final report on the level of checking of electrical installations to

A9721553

BRE

Final report on the level of checking of electrical installations to BS7671

Date: November 2014

2

Report prepared by: Dr Stephen L Garvin, Katy Hunter and John Reid BRE Scotland, Orion House, East Kilbride, G75 0RD The authors would like to thank the following:

LABSS and the individual verifiers who took part in the research SELECT and NICEIC (the scheme providers) and individual Approved bodies and Certifiers of construction who took part in the research Keith Groom of AKD Systems for assisting with technical understanding of electrical installation and testing.

The opinions expressed in this report are those of the author. Report commissioned by: Building Standards Division Local Government and Communities Directorate Denholm House Almondvale Business Park Livingston EH54 6GA Tel: 01506 600 400 Fax: 01506 600 401 e-mail: [email protected] web: www.scotland.gov.uk/Topics/Built-Environment/Building/Building-standards © Crown Copyright 2014 Applications for reproduction of any part of this publication should be addressed to: BSD, Directorate for the Built Environment, Denholm House, Almondvale Business Park, Livingston, EH54 6GA.

This report is published electronically to limit the use of paper, but photocopies will be provided on request to Building Standards Division.

3

Contents

1 Executive summary 4

2 Introduction 6

3 Review of guidance documents 8

4 Survey of verifiers 22

5 Interviews and reviews 33

6 Discussion 64

7 Conclusions 74

8 Appendices 76

4

1 Executive summary The Building Research Establishment (BRE) has been commissioned by the Building Standards Division (BSD) of the Scottish Government to undertake a research project to investigate the level of checking of Electrical Installations to BS7671. The background to the research is that the Building (Scotland) Act 2003 permits the construction of building work to be certified by qualified, experienced and reputable building professionals and tradespeople as complying with the building regulations. The objectives of the research are as set out in the introduction to this report.

The research included desk based research to review the available guidance documents on the processes required to assess compliance and the competence requirements of those checking electrical installations. The desk based research is relevant to objectives (a) and (b) of the project as set out in the project specification. A survey of local authority verifiers was undertaken in order to gather information on the approach taken in reasonable inquiry to checking of electrical installations across all 32 local authorities. The research additionally involved carrying out a number of interviews and reviews with both local authority verifiers and certifiers of construction.

The following conclusions are made from the research:

The electrical scheme for the certification of construction has been shown to be robust and to set high standards for approved bodies and approved certifiers of construction. It covers the competence of those within the scheme and sets standards for certification activities. There is flexibility in the scheme operation, which is based upon the complexity of the project and nature of the business undertaking the work.

In non-certified work the electrical installation is typically controlled by experienced building standards surveyors. Each verifier has their own approach, although most follow the existing guidance or a variation on it. The verifiers have limited competence in electrical work and do not have the qualifications to check installations and carry out testing. The verifiers are primarily checking that installers are competent.

There was lack of consistency and indeed transparency in the approach amongst the verifiers to electrical installation checking. The approach typically reflected the differences in the degree of risk perceived. One authority required almost an equivalent to the certification scheme as evidence for each installation, but typically SJIB cards and membership of trade bodies were enough evidence.

The scheme sets a template for consistency in the approach amongst different approved bodies and approved certifiers of construction. It is clear that over the

5

years a robust approach to auditing the membership has improved standards and consistency between certifiers. Although the approved bodies and certifiers found the audit process difficult it had benefits for the membership that were ultimately invaluable.

There was no evidence that the end products of certified and non-certified approaches were different. However, there were clear differences in the approaches, processes and competence of those involved. The certified approach is more highly regulated by the scheme and there is scope to improve the consistency and transparency of the non-certified approach.

A number of findings have been presented by the research, which are aimed at closing the gap between the approaches. The findings are achievable and proportional to the levels of risk involved in electrical checking. There is scope to make the non-certified approach more consistent and transparent. At the same time the electrical scheme may be able to consider adjusting requirements around low complexity/risk projects and high complexity/risk. At least more emphasis on documenting site visits, checks and any corrective actions taken should be required by the scheme providers.

6

2 Introduction The Building Research Establishment (BRE) has been commissioned by the Building Standards Division (BSD) of the Scottish Government to undertake a research project to investigate the level of checking of electrical installations to BS7671. The background to the research is that the Building (Scotland) Act 2003 permits building work to be certified by qualified, experienced and reputable building professionals and tradespeople as complying with the building regulations. Certification is an optional procedure to certify compliance with building regulations in Scotland and is only relevant to work that requires a building warrant. Certification can only be undertaken by an approved certifier of design or an approved certifier of construction who is registered with an appropriate approved certification scheme. They must also be employed by an Approved body that has been approved as adopting suitably professional practice to provide a certification service, including quality assurance procedures to check compliance with building regulations.

The certification system is operated by the Scottish Government Building Standards Division (BSD). The use of an approved certifier removes the need for the detailed scrutiny by local authorities. Certification schemes are approved by Scottish Ministers. There are currently five certification schemes and seven scheme providers.

An ‘approved certifier’ can confirm that work subject to building warrant approval meets the necessary standards either by conducting the work themselves or by checking work done by others. The intention to use a certifier should ideally be made known to the local authority at warrant application stage. Certification schemes should raise standards and improve public safety; therefore certification activities are monitored through a series of audits.

The objectives of the research were as follows:

Objective a: Identify the key attributes that support the robustness of the certification scheme. This should look at the level of competence of the certifier and the level of checking undertaken.

Objective b: Identify the key attributes of the verification role undertaken by local authorities when work (that could be certified) is not certified. This should look at the level of competence of the verifier and the level of checking undertaken by them, or by others contracted by the verifier.

Objective c: Consider and report on the consistency of the certified approach taken by approved certifiers.

7

Objective d: Consider and report on the consistency of the approach taken by verifiers for non-certified electrical installations.

Objective e: Consider in terms of the “public interest” whether there is a gap between the robustness of certified (non-verified) electrical installations and equivalent non-certified (verified) electrical installations.

Objective f: Where gaps are shown to exist, identify ways for certification and verification to be further aligned to improve compliance with the Building Regulations.

Objective g: Identify whether any additional levels of certification or verification checking are needed for work covered by the scheme.

8

3 Review of guidance documents The initial phase in the research included desk based research to review the available guidance documents on the competence and level of checking required to assess compliance. The appendix 8.1 provides a list of the reference documents, which have been included in the desk based review.

The desk based research is relevant to objectives (a) and (b) of the project. In addition to the desk based research, one of the BRE research team attended the ‘Scottish Building Standards (Electrical Installations to BS7671)’ course, run by SELECT, which provided additional insight into the electrical certification process and the training given to certifiers of construction. This section highlights the main sources of information and their contents.

3.1 Building Standards process and certification

Building Standards Division: Leaflets, Handbook and Guidance

The easiest way to ensure that certain aspects of building work meet relevant standards is by using an ‘approved certifier’ who can confirm the work meets the necessary standards when a building warrant is needed.

The certification of construction (Electrical Installations to BS7671) Scheme ensures that a competent, skilled and experienced electrician checks electrical work to make sure that it is safe, and meets the necessary standards. When the certifier is satisfied with the work undertaken, they provide a certificate of construction to the person who employed them, which can then be submitted to the local authority to confirm that all electrical work complies with the relevant standards. The certificate of construction also includes a declaration that other aspects of the building regulations were certified. This is in the form of a checklist that is appended to the certificate. Under no circumstances can work be excluded from a certificate of construction for electrical installation.

Certification is optional but the benefits of using an approved certifier include the following assurances:

work will meet building regulations;

trained, competent and experienced professionals will conduct the work;

Approved certifiers are independently monitored and carry professional indemnity insurance;

each scheme has a robust complaints procedure, and

9

a discount can be received on the cost of submitting a building warrant application.

Certified work does not need to be inspected, or verified, by the local authority; therefore application processing times are also likely to be reduced. Local authority verifiers check that the information on the certificate is correct by confirming it against the certification register. A process exists should verifiers find incorrect information on a certificate of construction.

Non-certified individuals and firms may still complete work that requires a building warrant, but no certificate of construction can be attained. A local authority verifier must then decide how to fulfil the requirement for reasonable inquiry with regards to checking electrical installation work. This process is likely to result in longer processing times for completion certificates than the certificate of construction approach.

Local authority verifiers are not required to supervise or monitor every activity on a building project. The responsibility for the supervision of building work lies with the applicant who should appoint a suitably competent building professional to supervise the work to ensure the standard is satisfactory and meets the building regulations. In signing the completion certificate, the relevant person is declaring that work has been carried out according to the building warrant plans, and also in accordance with building regulations. The verifier must then check the completion certificate; this does not remove the responsibility from the person who signs the certificate.

A building warrant may cover multiple buildings, in which case individual completion certificates and therefore certificates of construction are required for each dwelling. For non-domestic properties, the applicant may choose to submit one completion certificate for all properties included on the warrant.

A liaison group was formed in 2007 for the key stakeholders involved in certification of construction for electrical installations. These stakeholders include representatives from scheme providers, local authority verifiers and Building Standards Division. The liaison group meet to discuss themes and issues, and guidance is then developed and disseminated to all Scheme Members to encourage a consistent approach.

3.2 Process of certification of construction for electrical installations to BS7671

3.2.1 Certification

The certificate of construction (Electrical Installations to BS7671) Scheme was approved on 7 December 2004. The Scheme is run jointly by two scheme providers; SELECT (the trade association for the electrical contracting industry in Scotland) and NICEIC (an independent UK certification company). They represent many electrical contractors working in Scotland.

10

As a certificate of construction can only be submitted for work which requires a building warrant, an approved certifier may check that a building warrant has been issued; however, the onus to apply remains with the building owner.

Individuals can search for certified companies on the certification register, held on the Scottish Building Standards website (http://www.certificationregister.co.uk). The validity of all certificates of construction can be checked on the certification register.

