Fixed Electrical Installation Inspection & Testing

INTRODUCTION

There is a general duty under the Electricity at Work (EAW) Regulations 1989 that electrical systems should be maintained, “so far as is reasonably practicable”, in a safe condition. The Regulations do not specify how this is to be achieved. The word “system” includes fixed electrical installations, i.e. the wiring and switchgear installed in the building, and fixed equipment, i.e. equipment that is permanently fixed and can only be moved if fixings are removed, e.g. motors, compressors, heaters, lights etc.

REQUIREMENTS FOR INSPECTION AND TESTING

The duty “so far as is reasonably practicable” requires a person to assess the magnitude of the risk and balance this against the cost, in terms of physical difficulty, time, trouble and expense of eliminating or minimising the risk. Guidance on “reasonably practicable” and the EAW Regulations in general is contained in the HSE guidance book HS(R)25 Memorandum of guidance on the Electricity at Work Regulations 1989, which can be downloaded at https://www.hse.gov.uk/pubns/books/hsr25.htm   

The EAW Regulations do not specify how frequently electrical equipment is to be maintained or what records are to be kept. The HSE guidance book HS(R)25 refers to BS7671: Requirements for Electrical Installations, also known as the IEE (more recently the IET) Wiring Regulations. BS 7671 is a code of practice which is widely recognised and accepted in the UK and compliance with it is likely to achieve compliance with the relevant aspects of the 1989 EAW Regulations.

Periodic inspection and testing is carried out to identify the maintenance requirements of the electrical installation. This should be undertaken by an electrician qualified to at least the formal Electrotechnical NVQ Level 3 Diploma in Installing Electrotechnical Systems and Equipment (or its equivalent, such as an Advanced Apprenticeship or the pre-QCF NVQ Level 3 introduced in 1996), which is based on the IET Wiring Regulations/BS BS7671. Electricians conducting periodic inspection and testing should also hold a City and Guilds or EAL qualification specifically relating to electrical inspection, testing and certification.

In response to the need for electricians to demonstrate competency, the Electrotechnical Certification Scheme (ECS) has been established under which electricians with NVQ level 3 qualification or similar can apply for an ECS Gold Card as proof of identification, competence and qualification in a range of electrical disciplines such as installation, maintenance, low voltage, high voltage, etc. Whilst the scheme is voluntary, it is nowadays almost impossible for an electrician to gain access to a construction site without an ECS Gold Card.

UKAS ACCREDITED REGISTRATION SCHEMES

Electrical contractors having membership of a UKAS accredited registration scheme operated by a recognised professional body is always the preferred route.

Back in 2014, the Registered Competent Person Electrical single mark and register scheme was created which comprehensively lists all full scope, competent registered domestic electricians (firms or individuals) in England and Wales for the purposes of Part P of Building Regulations - https://electricalcompetentperson.co.uk/

More recently, plans were drawn up for the formulation of a similar scheme relating to electrical contractors operating in the commercial and industrial field but this has not progressed.

The main UKAS accredited electrical contractor certification and inspection body schemes applicable to buildings (other than dwellings) and industrial locations comprise:

• NICEIC (National Inspection Council for Electrical Installation Contracting) – www.niceic.com

• ECA (Electrical Contractors Association) – www.eca.co.uk

• SELECT (Electrical Contractors Association of Scotland) – www.select.org.uk

• NAPIT (Napit Certification) – www.napit.org.uk

Details of these and other schemes are contained in an Appendix at the end of this Technical Bulletin. 

RISK IMPROVEMENTS

A range of standard risk improvement wordings concerning electrical installation inspection and testing are contained in the wordings database for various applications; these should be observed at all times.  

It is extremely important that all electrical installation and maintenance work in explosive atmospheres is carried out by an electrical contractor having hazardous area membership of a UKAS accredited registration scheme for which an additional risk improvement wording is contained in the wordings database. Further wordings in respect of electrical installation inspection and testing in domestic premises have also been formulated, linked where applicable to the Registered Competent Person Electrical Scheme.

