Electrical Changes Update
We wrote last year about the need to get EICRs completed before September if we wanted to avoid the high cost of AFDD's. A member asked recently whether this became law and which HMOs it applies to. I also, somewhat foolishly, asked for the latest on plastic consumer units under stairs. Read the response of member and retired electrician, Graham Castellano.
AFDDs (Arc Fault Detection Devices)
The best answer to this question is not a black and white definitive answer, but an explanation of the current state of play. Bear in mind that I no longer practice, and it is based on my own interpretation of the current state.
The new 18th Edition Amendment 2 of British Standard (BS) 7671 (Electrics Regs) came into force on 28th September 2022. This introduced AFDDs (Arc Fault Detection Devices) as a requirement in specific circumstances, viz:
AFDDs conforming to BS EN 62606 shall be provided for single phase AC final circuits supplying socket-outlets with rated current not exceeding 32A in, amongst others, Houses of multiple occupancy (HMOs).
Points to note:
1) BS 7671 is not a statutory instrument; it is a British Standard and not a law. However, it is referenced in several laws, and is therefore a 'de facto' law. In a court of law, it is fairly damning if the requirements of BS 7671 have not been followed and fire or injury have been caused because the requirements have not been implemented.
2) The requirements of BS 7671 Amendment 2 apply to new installations or work carried out after the implementation date, i.e., after 28/9/22.
3) BS 7671 is not retrospective, so existing installations carried out to earlier versions of the Standard do not have to comply with, or be brought up to the level of, the latest standard, although if alterations are made to an existing installation, these alterations do have to be compliant.
4) HMOs are not specified by number of occupants, so all HMOs are covered by this standard.
When an electrical installation is inspected for the purpose of obtaining an Electrical Installation Condition Report (EICR), it should be inspected to the edition of BS 7671 that it was constructed to, or to which the latest alterations have been made. In practice this is hard to establish, so the electrician is immediately presented with scope for interpretation. This is open to abuse in order to create work (perish the thought!), but also latitude in interpretation.
Absence of AFDDs in an HMO with an electrical system designed before 18th Edition Amendment 2 became effective should be classed as Code 3, Improvement Recommended, which is only a recommendation and allows the property to be coded 'satisfactory' if no other more serious problems are found.
However, even though Amendment 2 does not apply in this case, the electrician could code it as C2, Potentially dangerous, urgent remedial action required, which would code the property as 'unsatisfactory' and lead to remedial work such as a Consumer Unit (fuse box) replacement. The electrician's coding as C2 would be because it is a safety exposure to the occupants not to have the AFDD's fitted, and that the upgrade should take place before a 'satisfactory' rating can be given for the property. I believe that this interpretation is incorrect, but I am no longer a practising Electrician and don't have access to current advice from Trade Bodies.
In summary, it's very likely that, if you have older properties, AFDDs are not mandatory for you. But it's also possible that an electrician will tell you otherwise and force an upgrade to AFDDs.
Plastic Consumer Units
All installations designed after 30th June 2015 must comply with BS 7671:2008,17th Edition, Amendment 3 (2015), which mandates metal consumer units (or plastic consumer units inside a fire resistant enclosure). 18th Edition carries on with this.
The implication is that installations designed before this date do NOT have to have metal consumer units.
This document https://www.electricalsafetyfirst.org.uk/media/2149/bpg4-1.pdf gives latest guidance on coding for EICRs (not an easy read!).
Specifically, on page 15, for 'C3 - Requires Improvement' coding (With only C3 codings, a satisfactory EICR can be issued.):
Presence of a consumer unit or similar switchgear made from combustible material (e.g. plastic) that is not inside a non-combustible enclosure and which is:
- Located under wooden staircase, or
- within a sole route of escape from the premises
(Note: If unsatisfactory connections or thermal damage are found during inspection, this would warrant a code C2 classification to be recorded)
Also on page 16, for 'Observation' only (also OK for satisfactory EICR):
Presence of a consumer unit or similar switchgear made from combustible material (e.g. plastic) that is not inside a non-combustible enclosure and which is NOT:
• Located under wooden staircase, or
• within a sole route of escape from the premises.
(Note: If unsatisfactory connections or thermal damage are found during inspection, this would warrant a code C2 classification to be recorded)
This all refers to Domestic (Households) Installations - there is nothing spelt out in Edition 17 or 18 which specifically refers to HMOs (apart from the AFDD part), so I assume HMOs are classed as Domestic premises, as opposed to Commercial or Industrial premises.
So, as usual, 'it depends' - on the age of the installation and on the electrician carrying out the EICR. Certainly, any change of consumer unit today must be metal, regardless of where it is located in the premises. (Just to confuse things, premises refers to the occupied areas. It is permissible to have plastic consumer units in detached or attached garages!)