Certificate of construction (Electrical Installations to BS7671) Scheme Guide

A scheme guide is published jointly by the scheme providers (SELECT and NICEIC), which details the operation and criteria for registration in the scheme.

The scheme requires approved certifiers to determine whether or not electrical installations meet the requirements of BS7671 and comply with Scottish Building Standards. In addition, designations are included for fire detection and fire alarm systems to BS 5839-1 and BS 5839-6 and emergency lighting systems to BS 5266.

A code of conduct is outlined within the scheme guide. The main requirements are for approved certifiers of construction and approved bodies to:

act with fairness and integrity;

have regard for public interest;

not maliciously or recklessly injure the reputation of another person;

declare conflicts of interest and to uphold the reputations of the Scheme.

Approved certifiers are also required to exercise appropriate skill and diligence, maintain and broaden their expertise and only undertake tasks for which they are suitably qualified. Individuals can apply to the Scheme if they can demonstrate their qualifications and eligibility. Approved certifiers must be employed by a reputable company, or hold approved body status themselves as a sole practitioner. They can then display the ‘Approved Certifier Registration Mark’. The conditions for membership of a scheme are set by the scheme providers and approved by Building Standards Division.

Approved bodies support the approved certifiers employed by them. A business that has been operating for more than six months, and which employs at least one approved certifier can apply to become an Approved body. To qualify, businesses must hold adequate public liability insurance (of at least £2 million), provide access to training for its certifiers, hold records for at least five years and allow auditing by the Scheme Providers. Each approved body must also employ at least one certification co-ordinator who has the responsibility of counter-signing all certificates. A sole trader can be an

11

approved certifier of construction, a certification co-ordinator and an approved body, but must meet the requirements of each role and submit separate applications for each. The co-ordinator need not be an electrician; it is a purely administrative role.

Approved certifiers must conduct an appropriate inspection and associated testing to ensure works comply with all relevant legislation before issuing a certificate of construction. Certificates of construction follow a template form which is issued by the scheme provider following consultation with Building Standards Division.

The scheme provider (either SELECT or NICEIC) is responsible for administering the scheme, ensuring that applicants to the scheme meet all requirements, and must regularly audit members to ensure that compliance is achieved. Scheme providers must also review membership regularly. They in turn must allow auditing by Building Standards Division and must also deal with any complaints, disciplinary action and appeals from members and the public. Generally, only complaints related to technical issues will be pursued, matters relating to cost, for example, should be dealt with by contractors.

A local authority may be both a verifier and an approved body for certification; however they may not certify work which is to be verified within their local authority.

Scheme Providers Code of Conduct, Code of Practice and Scheme Registration Rules

The SELECT Code of Practice aims to ensure the best possible relationship between Scheme Members and their customers. In addition to requiring members to conduct work in compliance with all building regulations and associated legislation (including Health and Safety), the Code of Practice also requests that Members use their skills, knowledge and experience to complete the work in a timely and economical manner.

Quotations and estimates for work are recommended to be in writing, and Members are urged to request confirmation of the acceptance of any quotation, also in writing, before any work commences. Members are reminded that they must hold necessary insurance; public liability insurance is required as prescribed by the scheme provider and must be appropriate to the range of work to be undertaken. Employee’s liability insurance cover may also be required. Evidence of insurance should be available for inspection.

The Code of Practice also outlines the complaints procedure, indicating how customers should proceed should they be unsatisfied with work undertaken. Complaints must be first made to the Member who undertook the work, and they in turn must investigate all complaints against them. SELECT will then assist if an agreement cannot be made, with an independent inspection conducted if necessary.

The NICEIC Consumer Code of Conduct helps ensure that members work in a safe environment, ensures that genuine complaints cases are dealt with appropriately, and

12

aims to achieve the best possible outcome for all involved parties. It requires NICEIC to address complaints in an impartial manner, resolve them expediently and maintain communication with customers during the process. In return, customers are required to be respectful of NICEIC members and staff, co-operate with all complaints procedures and not fabricate or withhold information.

3.2.2 Standards

Building Standards Technical Handbook: Section 4 – Safety (Domestic and Non-Domestic)

The Building Standards Technical Handbooks provide guidance on achieving the standards set in the Building (Scotland) Regulations 2004 and are available in both domestic and non-domestic versions. Section 4 covers safety aspects including access, stairs and ramps, protective barriers, aids to communication, hazards and dangers and security. Electrical safety (4.5) and electrical fixtures (4.6) are also included.

Section 4.5: Electrical Safety

In both the domestic and non-domestic versions, the mandatory requirements of electrical safety are that:

Every building must be designed and constructed in such a way that the electrical installation does not:

a) Threaten the health and safety of the people in, and around, the building,

b) Become a source of fire.

The hazards associated with electrical installations are shocks or burns resulting from contact with electricity and injuries and damage resulting from fires in buildings, caused by unsafe installations. An increase in the prevalence of electrical systems in buildings and in the demand upon them is of concern, and increases the risks posed. Section 4.5 of the building standards intends to ensure that electrical installations are safe in terms of the hazards outlined. Installations should therefore safely accommodate the likely maximum demand; incorporate appropriate automatic devices for protection against overcurrent or leakage; and provide means for isolating parts of the installation or equipment should it be necessary for safe working and maintenance.

The standard applies to fixed electrical installations in buildings, e.g. electrical wiring and associated components such as socket outlets and permanent equipment. Portable equipment and appliances are not covered by this standard. The standard also outlines specific measures to be adopted when working with extra-low voltage and above low voltage, including isolation and cut-off switches.

13

The standard for electrical safety in both the domestic and non-domestic versions requires electrical installations to be designed, constructed, installed and tested in accordance with the findings in BS7671. It also specifies that this work should be undertaken by a person with professional expertise, with relevant technical knowledge, practical skills and experience. It further states that an approved certifier of construction can certify the compliance of an electrical installation.

Section 4.6: Electrical fixtures

This section is only applicable for domestic properties. The mandatory requirements are that every building must be designed and constructed in a way, such that electric lighting points and socket outlets are provided to ensure the health, safety and convenience of occupants and visitors.

In order to achieve the mandatory requirements, and in light of the increasing number of electrical appliances used in homes, it is recommended to provide an adequate number of power points to reduce the possibility of overloading sockets, which can cause electrical fires. This is specified as at least four 13A sockets in each apartment, six in the kitchen and an additional four throughout the dwelling. In addition, at least one lighting point should be provided in every circulation space, kitchen, bathroom, toilet and all other spaces with floor areas of more than 2m2. Required lighting levels are set for common areas of domestic buildings, including stairs and ramps. Door entry systems with remote access and intercom are also specified for buildings with multiple dwellings where there is a common entrance.

BS7671: 2008 (as amended) Requirements for electrical installations (IET Wiring Regulations – 17th Edition)

The Wiring Regulations, BS7671, present the requirements for the design, erection and verification of electrical installations. The regulations provide for safety of persons, livestock (where applicable) and property against damage and danger and for proper functioning including requirements for continuity of service (e.g. for life support machines). Potential damage and dangers include electric shock and electrical fires.

The regulations require good workmanship by competent persons, or supervision by the same. They also require that on completion of installations, and before they are put into service, an appropriate inspection and testing must be carried out, again by a competent person. BS7671 includes a list of other British Standards which are made reference to within the regulations and a wide range of definitions and symbols to further understanding.

Inspection and testing procedures require electrical contractors to ‘verify’, as far as is reasonably practicable, that the requirements of the regulations are met.

14

In order to provide for safety and proper functioning, detailed steps are outlined for different hazards:

Electrical shock: hazardous-live-parts shall not be accessible (and vice versa). Designated protective measures detail how this can be achieved, including through separation and insulation.

Thermal effects: thermal effects include heat, combustion, flames and smoke and safety cut-out. Specification of materials, location and evacuation procedures are included.

Overcurrent: includes steps to ensure that live conductors are protected for auto-disconnection of supply in the event of overcurrent or related faults.

High voltage: includes steps to ensure damage does not occur as a result of high voltage, including electromagnetic disturbances.

Rules, and precautions to be taken, in the selection and erection of equipment, wiring systems and earthing and protection are included. Additional requirements are included to ensure safety in special locations such as baths and showers, swimming pools, saunas, medical facilities, caravans and photovoltaic panel installations.

There is also provision for the introduction of new materials and inventions. Where these innovations lead to a departure from regulations, it is necessary to ensure that the resulting degree of safety is not less than would be obtained through compliance with the regulations.

BS7671 also includes information on the conductivity of materials (e.g. copper and aluminium wiring), the harmonised cable core colours, and diagrams of parallel, ring and radial circuit arrangements.

The document includes copies of all appropriate certificates:

electrical installation certificate (to be completed by the electrical contractor),

minor electrical installation works certificate (where no new circuit is provided),

schedule of inspections (for new electrical works),

electrical installation condition report, and

schedule of test results.

15

Work carried out in accordance with BS7671 will satisfy the requirements of Building Regulation 8: Durability, Workmanship and Fitness of Materials and also the requirements of the sections regarding Electrical Safety.

Certification of Construction – Technical Guide

The purpose of the Technical Guide is to provide information to electrical installers who are registered in the scheme for electrical certification of construction (Electrical Installations to BS7671) to assist them in ensuring that building regulations are met. The guidance document also gives information on the types of work which require a building warrant and outlines the process for certification. The Building Standards of particular relevance to electrical installations are listed below, those which are relevant to non-domestic buildings (ND), or domestic buildings only (D) are marked:

Structure – 1.1 [prevention of collapse through notches, holes and chases]

Fire Safety – 2.1(ND), 2.2, 2.3, 2.4, 2.5, 2.9, 2.10, 2.11 [fire stopping, protecting load bearing structures, provision of escape lighting, and fire detection and alarm systems]

Environment – 3.10, 3.11(D), 3.12(ND), 3.13(D), 3.14, 3.17, 3.20 [sealing of openings and service penetrations against precipitation, accessible bathrooms and shower rooms, heating and ventilation provision]

Safety – 4.1(D), 4.2, 4.3, 4.5, 4.6(D), 4.7(ND), 4.8 [access and obstructions within buildings, including stairs and ramps, electrical safety, electrical fixtures, aids to communication]

Noise – 5.1, 5.2 (if relevant to ND) [maintaining noise prevention measures]

Energy – 6.2, 6.3, 6.4, 6.5, 6.6, 6.7, 6.8 [maintaining energy conservation measures including insulation, artificial lighting, mechanical ventilation and air conditioning, commissioning of building services and building user information]

Sustainability – 7.1 [sustainability labelling].