ELECTRICAL INSTALLATION CERTIFICATES AND CONDITION REPORTS

A key requirement of the BS 7671 following verification of a new installation or changes to an existing installation where new circuits have been introduced is the issue of an Electrical Installation Certificate, together with a schedule of inspections and a schedule of test results. For additions or alterations to the installation which do not extend to the introduction of new circuits, a Minor Electrical Installation Works Certificate may be used.

Following the periodic inspection and testing of an existing installation, an Electrical Installation Condition Report (EICR), together with the schedules previously mentioned is required to be issued. Standard formats for electrical certificates and electrical installation condition reports are prescribed by the IET and are to be found within the BS.

BS 7671 and the supporting IET publication Guidance Note No. 3 Inspection and Testing provide guidance on the methods, extent and frequency of inspections and testing of fixed installations (see Table 3.2). These documents, together with the On-Site Guide to BS 7671 published by the IET, give detailed guidance on the inspection and testing of electrical installations, including the records to be kept.

The purpose of the EICR is to report on the condition of the installation and, ultimately, present one of two outcomes:

• SATISFACTORY – the installation is deemed safe for continued use.

• UNSATISFACTORY – one or more issues of safety have been identified.

Where an “unsatisfactory” result has been recorded, C1 and/or C2 observations will have been included identifying the reason(s) for the result. FI (Further Investigation) may also be recorded where the inspection has revealed an apparent deficiency which could not, owing to the extent or limitations of the inspection, be fully identified and further investigation may reveal a code C1 or C2 observation.

Observations recorded within the EICR fall into four categories:

• C1 – Danger present. Risk of injury. Immediate remedial action required.

• C2 – Potentially dangerous – urgent remedial attention required.

• C3 – Improvement recommended.

• FI – Further investigation required without delay.

The recommendation of the IET is that wherever practicable, items coded as CI should be made safe on discovery (either by immediate repairs or by taking the offending item or circuit out of service). Where this is not practical, they recommend that the owner or user be given written notification as a matter of urgency.

FREQUENCY OF INSPECTION AND TESTING

Recommended initial frequencies of inspection of electrical installations are contained within Table 3.2 of Guidance Note No.3, which together with qualifying Notes is replicated below.

The “initial frequencies” in the table refers to the time interval between the issuing of the Electrical Installation Certificate on completion of the work and the first inspection. The recommended frequency of subsequent inspections may be increased or decreased at the discretion of the competent person carrying out the inspection and testing.

There has been a change in policy within the IET in recent years, which has departed from the previous prescriptive approach to periodical testing. The rationale behind this fundamental change of approach centres on the fact that, unlike visual inspection, testing involves a degree of dismantling of the electrical installation, which may be detrimental to overall safety. Therefore, whilst periodic testing of the installation is advocated, it is no longer considered necessary to lay down the prescribed intervals for this work, but that this is determined by the appointed electrical contractor having regard to the nature of the system and the premises concerned. It may be that it is deemed appropriate to carry out testing on alternative inspection intervals, or that sample testing is conducted (see below).

Reference to column 3 under the section “Buildings open to the public” shows significant alteration in the recommended frequency periods, as compared with the previous tables issued by the IEE for which annual intervals have in the past been commonplace. However, for premises such as cinemas, theatres and other places of public entertainment this is qualified by the notes at the foot of the table, and for many such buildings annual inspection and testing will still be required under the relevant statutory regulations.

SAMPLE INSPECTION AND TESTING

IET guidance recognises that carrying out 100% inspection and testing in many installations is unrealistic, uneconomical and unachievable. In these situations, sample inspection and testing is advocated, the percentage sample being at the discretion of the electrical contractor.

Considerable care and engineering judgement should be applied by the contractor when deciding upon the extent of the installation that will be subjected to inspection and testing. This will involve obtaining all relevant information on the installation, including the original installation certificates, previous inspection reports, maintenance records, etc. If the required information cannot be obtained, it may be necessary to inspect/test a large percentage of the installation, up to 100%. Other factors having a direct bearing on the size of the sample would include:

• Age and general condition of the installation;

• Type and usage;

• Ambient environmental conditions;

• Effectiveness on ongoing maintenance;

• Time periods between previous inspections/tests;

• Size of the installation.

Irrespective of the above considerations, IET guidance does not advocate a sampling regime below 10%.

