David Cowburn, Chief Operating Officer at NAPIT, reflects on the progress made by the electrical industry to enhance electrical safety standards over the past decade, including the Electrotechnical Assessment Specification (EAS), and considers the issues which remain unresolved.
It doesn’t seem long ago that I was sat in front of the Communities and Local Government Select Committee answering questions about Electrical Competent Person Schemes, the impact of Part P, enforcement and consumer awareness, to assist with their inquiry in 2013-14 into “Building Regulations certification of domestic electrical work”.
Looking back, a lot has changed since then, and although many of the recommendations from the Inquiry were for the government, the electrical industry has taken considerable steps to make improvements to safety standards in the sector.
One of the main focuses of the Inquiry, was the lack of public awareness around Part P of the Building Regulations, and the confusion caused by multiple Competent Person Scheme Operators. The Committee called for the industry to unite and produce one consumer facing brand and register for all registered electricians to use and be listed on.
It was following this recommendation that ‘Registered Competent Person Electrical’ (RCPE) was created in 2014. The single mark and register aims to raise awareness of electrical safety in the home by simplifying the task of finding and checking a competent, registered electrician.
It was updated in 2020 to provide a differentiated search for those looking for an electrical company registered to carry out electrical installation work or to undertake an electrical safety report, in support of the introduction of the Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020.
Also, to support these Regulations, the industry moved to update the Electrotechnical Assessment Specification (EAS) to introduce the minimum technical competence criteria required for carrying out Periodic Electrical Inspection and Testing. The update provided a consistent standard upon which the assessment of competence is undertaken for those who wish to be registered to carry out electrical inspection and testing, creating a common approach to enhance standards. Importantly this focussed on the individual carrying out the inspection and testing work, not their qualified supervisor.
The EAS is intended for use by Certification and Registration Bodies undertaking the Assessment of Enterprises carrying out Electrotechnical work. It sets out the minimum requirements to be met by an Enterprise and the individuals working for that enterprise, in order to be recognised by a Certification or Registration Body as technically competent to undertake the design, construction, maintenance, verification and/or inspection and testing of electrical installations.
It currently serves as the Minimum Technical Competency Document upon which MHCLG authorise Electrical Competent Person Schemes to operate and sets the benchmark for the sector. Although not particularly well known, it is the key document the industry can use to enhance safety standards and create positive change.
Since the Communities and Local Government Select Committee Inquiry, the EAS has been updated twice to overcome many of the issues raised. The 2015 version introduced a requirement for electrical contractors to hold an up-to-date qualification within two years of a change to the wiring regulations. This version also introduced specific risk-based requirements, clearly outlining the extent of on-site involvement needed by the responsible person throughout the duration of electrical installation work, to mitigate the risk highlighted by the Inquiry of the person undertaking work in people’s home not being adequately qualified or supervised, since Enterprises are registered rather than individuals.
The 2020 version of the EAS, published in January 2020, built on these changes to require registered companies to demonstrate the competence of their employed persons, including temporary, agency and sub-contracted labour. This includes the provision for the assessment of individual competence that has been the underpinning principle of the NAPIT Scheme from its conception.
Further to this, from September 2021, only full qualifications will be accepted for applicants to Electrical Competent Person Schemes, removing the auditable evidence route which was often criticized as allowing short cuts for gaining entry. This demonstrates a significant step change for the industry and shows a clear commitment to continued improvement. This hasn’t neglected those with experience, as the recognised qualifications available include approaches for using such experience to achieve a suitable qualification.
At the time of writing, the MHCLG are reviewing the competence criteria used within authorised schemes and the EAS will continue to evolve to accommodate these. There are particular concerns working in high-risk buildings (such as tower blocks) and the new technologies needed to deliver government’s environmental initiatives, such as electrical work underpinning renewable technologies, electric vehicle charge points and electrical energy storage systems to name but a few.
This diversity of competence requirements falling on specific individuals within the industry brings increasing emphasis on individual competence, where competence is demonstrated by a combination of qualifications and regular assessment within a regulated third-party certification scheme.
It is, however, important to remember that there is no legal requirement for electricians to be registered with a Competent Person Scheme, and so whilst we can, and will, continue to push for enhanced standards, the option remains for consumers to, perfectly legally, use unregistered electrical installers who are not required to meet the conditions set by the EAS.
Reflecting on one of the core recommendations from the Inquiry, for the government to put in place arrangements to incentivise and assist local authorities to strengthen the enforcement of Part P, we reiterate this recommendation and ask that now more than ever, enforcement needs to be addressed.
Whilst there are examples of great work going on within the industry to help understand and quantify the extent of the safety risk posed by unsafe and non-compliant electrical installations in dwellings throughout the UK, through the creation of a reporting form, led by the Electrical Safety Roundtable and TrustMark, it is up to the government to create real change in the enforcement landscape.
View the current and previous versions of the EAS here.