The guide is updated regularly, with the most recent version being published in 2014. This version supersedes the previous 2010 version and incorporates a number of changes, including the introduction of Section 7 of which section 7.1 is of relevance to electrical installers, and also significant guidance on the installation of carbon monoxide detection systems (standard 3.20).

The guide details how these Standards can be met, providing guidance in addition to the Building Standards Technical Handbooks. An example of the ‘scheme checklist’ is given, which notes the above sections of the Building Standards, and asks the certifier

16

to confirm how they have established that the work complies; either by checking another’s work, checking their own work, or by referring to a competent third party for confirmation. The scheme checklist shows how compliance has been determined. Further to this, examples of the electrical installation certificates are given. Appropriate British Standard certificates should be completed where applicable, including ‘Electrical Installation Certificate (BS7671)’ and ‘Fire Detection and Fire Alarm Installation Certificate (BS5839-6)’.

Finally, guidance is given as to the process that should be adopted if some of the work that is being certified was not carried out by the certifier’s approved body (e.g. the installation of a fire detection system by a third party). In this situation, reasonable inquiry should be made as to the competence of the installer, and a copy of the relevant BS certificate should be obtained and submitted with the certificate of construction. If all work to be certified has not been conducted by a member of the Approved body, then a certificate of construction can only be submitted if the work has been supervised by a certifier. If supervision has not taken place, then a certificate of construction cannot be submitted. In this instance, a Periodic Inspection Report accompanied by a Schedule of Inspections and test results should be submitted to the Local Authority Building Standards Verifier, by either a certifier or a member of SELECT or NICEIC. In this situation, a certificate of construction cannot be issued, as the electrician cannot say whether all work complies with building standards, as they were not there when it was undertaken.

Competence is not defined within the guidance, but ‘professional expertise’ is outlined under the section on electrical safety:

‘Electrical installation work should be inspected and tested by persons who possess sufficient technical knowledge, relevant practical skills and experience for the nature of the electrical work undertaken.’

Best Practice Guides 1 – 8

A series of Best Practice Guides have been published by Electrical Safety First. They aim to ensure that everyone in the UK understands the importance of electrical safety, and that electrical safety remains a priority for consumers, trade and government. They campaign to improve safety regulations and provide expert advice and information on electrical safety.

The Best Practice Guides have been written in association with leading industry bodies including BSI Product Services, City & Guilds, Electrical Contractors Association, NICEIC and SELECT. The guides are expected to be used by electrical installers, designers, verifiers and inspectors, but may also be of interest to specifiers, builders, building control bodies and customers. The Guides are as follows:

17

1. Replacing a consumer unit in domestic premises where lighting circuits have no protective conductor

This guide recognises that unearthed lighting circuits do not comply with BS7671 and provides guidance on how to protect customers and installers from the dangers which may arise during the replacement of consumer units installed in homes built before 1966 which were wired in accordance with the 13th edition, or earlier, of the IET Wiring Regulations.

2. Guidance on the management of electrical safety and safe isolation procedures for low voltage installations

The purpose of this guide is to provide practical guidance on the procedures which should be followed during construction and refurbishment projects and during maintenance to manage electrical safety, with particular emphasis on low voltage safe isolation.

3. Connecting a microgeneration system to a domestic or similar electrical installation

The third Guide aims to provide an overview of microgeneration intended to produce electrical energy, including the legal and contractual issues and guidance on the particular electrical and electrical safety issues which arise when installing microgenerators.

4. Electrical installation condition reporting: classification codes for domestic and similar installations

The aim of this guide is to provide practical guidance on the use of Classification Codes to be used during periodic inspection and testing of an electrical installation. This guidance is of benefit to the person ordering an inspection or test report.

5. Electrical installations and their impact on the fire performance of buildings (Part 1 – Domestic premises: single family units (houses, flats, maisonettes, bungalows))

This guide aims to promote best practice where electrical work requires, or has required, the penetration of linings forming ceilings and walls. It is considered, that by following the guidance, electrical installation work will not compromise the necessary fire performance provisions that are incorporated into domestic premises.

6. Consumer unit replacement in domestic and similar premises

18

The aim of this guide is to provide best practice guidance where the consumer unit is being replaced in domestic or similar premises, to protect customers and installers against dangers which may arise from the existing installation which may not comply with the current edition of BS7671 (as amended).

7. Test instruments for electrical installations: accuracy and consistency

This guide promotes best practice by providing practical advice and guidance for electrical installers, verifiers, inspectors and other competent persons who have responsibility for testing electrical installations. BS7671 does not require regular calibration of test instruments but those responsible for testing should have a procedure in place to maintain confidence in the accuracy of all test instrumentation.

8. Selection and use of plug-in socket-outlet test devices

This guidance, for electrically competent and skilled persons only, addresses concerns by the Health and Safety Executive (HSE) that simple socket-outlet test devices have been relied on to demonstrate that socket-outlets are safe. No socket-outlet test device can be relied on alone to provide full assurance that a socket-outlet is safe to use.

3.2.3 Verifiers

Guidance for verifiers of non-certified electrical installations and guidance on ‘reasonable inquiry’

This guidance document was written to assist local authority verifiers in their role in making reasonable inquiry as Enforces of Powers vested in them by the Building (Scotland) Act 2003. It aims to clarify criteria to ensure consistency and credibility. When a completion certificate is not accompanied by a certificate of construction from an approved certifier, verifiers must establish an approach to ensure that all building regulations are adhered to. Local authorities, as both verifiers and enforcers must have processes in place to address and deal with all types of installations carried out by both approved certifiers and non-certified installers.

The verifier must make ‘reasonable inquiry’ to check the validity of a completion certificate. Where an approved certifier of construction is used and a certificate of construction is issued then the verifier must check the scope of the certificate is correct, and also check the status of the approved certifier and approved body.

19

When a certificate of construction is not submitted, then the verifier must make reasonable inquiry to ascertain whether or not the completion certificate should be accepted. The completion certificate is confirmation that the work has been carried out in accordance with the building warrant and conforms to submitted drawings and design details. It also confirms that the construction, and all associated electrical installations meet building regulations. It reminds verifiers that the main principle of the building regulations is to protect the public interest.

An assessment of the risk an installation poses should be taken to establish what level of reasonable inquiry is necessary but a minimum checking procedure should be identified for all completions. The verifier must accept a completion certificate if, following reasonable inquiry they are satisfied that the work meets all relevant regulations and is in line with the building warrant. Reasonable inquiry may include the following:

checking that the correct certificate has been submitted;

checking that the schedule of inspections has been submitted if required; and

checking that certificates and reports have been completed and signed by a competent person. Competence is a vital requirement.

A risk assessment of a planned construction allows a Construction Compliance and Notification Plan (CCNP) to be created. The CCNP is issued to an applicant (or agent) with the building warrant and highlights the schedule of site visits or other methods of contact required to check compliance.

3.3 Competence of those carrying out electrical checking

Health and Safety Executive Guidance

The Health and Safety Executive (HSE) has the responsibility for enforcing a wide range of health and safety legislation including the Health and Safety at Work Act 1974 and the Electricity at Work Regulations 1989. As part of these responsibilities, HSE must also encourage the effective management and control of electrical risks at work. The electrical injuries that may be sustained include electric shock, electrical burns, loss of muscle control and thermal burns (resulting from electrical fires). HSE publish guidance documents and also link to industry best practice guides and codes of practice to ensure the safety of workers and the wider public.

The Health and Safety Executive (HSE) present accident case studies to help inform the workforce and highlight the precautions which should be taken to avoid incidents. The electrical accident case studies cover incidents related to overhead power lines, electrical maintenance, excavations and ignition of flammable atmospheres. Electrical accidents commonly occur whilst equipment is being maintained. These mainly occur

20

due to inadequate training, poor supervision or insufficient risk assessment. Nationally electrical incidents account for about 10% of all fatalities at work.

A perspective of electrical safety based on incidents

The Institution of Engineering and Technology compiled incident occurrence data recorded by a Health and Safety Executive (HSE) Electrical Inspector in the East and South East of England from January 2001 to December 2008. During this time, in this region, there were 33 fatalities and 94 major injuries in 151 serious incidents at work. Of these fatalities, 24 were caused by incidents associated with low voltage fixed installations or equipment. The causes and consequences of these incidents include the following:

failure to isolate, inadvertent contact with exposed conductors and poor maintenance of wiring circuits leading to electric shock, burns and falls;

use of non-insulated tools and failure to isolate, leading to explosions, fire and burns;

poor maintenance of equipment, including failure to isolate, leading to serious injuries such as blinding, burns and electric shock.

Investigations by HSE have shown that the majority of incidents are fundamentally caused by issues with procedure (55%), maintenance (36%) and design (9%). Health and safety at work is the responsibility of everyone within an organisation and as such awareness of electrical risks should be raised with all members of a company. Risk management can ensure that incidents are minimised. A full risk assessment should be systematically undertaken, and safe systems and procedures should be identified and followed. Work should be planned using these systems, and roles and responsibilities should be clearly defined. Communication between all levels of responsibility is vital; managers and leaders should promote a strong safety culture.

Qualifications for electricians and electrical installers

To qualify as an electrician, it is necessary to have an industry recognised NVQ (National Vocational Qualification), at Level 3; e.g. Level 3 Diploma in Electrotechnical Services (Electrical Maintenance), Level 3 Diploma in Installing Electrotechnical Systems & Equipment, Level 3 Diploma in Electrical Installations. Qualifications can be completed whilst working, or through an Apprenticeship. Normally Apprenticeships take two to four years to complete. Electrical qualifications are accredited by a range of bodies.

