Electrical Reg Changes Increase Landlord Costs
Former electrician and local landlord, Graham Castellano has highlighted a change in electrical regulations which will hit HMO landlords initially and all landlords eventually.
If you are an HMO landlord with an EICR due in the next 6-9 months, it is worth getting it done before the end of September. If you are a Social Housing landlord - no need to worry - there is no legal requirement for you to check electrical installations in your property...
What Is The Change
As of 28th September 2022, the new 18th Edition amendment 2 of BS7671 (Electrics Regs) becomes compulsory. This introduces AFDDs (Arc Fault Detection Devices) in specific circumstances, specifically:
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Regulation 421.1.7 now requires that AFDDs conforming to BS EN 62606 shall be provided for single phase AC final circuits supplying socket-outlets with rated current not exceeding 32 A in the following:
- Higher Risk Residential Buildings (HRRB)
- Houses of multiple occupancy (HMO)
- Purpose-built student accommodation
- Care homes
HRRBs are assumed to be residential buildings over 18 m in height or in excess of six storeys, whichever is met first.
For all other premises, the use of AFDDs conforming to BS EN 62606 is recommended for single phase AC final circuits supplying socket-outlets not exceeding 32A. Where used, AFDDs shall be placed at the origin of the circuit to be protected.
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What Are Arcs And Why Protect Against Them?
Arcs are visible plasma discharges caused by electrical current passing through a normally nonconductive medium, such as air. This is caused when the electrical current ionizes gases in the air, and temperatures created by arcing can exceed 6000 °C. These temperatures are sufficient to start a fire.
What causes arcs?
An arc is created when the electrical current jumps the gap between two conductive materials. The most common causes of arcs include worn contacts in electrical equipment, damage to insulation, break in a cable and loose connections, to mention a few.
Fire statistics...
Whilst fires in dwellings have decreased significantly over the past ten years, there are still a considerable number of fires which are attributed to electrical faults. In 2017/18 there were 74,118 primary fires with 13,070 associated with electrical distribution or other electrical appliance faults, which is still a significant number. It is not to say that AFDDs would prevent all of these incidents, but it is likely that the number would be reduced.
What are Arc Fault Detection Devices?
AFDDs are protective devices installed in consumer units to provide protection from arc faults. They use microprocessor technology to analyse the waveform of the electricity being used to detect any unusual signatures which would signify an arc on the circuit. This will cut off power to the affected circuit and could prevent a fire. They are far more sensitive to arcs than conventional circuit protective devices.
Like a Residual Current Circuit Breaker (RCCB) or Residual Current Breaker with Overcurrent protection (RCBO), AFDDs usually incorporate a test button which can be operated by the end-user to prove the mechanical operation of the device.
In terms of physical size, AFDDs are now in production that are the same size as a circuit-breakers, and also contain an RCBO.
So How Does This Affect Landlords?
Graham said, "This means that from that the end of September, any electrical installation condition reports (EICR, aka Electrical Safety Certificates) on HMOs, etc might (should!) class the absence of these devices in the consumer unit (CU) as a C2, which means that remedial work will be needed to get a 'satisfactory' rating.
Typical costs for the device alone is approx. £150 each (they will get cheaper as time moves on), and one is needed for each socket circuit. Add on top the electrician's costs for the remedial work and retest.
In some cases the AFDD can be inserted directly in place of the circuit breaker in an existing CU. More likely, though, it will need a CU reconfiguration, which might not be possible on all CUs, leading to a replacement CU being needed."
Our View
We have complained before about trade bodies and local authorities constant creep of regulation – at £150 per circuit plus potentially a new consumer unit, this could easily cost £2,000 per property.
In defence of trade bodies, Graham responded: "I find it hard to justify the introduction of these devices (benefits) versus the costs. However the UK doesn't really lead the regulations - we, due to harmonisation, CENELEC, etc are followers of European Standards, for instance the wiring colours, (I hate to say EU here, as it predates our in/out love affair with the EU). We have our own spin on the regs, but these devices are now becoming widespread in Europe so it was only a matter of time before they started being included in UK regs. It's symptomatic of our increasingly risk-averse society. On the other hand, if these devices save even one life, who is to put a value on that? "
The statistics are simple – 13,070 fires caused by electrical faults in one year and arc'ing suspected of being a significant contributor to those fires. Sadly, this poor science is typical of well meaning professionals who lack the scientific training to properly assess cause and effect, probability, etc.
In 2017/18 there were "13,070 fires associated with electrical distribution or other electrical appliance faults" sounds like ample justification, until you see "Everyday household appliances caused 15,000 accidental fires in homes across England between April 2019 and March 2020" from research by ElectricalDirect. Obviously one needs to compare apples with apples, but the suggestion from these 2 unrelated pieces of research suggests that very few fires were actually caused by 'electrical distribution' issues.
The research we would like to see would show how fires caused by electrical distribution faults are split between premises with a current / valid EICR versus those without. Our fear is that those with up to date and tested electrical systems are being penalised (by being forced to pay for expensive upgrades within their consumer units) to reduce risks that do not normally occur in well maintained properties. Sadly, this 'regulation creep' is all to common and continues to push up rents and make life harder for landlords.
On the topic of 'creep' Graham confirmed the risk by adding, "because the AFDDs contain microprocessors, they are susceptible to damage from mains-borne spikes. This might lead to having to install Surge Protection Devices (SPDs) at the Consumer Unit as a minimum - MORE expense. There are rules for the need to install SPDs, but too complex to detail here. However we are going in that direction!"
So if you have an EICR due – it may be one more reason to switch from HMO to Family Let, though Graham added that these 'recommendations' have a nasty habit of becoming 'rules' over a period of 10 years or so, so we will all have to pay sooner or later.