Once the degree of sampling has been decided upon, if significant defects or signs of damage or deterioration are identified, it is strongly recommended in Guidance Note 3 that the sample programme is widened. If more defects emerge, an inspection and test of the entire installation may be advocated. The following flow chart has been replicated from Guidance Note 3:

It is not the intention that RiskSTOP Consultants become involved in deciding on the extent of sample inspection and testing if applied, but that this is a matter for the appointed electrical contractor and the Policyholder.

ROUTINE CHECKS

As well as formal inspection and testing, Guidance Note 3 also advocates that recorded routine checks of the installation are carried out between inspections for which recommended intervals are given in Table 3.2 (column 2). Such checks would typically include:

• Check that all reported defects have been rectified;

• Visual inspection for wear and tear, signs of overheating, missing parts (covers, screws, etc);

• Confirmation that switchgear is accessible, switch rooms clear and secure;

• Correct operation of switchgear, RCDs, etc.

Guidance Note 3 goes on to state that these routine checks need not be carried out by an electrically skilled person, but should be done by someone who is able to safely use the installation and recognise defects.

LICENSED PREMISES

It should be noted that fire safety in night-club premises is covered under The Local Government (Miscellaneous Provisions) Act 1982 (as amended) and The Licensing of Public Entertainments Regulations, administered by the Local Council. For these premises a license is required which is to be renewed annually.

Prior to the issue of such a license an electrical certificate, amongst other things, is required to be provided. Thereafter a periodical inspection report is required to be furnished at intervals prescribed by the Council. This has traditionally been required annually, although in recent years some Councils have amended their policy to requiring this to be done once every 3 years, particularly where the installation has been installed by an ECA or NICEIC member contractor.  Unfortunately, this is very much dependent on the policy of the individual Council and some variance around the UK is likely to occur.

OTHER ELECTRICAL TESTING ARRANGEMENTS

In addition to periodic inspection and testing of the electrical installation, inspection and testing is also recommended:

• To assess compliance with BS 7671;

• On a change of occupancy or use of the premises;

• After alterations or additions to the original installation;

• Owing to any significant change in the electrical loading of the installation;

• Where there is reason to believe that damage has been caused to the installation.

For an installation under effective supervision in normal use, the guidance states that periodic inspection and testing may be replaced by an adequate regime of continuous monitoring and maintenance of the installation and all its constituent equipment by a skilled person. The key is that appropriate records must be kept.

If an installation is maintained under a planned maintenance management programme, incorporating monitoring and supervised by a suitably qualified electrical engineer, a formal periodic inspection and test report may also not be required. Once again, it is essential that adequate records are kept and that the results of tests are recorded. The results should be available for scrutiny and need not be in the standard IET format.

A question frequently asked is whether an in-house electrician with the appropriate level of competency can undertake inspection and testing and issue inspection reports. Whilst this may not contravene the BS/IET Regulations, third party inspection by an outside electrical contractor would always be the preferred route.

Another frequently asked question relates to the competence of the electrician involved in inspection and testing. Quoting from the Guidance Note – “It is important that the competency of the person carrying out the periodic inspection and test is of the appropriate level having gained sufficient education, experience and knowledge to be fully conversant with the aspects required of carrying out such an important inspection. He or she will, for example, need to be able to inspect switchgear, determine the age of installation components and recognise signs of their deterioration. As well have having sufficient visual inspection skills they will also need to possess good testing skills and experience of older installations and knowledge of what the resulting data means in the context of the ongoing safety of the installation.”

THE ELECTRICAL SAFETY STANDARDS IN THE PRIVATE RENTED SECTOR (ENGLAND)

REGULATIONS

These Regulations which came into force on 1 June 2020 require landlords to have the electrical installations in their properties inspected and tested at least every five years by a person who is qualified and competent. They must also provide a copy of the Electrical Safety Condition Report (EICR) to tenants, and to the local authority if requested. Should the EICR require investigative or remedial works, landlords will have to carry this out.

Landlords of privately rented accommodation, including houses in multiple occupation, must:

• Ensure national electrical safety standards set out in the IET “Wiring Regulations” (BS 7671) are met.

• Ensure the electrical installations in their rented properties are inspected and tested by a qualified and competent person at least every 5 years.