Electricians may gain further qualifications once they are in work, including Periodic Inspection and Testing and 17th Edition (IET) Wiring Regulations.

21

In order to gain access to construction sites it is almost always necessary to provide proof of identity, competence and qualification levels. An Electro-technical Certification Scheme (ECS) card is the sole identity and competence card for electrical operatives in the UK and is endorsed by industry. It is affiliated with the Construction Skills Certification Scheme (CSCS). An ECS card can be applied for through SJIB, the Scottish Joint Industry Board for the Electrical Contracting Industry.

The main objective of SJIB is to regulate relations between employers and employees of the electrical industry in Scotland and to additionally, in the public interest, regulate and control employment, the level of skill and proficiency and health and safety competence of electrical operatives. To apply for an ECS card, a Health and Safety Assessment must first be undertaken, unless proof of a recognised Health and Safety qualification can be given. There are twelve grades of card including ‘Electrician’, ‘Approved Electrician’ and ‘Technician Electrician’, plus cards can be gained for visitors, managers, office staff and related disciplines as required. Each grade has a set of additional mandatory skill and experience requirements. SJIB also run training schemes for Apprentices and Adult Trainees in addition to the ECS card scheme.

Individuals can apply to join the certification of construction (Electrical Installations to BS7671) Scheme if they are eligible to qualify for an SJIB (Scottish Joint Industries Board) Approved Electrician (ECS) Grade Card, and are employed by an Approved body. In addition, individuals must meet certain qualifications, including a Level 3 certificate in the requirements for electrical installations BS7671: 2008 (or equivalent SJIB grading) and a demonstrated knowledge of Scottish building regulations and the building standards system. The specific courses to be taken are dependent on the date when a recognised apprenticeship was completed, as earlier training schemes (pre-1995) did not cover the necessary Electrical Design and Verification, or Inspection and Testing training. Additionally, an Advanced Competence Assessment (ACA) must be completed by electricians whose apprenticeships were completed after 1995.

22

4 Survey of verifiers A survey of verifiers was undertaken in order to gather information on the approach to checking of electrical installations across all 32 local authorities. The survey was created online using ‘survey-monkey’. The questions included in the questionnaire are given in Appendix 8.3.

In total, 24 of 32 local authorities had completed the survey (75%). However, only 21 local authorities completed the survey from question 5 to 22, and 23 completed questions 23 and 24. Only half of the initial respondents were able to complete questions 25 to 27 as often this information was not readily available to verifiers.

The survey responses can be viewed in detail in Appendix 8.4; the following sections highlight the key findings and trends.

The survey was constructed to allow verifiers to follow the same series of questions, depending on their answer to question 4:

‘Where electrical installations are not certified by an approved certifier of construction, please indicate the most common means of conducting reasonable inquiry within your local authority’.

It should be noted that the copy of the questionnaire shown in Appendix 8.3 shows all questions and appears which might appear to repeat. However, when the verifiers completed the survey online, they would only see one set of questions, relevant to their chosen response to question 4.

4.1 Use of guidance documents

4.1.1 Questions 2 and 3

Verifiers were first asked to indicate, from the list below, which guidance they use when undertaking reasonable inquiry on non-certified electrical installations to BS7671 (e.g. those that are submitted without a certificate of construction). They were required to state how often they use specific guidance, and also if they additionally use guidance which was not included in the list.

SBSA/SABSM 2006 Guidance for verifiers on electrical installations not certified

BS7671

On-site handbook (Best Practice Guides, see Section 3)

23

Building Standards Technical Handbooks.

As can be seen in Figure 4.1, 54% of respondents said they always used the SBSA/SABSM guidance document, with a further 30% saying they used it ‘often’ or ‘occasionally’. Two of the councils (8%) said they did not use the SABSM (LABSS) guidance.

Around half of those who responded (54%) said they used BS7671 for reference when undertaking reasonable inquiry and 50% (12 local authorities) said they used the Building Standards Technical Handbooks. More than half (54%) said they never used the on-site handbook (Best Practice Guides, see Section 3).

Other guidance used by verifiers included six internal or local authority policies. The main reasons given for the use of these internal policies were as follows:

1. To include a ‘checklist’ for surveyors and verifiers.

2. To deal with small practitioners who for whatever reason do not wish to join SELECT or NICEIC but who have been competently undertaking minor works for a number of years.

Figure 4.1: What guidance do you use when undertaking reasonable inquiry on non-certified Electrical Installations to BS7671 (Question 2)

0%

10%

20%

30%

40%

50%

60%

SBSA

/SABSM

2006

Guidan

ce for Verifiers

BS 7671

On‐site Handbook

Building Standards

Technical Handbook

Other

What guidance do you use when undertaking reasonable inquiry on non-certified Electrical Installations to BS7671?

Always Use

Use Often

Use Occasionally

Do Not Use

24

3. To take account of specific geographical/location challenges.

One other local authority said they had direct contact with a professional body (e.g. SELECT) for background advice to allow them to conduct reasonable inquiry.

4.2 Most common means of reasonable inquiry

4.2.1 Question 4

The verifiers were then asked the following:

‘Where electrical installations are not certified by an approved certifier of construction, please indicate the most common means of conducting reasonable inquiry within your local authority’ from the following options:

1. Relevant documentation is sought from the installer to confirm that the installations are designed, constructed, inspected and tested in accordance with the requirements of BS7671

2. Arrange for an independent inspection and test to be carried out by a competent external consultant

3. Arrange for an independent inspection and test to be carried out by a competent employee of the local authority (not a building standards surveyor)

4. Inspection by building standards surveyor

5. Acceptance of completion certificate and no further action

6. Another route is taken.

The majority of respondents (92%) said that they requested relevant documentation from the installer to confirm that installations met BS7671 (see Figure 4.2). Two authorities took an alternative approach. One only accepted certification by SELECT or NICEIC and the other followed an internal procedure, where they also accept electrical work carried out by non-scheme members.

25

4.2.2 Question 5

Of the 92% who said they request documentation to confirm installations meet BS7671 requirements, 86% (19 of 22 authorities who answered this question) gave a figure for the percentage of reasonable inquiry which are conducted in this way. Seventeen (89%) of these said that this approach was taken for 80% or more of reasonable inquiry; nine (47%) said that 100% of reasonable inquiry are conducted using this approach.

4.2.3 Question 6

In question 4, the majority of respondents (92%) said that where electrical installations are not certified by an approved certifier, they request relevant documentation from the installer to confirm that the installations meet BS7671. Question six asked which other approaches are taken by verifiers, see Figure 4.3. Other approaches included the following:

Figure 4.2: Where electrical installations are not certified by an Approved Certifier, what is the most common means of conducting reasonable inquiry? (Question 4)

Relevant documentation is sought from the

installer to confirm the installation

92%

Arrange for an independent inspection and test to be carried out by a competent external

consultant0%

Arrange for an independent inspection and test to be carried out

by a competent employee of the Local Authority (not a Building Standards Surveyor)

0%

Inspection by Building Standards Surveyor

0%

Acceptance of completion certificate and no further action

0%

Another route is taken8%

Where electrical installations are not certified by an Approved Certifier, what is the most common means of conducting reasonable inquiry?

26

Arrange for an independent inspection and test to be carried out by a competent external consultant.

Proof of competence where certifiers or scheme members are not used.

Acceptance of a condition report from an electrician who meets the relevant "competent person" criteria.

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

Arrange for anindependent

inspection and testto be carried out by

a competentexternal consultant

Arrange for anindependent

inspection and testto be carried out by

a competentemployee of the

Local Authority (nota Building Standards

Surveyor)

Inspection byBuilding Standards

Surveyor

Acceptance ofcompletion

certificate and nofurther action

Another route istaken

What other means of conducting reasonable inquiry are used within your Local Authority?

Figure 4.3: What other means of reasonable inquiry are used within the Local Authority? (Question 6)

27

4.3 Competence of the electrical installer

4.3.1 Questions 7 and 8

The installer’s competence was checked by 95% (20 of 21 respondents who answered this question); proof of competence included copies of trade cards (SJIB) or online checking of the certification scheme membership. In some cases providing a copy of the SJIB trade card has been seen as acceptable by verifiers. Even where non-certified work has been submitted, evidence that the individual or company is a member of the certification scheme has been taken as evidence of competence by the verifiers. Acceptable levels of qualifications and skills are shown in the graph in Figure 4.4.

4.3.2 Question 9

When projects are more complex or contain specialist elements, 86% (18 of 21 respondents who answered this question) said they would take the same approach as for other less complex works (as shown in Figure 4.5). Those who took a different approach asked for certification for highly complex works, or additional certificates to cover more specific or specialist elements such as emergency lighting and fire alarms.

Figure 4.4: What level of qualifications, skills and experience would you accept for electrical installers? (Question 8)

95.2%

81.0%

57.1%

33.3%

57.1%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Approved

Certifier

(SELEC

T/NICEIC)

Mem

ber of

appropriate

trad

e association

Qualified

Electrician

(SVQ/N

VQ Level

3)

Completed

'Req

uirem

ents

for Electrical

Installations to

BS7671: W

iring

Regulations'

Course

SJIB Graded

What level of qualification, skills and experience would you accept for electrical installers?

28

4.4 Alternative means of reasonable inquiry (Questions 10 to 22)

Question 4 in the survey asked the verifiers to identify their most common means of conducting reasonable inquiry. The survey was created to ensure that regardless of the reasonable inquiry approach taken, the verifiers would have to answer the same set of questions. This meant that questions 5 to 9 were repeated, with a similar set for each possible answer to question 4. As none of the verifiers selected the options 2 to 5 (see section 4.2.1), there were no responses to questions 10 to 22. The full survey can be seen in Appendix 8.3.

