The experts at Stroma Certification are back with the second part of this best practice advice column.
In the previous article of this technical guidance series we looked at the objective of periodic inspection and testing, the importance of inspection (as opposed to testing) and the requirements of inspector competence.
In this article we’ll now look at documentation, the extent of the installation to be inspected, limitations and the recording of non-compliances and defects.
BS 7671 requirements
Chapter 63 of BS 7671 sets out the requirements for documenting the outcomes of inspections and tests. This chapter requires the outcomes to be recorded in an Electrical Installation Condition Report (EICR).
The results of the inspection are to be recorded in a schedule of inspections and the test results to be recorded in a schedule of test results. Appendix 6 of BS 7671 provides model forms for these documents. Regulation 634.2 requires, ‘Any damage, deterioration, defects, dangerous conditions and non-compliances, including their reasons, shall be recorded’.
Clarifying the extent of the test or inspection
The front page of the EICR requires entries to be made on the address of the premises, the reason for the inspection and test, the type of premises to be inspected and the estimated age of the installation. The form then requires the ‘extent’ of the installation that has been inspected and tested.
It is essential that the inspector describes what parts of the installation have been inspected and tested in unambiguous detail. For example, if only one floor of an office building has been inspected and tested, that should be described by location and extent such as, ‘The distribution boards and final circuits in the third floor office only, excluding portable appliances, telephone and data circuits and the BMS control system’.
This makes it clear that the other floors, the landlord’s common areas and the distribution circuits to the floor have not been inspected and tested. In simpler terms, say what you have and have not done.
The EICR has a requirement to record any limitations to the inspection and testing over and above the standard limitations which are stated on the form as being, ‘Cables concealed within trunking and conduits, under floors, in roof spaces, and generally within the fabric of the building,’ unless specifically agreed with the client.
However, equipment installed in roof spaces should be inspected. There are separate limitations that should be agreed with the client before work starts and operational limitations where inspection and testing cannot be undertaken, but the reasons for this must be explained.
An agreed limitation may be something along the lines of, ‘The supply to the server room has not been isolated for inspection and testing at the request of the client. Visual inspection only with limited live testing’.
Defects and non-compliances with BS 7671 will need to be recorded in detail. These items will need to be awarded a code. These codes are C1, C2, C3 and FI.
C1: This code is appropriate for an item where there is danger present, such as an exposed live part. In which case, the inspector should advise the client of this condition without delay so that immediate action can be taken to reduce the hazard.
C2: This code is for a ‘potentially dangerous’ condition where the defect or departure is pre-disposed to becoming a ‘dangerous condition’ but it requires another event. An example of this is an unearthed Class I light fitting where it is not immediately dangerous but a live conductor touching the metal casing would make it dangerous as that part would be live and the circuit protection would not operate.
C3: This defect means ‘improvement recommended’. An example of this may be missing warning labels.
FI: This means ‘further investigation’. This is appropriate where the inspector cannot come to a conclusion about the safety of the installation without the need for further information or investigation. An example of this might be no main protective bonding of a Lightning Protection System (LPS), where the LPS designer or contractor needs to be consulted to verify it is appropriate and safe to bond the LPS.
Whilst there is industry guidance on the coding of defects and non-compliances it is very much a personal decision for the inspector to award a code based on their sound engineering judgement. However, the inspector must be prepared to justify their decision by putting forward their technical explanation. The award of a single Code 1, Code 2 or Code FI on an EICR must make the outcome of the report ‘unsatisfactory’.
Test and inspection periods
On completion of the inspection and test the inspector will need to apply a label to the installation, stating the date of the inspection and the recommended date of the next inspection. The inspector also needs to record the recommended date for the next inspection on the EICR.
IET Guidance Note 3 has a table of maximum periods for the date of a periodic inspection and test after initial verification which is a useful guide for subsequent inspections. An inspector may shorten those recommended periods due to the age and gradual deterioration of the installation but again the inspector must be able to justify their decision.
A common error is for inspectors to shorten the period for the next periodic inspection and test due to the extent of the defects and non-compliances found and the fact the installation is ‘unsatisfactory’. That is not correct as it states on the form that the date for the next inspection is ‘subject to the necessary remedial action being taken’.
For more technical guidance and information from Stroma Certification visit: stroma.com/certification