• Obtain a report from the person conducting the inspection and test which gives the results and sets a date for the next inspection and test.

• Supply a copy of this report to the existing tenant within 28 days of the inspection and test.

• Supply a copy of this report to a new tenant before they occupy the premises.

• Supply a copy of this report to any prospective tenant within 28 days of receiving a request for the report.

• Supply the local authority with a copy of this report within 7 days of receiving a request for a copy.

• Retain a copy of the report to give to the inspector and tester who will undertake the next inspection and test.

• Where the report shows that remedial or further investigative work is necessary, complete this work within 28 days or any shorter period if specified as necessary in the report.

• Supply written confirmation of the completion of the remedial works from the electrician to the tenant and the local authority within 28 days of completion of the works.

For the avoidance of doubt, the Private Rented Sector (PRS) is a classification of housing in the UK. The basic Private Rented Sector definition is: property owned by a landlord and leased to a tenant. The landlord, in this case, could be an individual, a property company or an institutional investor. The tenants would either deal directly with an individual landlord, or alternatively with a management company or estate agency caring for the property on behalf of the landlord.   

The Regulations apply to all new tenancies from 1 July 2020 and existing tenancies from 1 April 2021. If a private tenant has a right to occupy a property as their only or main residence and pays rent, then the Regulations apply.

Exceptions are set out in Schedule 1 of the Regulations and include social housing, lodgers, those on a long lease of 7 years or more, student halls of residence, hostels and refuges, care homes, hospitals and hospices, and other accommodation relating to healthcare provisions.

The Management of Houses in Multiple Occupation (England) Regulations 2006 previously put specific duties on landlords around electrical safety. This requirement has now been repealed, and HMOs are now covered by the new Electrical Safety Regulations.

HMOs with 5 or more tenants are licensable. The Housing Act 2004 has been amended by these Regulations to require a new mandatory condition in HMO licences ensuring that every electrical installation in the HMO is in proper working order and safe for continued use. See guidance on HMO licences.

For further information concerning the new Regulations, reference should be made to an article in “Wiring Matters” on the IET website.

Similar legal requirements came into effect in Scotland in 2015 under the Housing (Scotland) Act 2006, for which guidance for landlords has been published, and in Wales. Similar regulations are being introduced in Northern Ireland.

SURVEY EXPECTATIONS

It is essential that RiskSTOP Consultants continue to pay close attention to assessing the age and visual condition of the electrical installation as a as key element of all survey work, and that this is supported by enquiries concerning maintenance of the installation and periodic inspection and testing. Consultants should also be familiar with any Client Policy Warranties regarding the need for fixed electrical testing.

Appropriate risk improvements should be made using the RiskSTOP standard Risk Improvement Wordings and such items will normally be submitted as “Requirements”.

Dealing specifically with periodic inspection and testing, the approach should be that of supporting “best practice” as set out in Table 3.2. overleaf;

 TABLE 3.2: Recommended Initial Frequencies of Inspection of Electrical Installations

Notes (Table 3.2):

1.      Particular attention must be taken to comply with S1 2002 No 2665.  Electricity Safety, Quality and Continuity Regulations 2002 (as amended).

2.      Electricity at Work Regulations 1989, Regulation 4 and Memorandum of Guidance (HSR 25) published by the HSE.

3.     See BS5266, Part 1: 2005 Code of Practice for the emergency lighting of premises.

4.     Other intervals are recommended for testing operation of batteries and generators.

5.     See BS5839, Part 1 2002 + A2:2008 Fire detection and alarm systems for buildings. Code of Practice for system design, installation, commissioning and maintenance.

6.     Local Authority Conditions of Licence.

7.     It is recommended that a caravan is inspected and tested every three years, reduced to every year if it is used frequently (see Regulation 721.514.1 and Fig 721 – Instructions for electricity supply).

8.     The person carrying out subsequent inspections may recommend that the interval between future inspections be increased or decreased as a result of the findings of their inspection.

9.     Medical locations shall have their isolating transformer equipment inspected and tested for functionality as well as alarms etc; every third year the output leakage current of the IT isolating equipment shall be measured.

10.  The Landlord and Tenant Act 1985 requires that properties under the act have their services maintained. Periodic inspection and testing is the IET recognised method of demonstrating this.