4.5 Issues and rejections of completion certificates

4.5.1 Question 23

Just over a third of verifiers (9 of 23 respondents who answered this question) said they had previously rejected a completion certificate for reasons related to the electrical installation (see Figure 4.6). The main reason for rejection was being unable to confirm the competence of installers, or installers being found to not have suitable qualifications.

Figure 4.5: For specialist elements, is the same approach used? (Question 9)

Yes86%

No14%

When a project has a specialist element, or if highly complex, is the same approach

used?

29

Other reasons included fraudulent or incorrect information included in BS7671 certificates and situations where work was clearly incomplete despite a certificate being issued.

4.5.2 Question 24

Almost half (43%) of all 24 respondents said they had raised comment on the certificate or the installation with the applicant or certifier when assessing completion certificates which are submitted with a certificate of construction (Figure 4.7). The reasons for raising comment included the following:

where work was found not to be in compliance with building regulations e.g. location of smoke detectors or light switches

sub-standard electrical work

incomplete work (including cases of bare wires and incomplete distribution boards)

fraudulent use of certificates, or errors in certificates.

Figure 4.6: Have you ever had to reject a completion certificate? (Question 23)

No61%

Yes39%

Have you ever had to reject a completion certificate for electrical

installation related reasons?

30

4.6 Estimation of processed completion certificates

4.6.1 Question 25, 26 and 27

The verifiers were asked to estimate the number of the following:

1. Completion certificates received which included electrical work.

2. Completion certificates processed which included electrical installation work, which were submitted with a certificate of construction for the electrical installation.

3. Completion certificates processed which included electrical installation work, which was non-certified, i.e. they were submitted without a certificate of construction for the electrical installation.

Many of the respondents were unable to complete these questions, as the information was not readily available. However, 15 responses were received and the results are shown in Figure 4.8.

No57%

Yes43%

Has there ever been cause to raise comment on the certificate or the installation with the

applicant or Certifier?

Figure 4.7: Has there ever been cause to raise comment on the certificate? (Question 24)

31

Figure 4.8: Number of Certificates (Question 25, 26, 27)

0

500

1000

1500

2000

2500

3000

3500

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

May 2010 - April 2011

Number of completion certificates processedwhich included electrical installation work?

Number of these completion certificates whichwere submitted WITH A CERTIFICATE OFCONSTRUCTION for the electrical installation?

Number of these completion certificates whichwere non‐certified, i.e. they were submittedWITHOUT A CERTIFICATE OF CONSTRUCTION?

0

500

1000

1500

2000

2500

3000

3500

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

May 2011 - April 2012




0

500

1000

1500

2000

2500

3000

3500

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

May 2012 - April 2013




32

4.7 Additional comments

4.7.1 Question 28

The verifiers were invited to add any further comments related to the survey, or to the research, as follows:

“Can we suggest that some work be carried out as to why certifiers of construction do not submit certificates of construction to support the submission of a completion certificate. The Government wishes to see an increase in the use of certificates of construction and there is a feeling that the low level of usage is an issue created by verifiers when it is not. There requires to be some work carried out with electricians / developers / architectural agents / applicants to promote their use.”

“The non-certified route creates a huge paperwork burden on staff and archiving - an electronic solution at source would be good. We have had to occasionally challenge the submission of membership cards as some have been found to be fraudulent.”

“We recognise that this is an important piece of research and we would like to see clear and concise recommendations that can be applied in a nationally consistent manner as an outcome of this study.”

“We have stuck to the SABSM Guide despite some strong opposition from certain electrical contractors and it has to be said some criticism from the Building Standards Division who suggested we may be creating a barrier to trade. If an electrician is not a member of a recognised trade body then we do accept third party certification from someone who is.”

33

5 Interviews and reviews

The research involved carrying out a number of interviews and reviews with both verifiers and certifiers of construction; the latter included approved body coordinators as well as the certifier.

5.1 Verifiers – interviews and reviews

The selection of verifiers was made with the aim to include small, medium and large authorities, as well as a range of city, town and rural locations and a geographical spread. The verifiers selected were designated as shown in table 5.1.

1 Small Rural

2 Medium City

3 Large Rural / towns

4 Small Town

5 Medium/Large Rural / towns

6 Medium Rural / towns

Table 5.1: Verifiers

The interviews with the verifiers included 12 questions. The questions examine the approach to compliance checking of non-certified work within the authority and the requirements made with regards to competence and qualifications of individuals undertaking checking of electrical installations. The interaction between verifiers and certified work was also examined. The interview questions are given in Appendix 8.5.

A review of projects was also undertaken. BRE requested that nine project files be supplied, including three larger or more complex projects, three medium and three small or less complex jobs. The purpose of the reviews was to confirm that the approach taken in terms of reasonable inquiry for electrical installations agreed with the details given during the interview sessions. Additionally, to examine how non-certified work is assessed and evidence that competent professionals were involved is recorded.

34

5.2 Certifiers – interviews and reviews

A similar approach was taken to the selection of certifiers. The two scheme providers (SELECT and NICEIC) assisted BRE by directly contacting their scheme members and requesting their assistance and co-operation. Five certifiers confirmed their agreement for interview, they are categorised as shown in Table 5.2.

1 1 certifier Medium SELECT

2 1 certifier Small SELECT

3 2 certifiers Large – multi-disciplinary company

NICEIC

4 1 certifier Sole practitioner NICEIC

5 1 certifier Medium NICEIC

Table 5.2: Certifiers

The approach to the interviews addresses the issues of competence and procedures undertaken in certification. There were 13 interview questions, which are reproduced in Appendix 8.6. The projects review addressed the process and procedures undertaken by certifiers and approved bodies. It was not a technical review of the work that was carried out, but rather the thoroughness of processes that were undertaken.

5.3 Findings - verifiers

Verifier 1 The first verifier was a small local authority, mainly rural with a series of small to medium towns clustered together in one area. The summary of the project reviews is given in Table 5.3.

Interview

The local authority verifier took a proactive approach to certification of construction when the certification scheme began. They actively promoted the use of certification, even although it is not mandatory, they also accept other recognised means of proving the competence of electrical installers. Where an electrical installation is not certified, the verifier accepts a BS7671 certificate (including test and inspection schedules) from a SELECT, NICEIC or other UKAS accredited body, along with proof of membership. An alternative option, which the local authority has never used, would be to appoint a competent person to inspect the electrical installation to confirm that it meets the necessary regulations.

35

Where an installer completing the BS7671 certificate is not a member of a recognised trade body, then the verifier will accept a SJIB card as proof of competence. Initially, when the scheme started they accepted any SJIB card, as it wasn’t clear what the different types meant. Following this, the verifiers had a period of not accepting any SJIB card, as they couldn’t be sure which electricians had the necessary competence to undertake work. The resulting conflict with SELECT and SJIB about this, led to the verifiers accepting three kinds of SJIB cards (technician, approved electrician or electrician).

As part of their reasonable inquiry process, the verifier checks online to confirm the validity of: the certificate of construction, the approved body, the approved certifier, or the membership of the contractor with SELECT or NICEIC. A print out of this check is included within the project files. Where a SJIB card is presented, a copy of this is taken.

None of the local authority verifier staff are electricians, so they rely on their check of the competence of the installer. Most of the verifiers in the local authority have degree level qualification and some are MRICS or MCIOB. On-site checks of the electrical installations generally occur at completion stage, although occasionally a verifier may be on-site at an early stage, at the same time as the electrician. On-site checks include checking the height of sockets and light switches, checking that circuits and lighting works, that the circuit board is correctly labelled. However, the electrical installation is not checked for compliance with all the regulations; as such they rely on the competence of the installer. Where a project is submitted with a certificate of construction, the only check is to confirm its validity.

The verifier keeps up to date with technical changes through in-house training. Those with professional membership have a requirement for CPD, though at present their focus is on the changing energy standards. NICEIC also run information road shows which they try to attend. However, at present, the department is short staffed so they have other priorities than training.

Any issues that arise with information on certificates, details on site or complaints from the public would be directed back to the installer in the first instance. Where this does not resolve the problem, the verifier would report to SELECT or NICEIC. If a member of the public had a complaint about an electrical installation, the verifier would arrange to meet the installer and the individual on-site to discuss the issue. Again, if this did not result in the problem being resolved, then they would refer the complaint on to the relevant scheme provider.

The local authority considers that the certification of construction scheme is a positive development in building standards and if it was mandatory then it would resolve a lot of problems. However, as it is not, it means the verifier has to accept various other means of proving compliance and competence (which are not necessarily equally competent). In terms of the verifier’s process, it isn’t a huge difference for them; though it takes

36

slightly longer to conduct reasonable inquiry, the electrical checking is such a small part of the overall process that it does not affect them much. However, the verifier considers that the client would get a better result from using a certifier of construction.

Verifier 2 This verifier is a medium sized, city local authority. The summary findings of the project reviews are given in Table 5.4.

Interview

The verifier uses the guidance from BSD, LABSS and any other guidance which comes to their attention. BS7671 also lies behind the verification process. For every completion certificate there is a standard template which is used by the officer undertaking the verification. This template has been prepared based on the wide experience of the department and the guidance available. The approach reflects the issues addressed in BS7671.

The verifier is expected to engage with the process to prevent it becoming an exercise in ticking boxes; consideration would be given to whether or not the project profile fits the template and alterations made where necessary. Experience of use has shown the template to be robust but any changes to the guidance would be considered for updating the template as required.

The local authority officers carrying out verification do not have specialist knowledge of electrical works and therefore would not be expected to have an exclusive role in checking. They would follow the guidance where appropriate. Verification is not outsourced, but on rare occasions experienced council electricians have been used to supplement the normal checking procedure. The council electricians used for supplementing checks would be experienced, fully qualified electricians familiar with BS7671 and electrical testing.

There are policies in place to ensure all council electricians are fully trained and keep up to date with all requirements of standard electrical work, including more complex projects.

On-site checks are never made on projects which have had certificates of construction submitted. Checks are made against the relevant external websites to ensure they are current members of NICEIC or SELECT.

