I think it is fatally flawed, as it seems likely it will remove properties from the rental market and result in more homeless. But I hope I am wrong.
The EICR was designed to tell the owner the condition of the electrical installation so the owner can make informed decisions one what work can be done in the future.
Three main codes are:-
C1 – There is a danger present, risk of injury and immediate remedial action required.
C2 – There is a potential danger present and urgent remedial work is required.
C3 – Improvement is recommended.
There is a forth F1 - Further investigation required and there was a code 4 does not comply with current edition of BS7671 which was removed as it was said it confused the client.
As to F1 I would personally issue it where access is not possible like no loft hatch, it was common in terraced houses for only one house in the terrace to have a loft lid.
First question is what is the remit of the inspector? Electrical installation is defined in building regulations as any fixed electrical equipment, and BS7671 says "Electrical installation (abbr: installation). An assembly of associated electrical equipment having co-ordinated characteristics to fulfil specific purposes."
It does not include what is missing, so if a smoke detector is missing, then it is not anything to do with the inspection one would think, that would come under an inspection done by a fire protection expert not an electrician.
However it seems [url=https://www.electricalsafetyfirst.org.uk/media/2149/bpg4-1.pdf]The electrical safety council best practice guide 4 issue 5[/url] does not agree, it shows inadequate provision of socket outlets (Note: A Code C3 or, where appropriate C2, if extension leads run through doorways, walls or windows, or under carpets, or are otherwise being used in an unsafe manner) however we are not really worried about C3 codes, neither are we really worried about C1 codes immediate danger clearly needs addressing before the electrician leaves the premises.
So it is the C2 which is causing the problem.
[quote="Best Practice Guide"]Code C2- Potentially dangerous (urgent remedial action required)This code should be used to indicate that, whilst an observed deficiency is not considered to be dangerous at the time of the periodic inspection, it would become an immediate danger if a fault or other foreseeable event was to occur in the installation or connected equipment. The person ordering the report should be advised that, whilst the safety of those using the installation may not be at immediate risk, remedial action should be taken as a matter of urgency to remove the source of potential danger.[/quote]
Lets face it 230 volt is "Potentially dangerous" and it would be near impossible to say any inspector is wrong when awarding a C2, so if going to the silly then awarding a C2 because home fitted with type AC RCD and a inverter drive washing machine is being used I think everyone would say that is OTT, although not totally wrong.
So most use the best practice guide as guidance, but that has a lot of conflicting information, it says the old Wylex fuse box "can continue to provide satisfactory service." but also says "Absence of RCD protection for portable or mobile equipment that may reasonably be expected to be used outdoors." but makes it clear extension leads should not run through doorways, walls or windows, or under carpets. So unless there is an outside socket, it does not need RCD protection, or are we to assume because there is an electric lawn mower in the shed it will be used with an internal socket without the plug in RCD we can see on the end of cable?
And this is the point it is left to the discretion of the tester, but if the tester goes OTT some one can become homeless.
We have near every electrical organisation giving often conflicting advice, and landlords pulling out there hair when a property which passed in 2018 is failing in 2020 even when we are using the same edition of BS7671.
Every forum with an electrical section is full of cases where it is clear C2 has been issued in error, of course no one complains when C2 not issued when it should be.
At the moment in England only where new tenants are renting a property is it required, but landlords are given 28 days to correct faults, as to how is not clear, if for example water is running down the wall of an outbuilding making a socket wet, then one would think disconnecting the supply would make it safe, and not stop the use of many property, but it needs a minor works to show corrected, how can a minor works be issued for some thing not being powered?
At £250 for an EICR clearly you don't what to pay that for a correction, it seems it is all getting rather silly, we are told as inspectors the report goes only to the person ordering the report, but the owner has to provide copies to the tenant, and if asked the council, some electricians say in spite of BS 7671 2001/2008/2018 all saying they only apply to installations designed after a given date, that C2 can be awarded to items that complied when designed and don't comply now, with no code 4 any more coding changes as C3 may be correct, but not a C2.
So if in 1992 when BS 7671 first came out, you did not need a RCD why should it need one now to avoid getting a C2?
OK maybe there are some reasons why not safe now but was safe in 1992 with no degrading, maybe today we use more suppressors as more electronic equipment so greater leakage to earth than in 1992, but because we now use more RCD protection more likely the reverse is true.
In 1966 the rules for earthing lights changed and still the electrical safety council details what should be done when we find the earth is missing, using class II equipment etc. They still don't say lack of earth on lights is a fail, even when it is unlikely to find any PVC cables in properties that old, any likely any property without earth to lights is well past its use by date.
So what do you think should happen? Should we write to MP to complain, should we turn blind eye, what do you think should be done?