11.    The Management of Houses in Multiple Occupation Regulations (England and Wales).

For the purposes of this table, the “Industrial” installations category is intended to apply to all manufacturing/production facilities, whereas “Commercial” is intended as a “catch all” for any occupancy not otherwise specifically included in the Table – typically storage and distribution risks, recording studios, typesetters, etc. Motor garages are deemed by the IET to fall under “Industrial” owing to the presence of petrol driven vehicles.

When considering the frequency of inspection, in the event that a current certificate and/or a periodic inspection report/electrical installation condition report exists, the routine inspection frequency as recommended by the Electrical Contractor is to be accepted, unless it can be shown that the condition of the installation has deteriorated in such a manner as to bring the need for inspection and testing forward. 

Appended to this bulletin are the first two pages of an Electrical Installation Condition Report form as supplied by the IET, taken from Appendix 6 of BS 7671. Also, a further appendix has been incorporated giving details as at February 2023 of the various UK accreditation schemes applicable to the field of electrical contracting. 

APPENDIX

Accreditation of Electrical Contractors/Accreditation Schemes

Main schemes (in no particular order) are as follows:

1.     Electrical Contractors’ Association (ECA)

Comprising 3000+ Registered Members representing the full spectrum of electrical and electronic work. Each undergoes regular, rigorous technical assessments to ensure they carry out safe electrical work and each is covered by the ECA Bond and the ECA Guarantee of Work scheme.

The ECA operates two certification schemes; the UKAS-accredited ECA Membership Certification Scheme for BS7671 electrical installation work and a scheme for all other areas of work, including controls, high voltage, fire and security systems, audio visual, data and telecommunications, outside the scope of BS7671. The Registered Members scheme is administered on behalf of the ECA by Certsure LLP (see below) in which members are certificated against one or more of the following disciplines:

• Commercial and industrial

• High voltage

• Fire detection and emergency lighting

• Building and industrial controls

• Datacomms & IT infrastructure

• Other allied and supplementary electrical trades

• Security & CCTV

• Hazardous areas

• Domestic installations

For contractors who carry out domestic work, the ECA also provides registration as one of the Government approved Full Scope Competent Persons schemes for Part P of the Building Regulations (England & Wales).

When selecting a member on the search facility on the ECA website (www.eca.co.uk/find-an-eca-member), clicking on the name of the contractor reveals the disciplines for which they are registered under the headings of “services” and “specialities”. 

2.    NICEIC (a Certsure brand)

The UK’s leading UKAS accredited regulatory body for the electrical contracting industry. It has been assessing the electrical competence of electricians for over fifty years and currently maintains a roll of over 30,000 approved contractors. Schemes operated by NICEIC include:

• Approved Contractor Scheme: for electrical contractors undertaking design, installation, commissioning and maintenance of electrical installations to BS 7671.

  
  

  The scheme is open to any electrical contractor or contracting organisations who can demonstrate their competence to perform electrical installation work in accordance with BS 7671. Applicants may include:

  • Electricians working on commercial and industrial installations

  • Electricians working on domestic installations

  • Testing and inspection

  • Street lighting installers

  • Security systems installers

  • Other contractors with a scope of work covered by BS 7671

• Hazardous Areas Scheme: an extension to the scope of those contractors that have already achieved Approved Contractor status, covering the inspection, testing and maintenance of electrical installations in potentially explosive atmospheres. 

• Domestic Installer Scheme (Part P): registers installers to Full Scope or Defined Competence for domestic electrical installation work in accordance with Part P of the Building Regulations (England & Wales). (This scheme includes the former ELECSA brand which has been retired.)

3.    Napit Certification Ltd

A UKAS accredited certification body covering various disciplines, including electrical contracting. Specific electrical contracting fields for which registration can be obtained include:

• Commercial Installations

• Fire and Security systems, Emergency Lighting, CCTV

• Domestic Installations

• Periodic Inspection Reporting

• Electrical Heating

• Industrial Installations (excluding hazardous areas)

• Portable Appliance Testing

When selecting a member from the search facility on the NAPIT website (www.napit.org.uk), information is obtained of the trades and specialities for which the installer has been registered.