The council considers that the certified route works well; the non-certified is more complex for verifiers and they are faced with examples of DIY electrical work (generally in the low complexity area) and this can be difficult and time consuming to check. There are also examples of fraudulent qualifications offered and therefore the external website checks are essential.

37

The council attempts to keep their own list of competent electricians who are known to them and therefore they are aware of the status of these firms. Checks are still carried out of each of these but there would be an additional focus when companies, not known to the council carry out work.

There are a variety of BS7671 certificates with slight differences. This can make it difficult for Building Standards officers to check the validity of the certificate and ensure it is not simply a copy which has been modified on someone’s computer. An online reference showing samples of all valid certificates would simplify these checks and help officers to reject homemade versions where appropriate.

A complaints system is in place within the local authority. On one occasion, a potential problem was reported to the council by a householder, notified by a relative who was an experienced electrician. The work had been carried out by a member of SELECT and the matter was referred to them by the householder on the advice of Building Control. The matter was resolved to the council’s satisfaction.

Verifier 3 Verifier 3 is a large local authority, with a mix of rural areas and large towns. The summary of the projects review is given in Table 5.5.

Interview

The verifier has an in-house protocol for electrical verification. They use this to ensure that standard requirements (including placement of sockets/light switches and BS7671 requirements) are included from design submission stage. During construction, checks are undertaken to ensure that installation is as per the drawings. Certification of construction is the preferred route for electrical installations (though it is not insisted upon). Where one is not submitted, SELECT, NICEIC forms or standard BS7671 template forms with a copy of the installers SJIB card are accepted.

The verifier checks the validity of certificates online, but they have to accept SJIB cards at ‘face value’. They get to know local companies who are undertaking electrical work. Where a project has been a self-build, the applicant needs to submit a certificate of construction, or else have an electrician check the work.

On-site visual checks are made by the verifier to confirm the number of sockets and lights. They also confirm that fire alarms and emergency lighting are operational, and that lighting circuits work. They do not conduct electrical safety testing, but can witness testing done by others. There is no specific electrical expertise within the building standards team, but there may be others within the local authority who could advise if necessary. Checking is not routinely outsourced to any external contractors.

The verifier keeps up to date with technical changes to regulations through regular seminars from LABSS and BSD as well as an in-house training process.

38

The current verification approach adopted in the local authority is stricter than in the past.

The verifier adopts a risk based approach, requiring specialist design elements to be signed-off by an approved electrician. They do not routinely check certified work but would respond to any identified issues. They feel that their final check on projects would identify any issues; this is their standard procedure for all aspects of the building regulations.

The local authority considers that there is no gap between certified and non-certified work, as checks are in place for non-certified electrical work comparable to the certification route. The two approaches lead to different ‘reasonable inquiry’ routes, but there is no difference in the level of reasonable inquiry taken. Certificates of construction give the verifier’s confidence that the electrician is fully qualified and is a more robust route. Certification shows that relevant trade cards are in place, and that no further checking is required. The verifier considers that the problem with SJIB cards is that they cannot be checked online to confirm the qualifications. The verifier considers that further explanation of electrician qualifications would be beneficial.

Verifier 4 This verifier is a small authority, mainly covering a series of medium sized towns. The summary of the projects review is given in Table 5.6.

Interview

The verifier uses guidance outlined in the SABSM document (Guidance on Electrical Installations not certified by an approved certified of construction for verifiers in their role as Enforcers of Powers vested in the Building (Scotland) Act 2003 (2006)), plus an internal policy which has also been in place since 2006. The internal policy allows different documents to be submitted for minor electrical work to domestic premises only (minor work includes extension of a ring main only; new ring mains require the full process to be followed). In minor works, where a certificate of construction is not submitted either of the following is accepted:

BS7671 certificate with inspection and test results completed by a competent person (competent as determined in the certification of construction scheme guidance),

BS7671 certificate (including inspection and testing parts) completed by an approved electrician.

In this situation, an approved electrician must present a SJIB electrical contracting card in addition to a BS7671 certificate.

39

The local authority considers that this process is appropriate on the basis that SELECT and NICEIC members must meet NVQ/SVQ Level 3, as must SJIB approved electricians; therefore both are seen to be competent.

The internal guidance was brought in as a large number of small contractors would have been cut out of the system, as they are not affiliated to a UKAS body. The internal guidance policy therefore allows these smaller contractors to sign off BS7671 certificates but only for minor works.

In the situation where a contractor is no longer trading after work is completed, but before the certificate is signed (e.g. as a result of death or going out of business), then a suitable ‘condition report’ is requested. This is for minor works only, major works require an approved body or certifier to inspect and sign off the completed work.

When a building warrant application is received, the verifier requires the electrical layout to be included in plans, plus a docket to say that the wiring will conform to BS7671. When certificates of construction or BS7671 certificates are received, the details are checked on the scheme website, to ensure those signing are competent. If the person completing it is not an approved certifier (or working for an approved body), then copies of SJIB cards are requested, as the list of qualifications is printed on the card.

If a project is complex, for example if it includes automatic fire alarms, ventilation systems, lifts, emergency lighting or HVAC systems, then the verifier will ask for the commissioning certificates for those items in addition to the BS7671 certificate.

Building standards surveyors working for the local authority would carry out onsite checks in relation to electrical work that affects other building regulations (e.g. wiring through fire walls or separating walls). They have never had an external contractor (electrician) verify that work done by another electrician was satisfactory. There is no-one within the building standards department who has approved electrician status; although electricians are employed by the council in the building and works department, such checking is not outsourced.

In the local authority, all surveyors have a degree in building control, plus some have professional qualifications (e.g. with RICS). Presently, all the building standards surveyors have more than 5 years’ experience. There are three verifiers with professional qualifications who have a requirement through the professional body to undertake CPD. All staff must go through an annual appraisal system which records all training undertaken. In addition, all staff are required to conduct a minimum of one hour training per month; this is generally relevant to the types of jobs being processed at the time. There is an expectation in the department that they will keep up to date with building standards and other regulations, and this is checked during the annual appraisals. Staff are also sent to all relevant seminars.

40

The only check made on certified work is to the scheme website to make sure that on the date the certificate was issued, the individual had the necessary qualifications. If there are any problems identified, the verifier would inform the scheme provider. To check that ‘as-built’ work relates to the submitted drawings and plans, the verifier refers to the approved plans to check the location of sockets and switches. They are not expected to check all items, but confirm a sample, relative to the building size and complexity.

If a member of the public raised an issue over certified work and the building was complete, the verifier would advise the member of the public to contact the trade body that the electrician is associated with, and also advise them to contact trading standards.

If the building is yet to be completed, the verifier would arrange to visit the site and give advice to those carrying out the work, and the building owner. They want to ensure the onus of responsibility remains with the owner.

The local authority previously received a complaint, which went to the ombudsman, relating to the lack of information about the need for an approved or competent person to sign off electrical work. As a result of this complaint, the local authority has increased their signposting. For the last 18 months, they have included guidance on BS7671 in their pack to applicant.

The verifier hopes that there is not a gap between certified and non-certified work. The local authority follow the policy guidance to do all they can to ensure that the competence of people undertaking non-certified work is as close as possible to that of those carrying out certified work.

One suggested step, to align electrical work (by certified and non-certified routes) could be to have a register of competence for those who can complete BS7671 certificate but who are not certifiers of construction. They have noticed a general decrease in the number of certificates of construction which are submitted. Anecdotally, they would say this is because it is easier not to use this route, and that work can be signed off without one. Additionally, it is more expensive to use the certificate of construction route. The verifier concluded that the intention of the Building (Scotland) Act is for verifiers to inspect, but this is not explicit and could be clarified further. They would like to see a national consistency in approach and in terms of the research, they would like it brought to a conclusion. The verifier considers that they have a strong policy and they are content with the approach taken for electrical work. While the verifier team does not include electricians, they are satisfied that their policy ensures that electricians are competent. The verifier stated that electrical work is a ‘hidden element’, it is not possible to ask contractors to pull out electrics or remove fabric finishes in order to carry out an inspection. Therefore, the verifiers fully rely on the competence of electricians.

41

Verifier 5 This verifier is medium to large in size and includes a mix of towns with a wide rural area. Table 5.7 shows the summary of the projects review.

Interview

The local authority follows the BSD Guidance directing all projects to approved electricians. Uncertified work must be covered with a BS7671 certificate. Electrical certification will not be accepted from any person other than a qualified electrician who is a member of a recognised trade organisation. The main recognised trade bodies in Scotland are NICEIC and SELECT. Others do exist but alternative schemes must be UKAS accredited.

Where BS7671 certification is received, it is important to remember that it does not cover the associated works that are included with a certificate of construction. Accordingly, making reasonable inquiry may include the need to see items such as fire stopping, where this is considered to be important.

The verifier specifically focuses on electricians unknown to the council and the checks on these firms and individuals are more rigorous. The known electricians should be checked on every job but the frequency of checking is not as great.

A leaflet has been produced, outlining the verifier’s standard guidance with a procedure for certified work, uncertified work and the documentation to be submitted in each circumstance. This is provided to each member of staff, the content is supervised by an administration officer and the document as a whole is reviewed at intervals by the Building Standards Manager. The next review is planned for December 2014. However, the general process adopted by the local authority has not changed significantly since it was put in place when the certification scheme began.

There are no electrical checks or testing undertaken by the verifier’s staff. The building standards surveyors check the documentary submissions. If the works require further checking, the applicant must organise this and then submit the relevant documentation in the prescribed manner. The documentary checks are undertaken by the verifier, but they would not be required to undertake any physical electrical testing.

If a member of the public raised an issue over certified work, the verifier would report it to BSD. If the issue related to work undertaken by a SELECT or NICEIC contractor, they would firstly contact the relevant Scheme Provider.

Verifier 6 Verifier 6 is a medium sized local authority with a mix of small to medium sized towns, countryside and rural areas. Table 5.8 provides a summary of the projects review.

