portable equipment.

12.4 - D I Y.

99. Other relevant single comment issues are included at the end of this section.

The Electrotechnical Assessment Scheme (EAS)

100. Some responders suggested that any proposals for a certification scheme should comprise a

single scheme with a single logo if the public is not to be confused. One respondent suggested thatthe certification scheme should be named in legislation. Others thought that there should be one

set of scheme criteria but that it should be open for any group to apply for approval to run aseparate scheme.

101. The consensus was that it should be possible for competent persons schemes to be operatedby more than one organisation.

102. The EAS is based on EN 45011. Other organisations in the consultation suggested that thereshould be flexibility in the certification procedures and different forms of certification to, perhaps,EN 45004, EN 45013 or EN 45020.

103. The RIA suggests that only 13,000 of 61,000 electrical installation contracting companies in

the UK are in either the ECA or the NICEIC schemes. There is concern over the timescale andresources required to inspect and certify 48,000 contracting enterprises which are not at presentcertified and wish to become competent persons. This problem will be applicable to any scheme,so a reasonable lead-time will be required for implementation of any scheme.

104. There was a small lobby of inspectors and testers who suggested that electrical installation

inspections should only be carried out by separately registered inspectors.

105. A problem was identified by several organisations of certifying new contractors once ascheme is running. A Certification Body will require evidence of competent work. Currentschemes require a contractor to be in business for one year. If legislation requires competentpersons to inspect installations, then there will be additional inspection costs for new contractors

until they have been in business for a year. Should there be any transitional arrangements? Severalresponses suggested that any registration scheme for electrical installation contractors could leadto a shortage of competent electricians.

106. One respondent suggested a class of membership for DIY enthusiasts to promote their

involvement and assist the signing off of the work through better guidance on inspection andtesting.

107. There were 206 letters to the ODPM supporting Part P, mostly electrical contractors and 142letters to Members of Parliament, again from electrical contractors, requesting their support forPart P in Parliament.


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Action taken

108. Ministers have made an announcement on the way forward for self-certification of electrical

work. This is available at www.parliament.the-stationery-office.co.uk/pa/cm200203/cmhansard/cm030715/wmstext/30715m04.htm#30715m04.html_sbhd3

Building Control

109. The Requirement P of the Building Regulations states that electrical installations in dwellingswill become a "controlled service". Although no question referred to BCBs, 45 organisationsmade comment on the additional work that would be required.

110. More than half identified the additional workload that these Regulations will impose as aresult of the need to inspect of work undertaken by people or firms that are not approved

competent persons. The draft RIA makes no comment on the extent of the additional work thatBCBs would have to undertake or their powers of approval or rejection of work undertaken bynon-competent persons.

111. There are two possible options for approving work by non-competent persons, inspection by a

competent person or direct inspection by a BCB. It is unclear where responsibility and futureliability will be for the safe functioning of the electrical installation by either approvalmechanism.

112. Some respondents queried how a competent person would notify the BCB that installationworks had satisfied the requirements of Part P. It was suggested that the Electrical Installation

Certificate or the Minor Works Form (specified in Appendix 6 of BS7671) could be used toindicate compliance. Alternatively, a system similar to the Scottish system of statutory forms(although not statutory) may be all that is necessary. It is estimated that about 3 million electricalcertificates are issued each year for all types of electrical installation work, the majority fordomestic work.

Action Taken

113. Several Competent Persons Schemes have been introduced in the building industry sinceApproved Document P went out to public comment in May 2002. The role of BCBs in theseprovisions is in course of being reviewed. The provisions applicable to the certification thecompliance of electrical work with the Building Regulations (as opposed to certification incompliance with BS7671) are being further developed.

Portable and non-portable appliances.

114. The main issue identified in the consultation on portable and non-portable appliances involves

the inclusion of their accident statistics in the RIA (see section 11.1 above). The number of deaths

and injuries from appliances is more significant than those from fixed installations. AMDEAsuggest that appliances have never been safer. However, there are many more appliances in use inthe normal dwelling. The ring circuit was designed in the late 1940s to supply power to space heatusing electric bar heaters. The number of socket outlets and equipment plugged into them hasincreased about 12 times in 50 years, yet the total number of accidents has decreased.

115. It may be prudent to include appliances within the scope of the requirement for protection

against shock in the dwelling, not just accidents caused by the fixed installation. An earliercomment outlined under question 11.1 suggests that the rcd in the fixed installation protects theuser from shocks from defective appliances. The growth in mains powered garden equipment hascontributed significantly to electrical accidents attributed to the dwelling. However, an rcd at theorigin of the dwelling fixed installation significantly increases protection from a fatal shock from

the appliance and the flex from the socket outlet to the appliance.
http://www.parliament.the-stationery-office.co.uk/pa/cm200203/cmhansard/cm030715/wmstext/30715m04.htmhttp://www.parliament.the-stationery-office.co.uk/pa/cm200203/cmhansard/cm030715/wmstext/30715m04.htmhttp://www.parliament.the-stationery-office.co.uk/pa/cm200203/cmhansard/cm030715/wmstext/30715m04.htmhttp://www.parliament.the-stationery-office.co.uk/pa/cm200203/cmhansard/cm030715/wmstext/30715m04.htm


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Action Taken

116. It is acknowledged that protective devices in the fixed installation also protect portable

electrical equipment plugged into socket outlets. The RIA takes note of this benefit.

Do-it-yourself

117. Views expressed on DIY work on quality and safety issues are (numerically) divided in theconsultation. Those respondents who support DIY suggest that more information should be givenat DIY outlets and cheaper instruments made available to improve quality and compliance of theDIY installation with good practice. The industry and safety regulators believe that the mostdangerous installations are those undertaken by DIY workers and un-qualified practitioners. It isfurther suggested that these are the installations which would not be inspected and tested byqualified persons unless the owner asked for the inspection and tests.

118. The proposals on how to deal with DIY installations which are more than minor work are notclear in Part P. A policy is required to determine if DIY work which is within scope of theRequirements of Part P are to be inspected, by either competent persons or a BCB. In these

instances, does the responsibility for the installation pass from the DIY worker or non-competentperson to the inspector?

Action Taken

119. Work carried out by DIY workers will be treated as work undertaken by persons not coveredby a Competent Persons scheme. DIY installations are covered by BS7671 which requires theinstallation to be inspected and tested by a competent person in accordance with Part 7 ofBS7671. Work other than that listed in Table 1 in the Approved Document must be notified toBuilding Control or undertaken by a member of an approved competent person scheme.

Other relevant single comment issues

120. The insurance industry may assist with the implementation of Periodic Inspections at the IEEGuidance Note 3 recommended frequency of every ten years by giving discounts to house ownersfor their accident insurance cover.

121. The inclusion of the Periodic Inspection Report in the purposes of the Home InformationPack should be promoted for use in the sale and transfer of dwellings.

122. An Electrical Installation Certificate should be provided for every new house.

123. The EU Construction Products Directive is not generally applicable to the proposals for Part P

(except for cables).

Action Taken

Views on the desirability of including Electrical Installation Certificates, Minor Works Certificatesand Periodic Inspection Reports in Home Condition Reports have been passed on to the Division inODPM responsible for this initiative.