(NAPIT is a UKAS accredited certification body, operating accreditation schemes for electrical, plumbing, heating and ventilation contractors. NAPIT has tended in the past to attract smaller electrical contracting businesses, often principally involved with domestic work, but has obtained UKAS accreditation as a certification body for contractors carrying out electrical installations in buildings (other than dwellings) and industrial locations. As a direct result, any reservations which some Insurers may have had concerning the “acceptance” of NAPIT as an accredited certification body are no longer valid.)

4.    Electrical Contractors’ Association of Scotland (SELECT)

SELECT is the trade association for the electrical contracting industry in Scotland and is a UKAS accredited inspection body.

Registered members of SELECT are accredited to one or more of the following disciplines:

• Commercial and domestic wiring installations 

• Fire detection and fire alarm systems 

• Emergency lighting 

• Control panels and building control systems 

• Work in hazardous areas 

• Security systems 

• Voice and data systems 

• In-service inspection and testing of electrical equipment (PAT testing). 

In a similar vein to the search facilities detailed above, clicking on a member contractor on the SELECT website (www.select.org.uk) reveals the type of work for which they are registered.

5.    The Safety Assessment Federation (SAFed)

SAFed represents the UK’s independent engineering inspection and certification industry, and plays a key role in maintaining high standards of safety within the workplace. It acts as a focal point for all issues and concerns relating to the statutory inspection and certification, safe use and operation of plant, machinery and equipment.

SAFed Member Companies provide statutory and non-statutory equipment examinations and inspection services to national legislation standards. Full Members formally accredited by UKAS to international standards of inspection bodies include the likes of RSA Engineering, Allianz Engineering, Bureau Veritas UK etc.... On account of the prestigious nature of these companies and the services they provide, they are unlikely to be commonly employed for electrical inspection work outside of the corporate arena.

Other Accreditations /Quality Assurance Schemes/Trade Associations

Other accreditations/quality assurance schemes and trade associations applying to contractors in the electrical services field include:

1.     TrustMark

TrustMark is a government-backed initiative to assist householders to find a reputable contractor. Licensed TrustMark operators in the electrical contracting field consist of ECA, NAPIT, NICEIC and ELECSA, the members of which have an option of applying for TrustMark status should they so require. This has no relevance to the non-domestic sector.

2.    Building Engineering Services Competence Assessment (BESCA)

Activities include a UKAS accredited full scope Competent Persons Scheme for domestic work in compliance with Part P of Building Regulations. https://www.besca.org.uk/ 

 3.     CompEx

Operated globally, the CompEx Scheme is a UKAS accredited solution for validating the core competency of employees and contract staff of major users in the gas, oil & chemical sectors, both with offshore and onshore activities, including electrical engineers and contractors. RiskSTOP is unlikely to come across CompEx accredited engineers very often owing to the specialist application. https://compexcertification.com/ 

4.    Association for Petroleum and Explosives Administration (APEA)

A UK based organisation, drawing membership from all quarters of the petroleum industry, including Regulators from National and Local Government Authorities, Oil Companies, Equipment Manufacturers and Suppliers, Service and Installation Organisations, Training Establishments and many others. It is seen to be unique in representing all sides of the industry and in providing a forum for debate and the generation of technical guidance. Whilst highly meritable, APEA is essentially a trade association and not an accreditation body. https://apea.org.uk/ 

5.    Blue Flame Certification

A UKAS accredited certification body offering certification services in the Gas, Oil, Electrical, Solid Fuel, Building Services, Renewable Technologies and Building Energy Efficiency fields, including a Competent Persons Scheme for domestic work in compliance with Part P of Building Regulations.

IET ELECTROTECHNICAL ASSESSMENT SPECIFICATION

This specification is intended for use by certification and registration bodies undertaking the assessment of businesses carrying out electrical installation work, and sets out the minimum requirements to be met by a business, in order to be recognized by a certification or registration body as technically competent to undertake the design, construction, maintenance, verification and/or inspection and testing of one or both of the following categories:

Electrical installations up to 1kV:

• Dwellings

• All other

The intention is that certification and registration bodies will need to develop their own scheme requirements around the minimum criteria set out in the IET specification. Electrotechnical Assessment Specification - Electrical (theiet.org)