42

Interview

This local authority is part of a consortium which has devised an agreed approach to verification and which works together to enforce standards. If electrical work is not certified, then they would apply the same tests as UKAS. They look for a BS7671 certificate signed by a SELECT or NICEIC member, which covers the majority of installations. Alternatively, if the electrician is not a member of one of the trade associations, they would accept a BS7671 certificate alongside proof of training, professional indemnity insurance and confirmation of the calibration of testing equipment. An SJIB card is no longer seen as sufficient proof of competence by the verifiers. The additional assurances are required, just as they are for the certificate of construction scheme. The approach has been strengthened to this point over time. The verifiers find that installers have been slow to react to this change.

The verifiers check the details of a certificate of construction against the certification register. Where a certificate of construction is not submitted, the verifiers check the installer’s details, including their membership number on the SELECT or NICEIC websites. Most electrical work in the local authority is done by local companies. Additionally, checks are done to ensure that electrical installers are competent to undertake specialist work, for example fire alarm systems. Occasionally, the verifiers have caught installers who have had their membership of SELECT or NICEIC cancelled, but who are still completing electrical installations. These installers are reported to the relevant trade body.

When an installation is not certified, verifiers check the competence of the installer who has signed the certificate or form, but also check work on-site. This on-site check, is not to confirm the electrical installation, rather it is a check of the work done, for example fire stopping. There is not a specific schedule or timetable during construction work when these checks are carried out. These inspections take around 5 to 10 minutes for an average house extension project. The inspections also allow the verifiers to check that work is not being done by unqualified people. There is no specific electrical experience among the local authorities building standards surveyors; however an electrical services designer within the technical services department can be consulted if advice is required. Checking of electrical installations is not routinely outsourced, but it is possible this would occur if building standards had reached an impasse regarding a conflict with an applicant. There is no checking of certified installations.

The building standards surveyors keep up to date with technical developments through a CPD process, which includes all relevant courses as outlined by LABSS. Additionally, talks and magazines from scheme provider SELECT inform the verifiers of updates and changes.

The approach to verification has not changed in recent years. However, following the implementation of the new approach, there was an initial ‘bedding in’ period. The

43

verifier considers that the new approach is much tighter on who can sign-off electrical work compared to the previous system.

If a complaint was received from a member of the public, regarding an electrical installation, the verifier would refer this to the installer and to SELECT or NICEIC to investigate. Building Standards could act as an intermediary body in any dispute. To date there have been no reported complaints related to electrical work, but it is possible that they may start to receive more complaints due to new links with Trading Standards.

The verifier considers that there is not a gap between certified and non-certified electrical work due to the robustness of the checks they carry out. There is more paperwork required for a BS7671 certificate, than a certificate of construction, but this is possibly due to the paperwork they receive for each approach.

The verifier’s opinion is that the discount offered to applicants for using an approved certifier does not encourage use of certification schemes. To align electrical installation checking, it would be necessary to have a national scheme (perhaps run by LABSS), and more guidance with the Technical Handbooks on how to check electrical work.

44

Category Description and comments

Types of projects Nine project files were available for review. Three were low complexity, two

medium and four high complexity projects. There was a mix of domestic

and non-domestic projects. Projects included extensions to domestic

properties, alterations and conversions and new build flats, retail units, a

care home and two medical centres.

Approach taken to

checking

Five of the projects had certificates of construction, completed by a scheme

member. In some cases this was supplemented by BS7671 certificates for

minor works, small installations or electrical installations. In some cases the

Certifiers were certifying work they had carried out, in others they had

supervised and inspected work done by others. In the case of the flat

development, a certificate of construction was supplied for each flat, and

also one for the landlord’s supply.

Other projects were supplied with BS7671 certificates, either SELECT,

NICEIC or unbranded. These files generally included either emergency

lighting and fire detection and alarm certificates, or commissioning

certificates to confirm the installations. Where the BS7671 certificates were

not branded, or completed by a member of a trade body, proof of

competence was also included.

Evidence of

competence

All project files submitted with a certificate of construction included a print

out of the online validity check of the certificate of construction, the certifier

and the approved body. Where a BS7671 certificate was used, a print out

of an online check with NICEIC or SELECT of the membership of the

installer was used, or alternatively a copy of the SJIB card was provided.

Completion of

project files

All files were complete.

Issues raised by

verifier

In one project file, a concern was raised regarding the competence of the

designer of an electrical installation noted on a BS7671 certificate, as they

were not NICEIC members. Communication included in the file, from

NICEIC, confirmed that the electrical design may be carried out by a non-

electrician (e.g. an architect), and that only electrical contractors can be

registered with NICEIC. This was agreed by the verifier and the certificate

was accepted. The installer, tester and inspector were confirmed as

NICEIC members.

45

Other queries included a request for changes to emergency lighting

provision and a necessary amendment to a drawing – both of which were

resolved. Another query related to the proposed multiple occupancy of the

building which was not indicated in the original application and required

changes to fire stopping and separating walls/floors which would affect the

electrical work.

In one file, the verifier had to request the electrical installation certificates,

which was also resolved.

Any involvement

from other parties

No other parties were involved.

Table 5.3: Project Review (Verifier 1)


Types of projects Nine project files were supplied for review. These were three low

complexity domestic extensions; three medium complexity new domestic

dwellings and three high complexity non-domestic projects – work in a

hotel, and two new office and workshop buildings.

Approach taken to

checking

Only one of the project files had a certificate of construction. Others had

BS7671 certificates, a mix of NICEIC or SELECT branded and unbranded.

Additionally, a couple of files included emergency lighting and fire detection

and alarm installation and commissioning certificates.

Evidence of

competence

All files are signed off by a building standards surveyor who would have

followed a process to ensure the competence of an electrical installer.

Completion of

project files

The files do not include a check of competence of the electrical installer.

Issues raised by

verifier

The local authority verifiers do not include issues raised in the final project

files. These would be dealt with as they arose but not necessarily recorded

in the as-built files.

Any involvement

from other parties

Some projects are checked by more than one member of the verification

staff, but these checks are not necessarily recorded in the project files.


46


Types of projects Ten projects were presented for review. Three were low complexity, four

were medium complexity and three were high complexity. Projects included

alterations to domestic properties and new build domestic properties. The

more complex projects were a new build supermarket, and new build

warehouse complex, as well as alterations to a bar/restaurant.

Approach taken to

checking

Just under half of the projects were submitted with a certificate of

construction. In most cases these were signed off by a certifier who had

supervised and checked work carried out by another electrician. A couple

of the certificates of construction were supplemented by SELECT branded

BS7671 Electrical Installation Certificates.

The other projects either included NICEIC or SELECT branded BS7671

Electrical Installation Certificates completed by trade body members. Some

also included Emergency Lighting and Fire Detection and Alarm System

certificates. One project was submitted with an unbranded BS7671

certificate.

Evidence of

competence

Where a certificate of construction was used or a SELECT or NICEIC

BS7671 certificate, there is no evidence to confirm that the competence of

the installer has been checked. It is possible that this has happened, but

there is no documentation within the project files to indicate this.

In the situation where an unbranded BS7671 certificate was used, it was

accompanied by a copy of a SJIB card, detailing the qualifications of the

electrician.

Completion of

project files

Project files were complete as expected, including drawings detailing the

electrical work. Evidence that competence had been checked would be

beneficial.

Issues raised by

verifier

There were no issues raised by the verifier with respect to the electrical

work.

Any involvement

from other parties

None of the project files indicated any involvement from other parties.


47


Types of projects Nine project files were presented for review. These included three ‘high

complexity’ new build projects; a supermarket, a sports centre and a high

school; three ‘medium complexity’ projects; two alterations to shops within

commercial premises and one new build multi-plot housing project; and

three ‘low complexity’; alterations to a domestic building, and extensions to

a small restaurant and a domestic building.

Some of the project files were hard copies and others were stored

electronically on the local authorities building standards system.

Approach taken to

checking

The Building Warrant checklist is completed and signed (and usually

countersigned) by building standards staff.

For most of the projects, a BS7671 certificate has been submitted, either a

SELECT or NICEIC branded form. In these cases, the form either includes,

or is attached to full testing and inspection reports. In addition, for the

medium and high complexity projects, there are a series of commissioning

certificates included for the various specialist elements included in the

construction. The application for completion certificate and the completion

certificate acceptances are also included in the files. Occasionally,

applications for temporary occupation and acceptance of same are also

included.

For the lower complexity projects, different certificates are included instead

of the BS7671 certificates; domestic installation certificates, small

installation certificates and minor works certificates are all included in files.

Evidence of

competence

The building warrant checklist includes a section which is checked off to

indicate that the competence of the person completing certificates is

competent; however, only in one of the files was there a copy of an SJIB

card.

Completion of

project files

All files are complete and as expected, though additional evidence to

explain how competence had been checked would be beneficial.

Issues raised by

verifier

One file had a request from the verifier to the applicant for amendments to

be made to the submitted drawings. Another file, which had a staged

warrant, included a reminder before the necessary stage that the electrical

work should be completed in accordance with BS7671 and by a competent

person.

In a third file, the verifier raised an issue with the work that had been done,

stating that a fire door should be installed. Later, the completion certificate

48

was rejected, as the verifiers wished to see an extract fan installed and also

to see proof of competence of the installer. This is the file that had the SJIB

card included.

Any involvement

from other parties

There is no involvement from any other parties.



Types of projects Nine projects were reviewed. These covered a mix of domestic and non-

domestic jobs, of varying complexity. Projects included extensions to

domestic buildings and to a castle; a new build school and veterinary

practice; alterations to shops and houses and the demolition of non-

domestic premises.

Approach taken to

checking

All files included a certificate of construction. Electrical checking was

conducted by either a NICEIC member or another approved electrician, and

an approved certifier.

Evidence of

competence

Evidence of competence is sought by the verifiers, but there is not always

proof that this has occurred available in the files.

Completion of

project files

The files reviewed were limited to completion/as-built files.

Issues raised by

verifier

The correspondence was held separately from the files that were reviewed.

Any involvement

from other parties




Types of projects Ten project files were presented for review. They included a range of low,

medium and high complexity; domestic and non-domestic jobs. Projects

include alteration and extension to an industrial unit; alteration, conversion

and extension to dwellings; electrical upgrades to office accommodation;

49

alterations to classrooms; internal refurbishment of commercial properties

and the construction of 46 new dwellings.

Approach taken to

checking

Three of the projects were issued with a certificate of construction. In other

files, SELECT or NICEIC Minor Electrical Installation Works forms were

included. The NICEIC forms were generally appended by fire alarm and

emergency lighting installation forms.

One file contained a domestic installation form, which was neither a

SELECT nor NICEIC form. This form stated that it was based upon the

requirements of BS7671-2008, amended 2011 and included a schedule of

circuit details and test results.

Another file included a NICEIC Electrical Installation Condition Report which

states that it has been issued to assess the installation for compliance with

BS7671.

On two occasions, a certificate of construction was submitted, but the

intention to do so was not indicated on the Building Warrant application.

Additionally, on one project, the intention to submit a certificate of

construction was noted, but this was not the process followed.

Evidence of

competence

In some cases there was no evidence to suggest that the competence of

the installer had been checked. In other cases, there were notes to indicate

the competence had been checked (on the certification register or with the

trade association), but often there were no details on how this check was

carried out.

Completion of

project files

Project files were complete as expected, except for those where there was

no evidence that the competence of the installer had been checked.

Issues raised by

verifier

There were no issues raised by the verifier with respect to the electrical

works.

Any involvement

from other parties

Some forms are countersigned by a supervisor or certifier, but many are

signed only by the installer. Certificates of construction are countersigned

by the certification co-ordinator and in one case a quality manager has also

signed a form.


50

5.4 Findings – certifiers

Certifier 1 The first Certifier interviewed works in a medium sized electrical contractors based in the south east of Scotland and is the only certifier in the business. They are part of the electrical certification scheme and have been approved by SELECT. The projects review summary is given in Table 5.9.

Interview

The company have been an approved body since the scheme began; they were involved in the initial scheme pilot. The first ever electrical certifier of construction used to work for the company. They joined the scheme partly because they considered that it was necessary to be part of the scheme to approve work, but also it was a step forward and that continues to be their belief today.

The firm have nine electricians, with one approved certifier and one foreman. The certifier also acts as the certification co-ordinator. All the staff are based at the same offices. There were plans to put the foreman through the certification process, but at present there has been no need to due to the volume of certificates of construction they are required to submit. They carry out work all over Scotland, and occasionally do commercial work in England, but they are not Part P accredited. Most of their work (around 80%) is directly to clients (including homeowners, local authorities and Historic Scotland).

The approved certifier signs off work done by his electricians. The certifier conducts visits to site to supervise the work of electricians, spending two to three days per week visiting the various sites to check progress. At the end of a job, the on-site electricians will complete the inspection and testing forms, which are returned to the office with the ‘O&M’ paperwork. The certifier goes through the checklist and completes the certificate of construction. Often the verifier asks for the electrical paperwork, in addition the certificate of construction, although the certificate should be sufficient proof of compliance.

If the verifiers had online access to the completed certificate of construction that would speed up the process, rather than having to manually submit documents. Generally, the electricians are last on site, and clients often ask for the certificate before work is finished, but they will not produce it until the job has been completed.

The company never uses a sub-contractor to certify work, and they do not certify work done by others. However, they do carry out Electrical Condition Reports for work done by others. They feel that only approved certifiers should be able to submit these, but at present they can be completed by any electrician.

51

The certifier is an approved electrician. He trained in the 1970’s and has a City & Guilds electrician qualification, as well as having been on building standards courses, the wiring regulation BS7671 course and health and safety courses. The company hold training records for all their electricians; who are re-trained on the wiring inspection and testing every three years.

All the electricians have a copy of the SELECT Technical Handbook, which they use for all work, not only that which is to be certified. They also have a copy of the wiring regulations (and on-site handbook) should it be needed for reference. The approach to risk in the company is that even small jobs have risks, and risk assessments are completed for all work. There is more planning involved in complex jobs, but they find that small jobs can actually be more complicated, especially when it is in an existing building, which are more technically challenging. New build projects are relatively straightforward.

The certifier states that SELECT keep members and approved certifiers up to date with training. Every time they pay their renewal fees, SELECT send out a checklist of the training that has been completed and any which is outstanding or due to be refreshed. If the course expiry is within six months, SELECT recommend they retake the course. Once the course is completed, it is logged with SELECT. They would be taken off the membership list and approved body list if anything lapsed. SELECT send out frequent bulletins with updates on regulations and other matters, for example, the BS7671 amendment which comes into force in January 2015. Each SJIB card carries the dates of courses attended, so that it can be seen if any are due for renewal.

The company has a quality management system (accredited to Quality Management Standard BS EN ISO9001) and are audited by their accreditation body every six months. The body reviews calibration test certificates and assesses their quality assurance manual. They were audited six weeks before the interview, and no non-conformities were found. They have a quality assurance manager who is sub-contracted. The quality manager is responsible for the internal auditing and helps with health and safety compliance. They are audited every three years by SELECT. The auditing system follows a risk based assessment. They are audited less often than others, due to the robust ISO9001 process which results in less risk for SELECT.

If the company received a complaint, then they would inspect the site to determine the issue. If it could not be resolved with the client, then they would pass it to SELECT. This is in line with the company’s complaints procedure. The company have only had two complaints since they began trading in 1992, both of which were resolved in-house.

All work is done to the same standard, whether it is to be certified or not. They feel that the main problem with the certification system is that there needs to be tightening on the competence of electricians who are not doing certified work. For example, verifiers will accept a schedule of test and inspections, plus a grade card, but the test results could say anything, and also any other issues could be hidden.

52

The firm considers that the reasonable inquiry process needs to be tightened; it is currently open to interpretation. The 1% discount should be reversed; instead there should be an additional charge for non-certified work where the verifier must conduct reasonable inquiry.

To assist in resolving site issues, more should be done to encourage the use of certifiers. If a building warrant is required, then a certifier should be used. This process is used for gas installations (Gas Safe), so they don’t understand why electricity is different. The company would also like to see other work included under the scope of a certifier, for example house rewiring, which does not require a building warrant but can be a complex job.

Additionally, more information for clients on the process should be given. Small clients (householders) are likely to only deal with the building warrant process once or twice, and can find the process confusing and not transparent. The architect, who often leads the building warrant process, can also be lapse in telling the client what is required, particularly regarding certification. The public need to be made more aware of the importance of using a certifier. The company will inform clients when they need a building warrant and will recommend they apply for one, but they cannot insist on it as they do not want to risk losing the job. They feel that the searchable database of approved bodies and certifiers of construction is an improvement on the previous register.

Certifier 2 This Approved body is a small electrical contracting company. It has one certifier and operates in the north of Scotland. The projects review summary is given in Table 5.10.

Interview

There are only two members of staff in this company. They are members of both SELECT (for 40 years) and NICEIC. Both electricians work on certified projects, though they issued less than ten certificates of construction since they joined the scheme in 2005. As a result they have been audited every three years. The low number of certificates produced over the period of time is due to almost non-existent client demand for this service in the area. Much of their client base is domestic and small works, with the result that there is limited knowledge and therefore demand for certification by the clients. They do not produce certificates of construction as a matter of routine, but only when requested by a client.

They generally work only on small jobs and phone the SELECT Helpline if they require any guidance. SELECT also provide them with advice on any changes to the systems or regulations. The certifier is a committee member with SELECT and therefore is generally aware of the changes before they take effect. The company keep in touch with SELECT and NICEIC to ensure that all training is undertaken as required.

53

They would only certify low complexity projects; any work which is of greater complexity would be sent to a larger company for them to certify.

The senior member of staff (the owner) is a technician grade electrician and a qualified supervisor (through SELECT) who undertakes relevant courses delivered by SELECT including Building Standards to BS7671.

The electricians conduct dead tests followed by live tests based on SELECT forms. For building warrant jobs they log onto the SELECT website and use the current forms to ensure comprehensive checking. The certifier sees each stage of all the certified work and is therefore in a good position to pick up any problems.

If a member of the public raised an issue with any electrical work, they would check the issue and would consult with SELECT for guidance. Alternatively they may get SELECT assessors in to check. However, the company have not had any complaints or problems since they joined the scheme.

Customers sometimes request testing, when work without BS7671 certificates have been carried out by others.

The company feels that this shows that there is a lack of publicity in place to explain the benefits of employing a certifier of construction at the start of the project. More publicity, perhaps through architects, would also increase the pressure on the industry for others to up-skill and improve standards to gain work.

Certifier 3 The third company are a large business, covering all areas of construction, including electrical work. They have been approved by NICEIC as members of the certification scheme. They are based in the west of Scotland. The projects review summary is given in Table 5.11.

Interview

The company has a large number of electricians and sought to include certification services in their business using in-house staff rather than employing other companies. There are currently two certifiers within the business, both located in the same office.

They have been part of the scheme for seven years. This was client driven; they needed to be a member of one of these bodies (either NICEIC or SELECT) to get onto certain tender lists. Previously they checked their own work but recognised that membership would help to increase the quality and skill level within the organisation.

The company operate on the basis of managers being supervisors and certifying work that is checked on site. The managers certifying the work are trained and audited by NICEIC to carry out this work or to assess condition reports.

54

The organisation has prepared a set of check sheets for each type of project. Each electrician takes delivery of the appropriate books and can complete them on site. The sheets have unique numbers to ensure that the project is clearly identified. The audit team within the organisation operates a checking system to ensure the project sheets are completed as required to ensure the project records are fully assessed on site before being passed to the certifiers for checking off. This system is backed up by the in-house IT system which is used to record the details of each project. Frequent toolbox talks to all the electricians ensure the process is followed correctly.

The organisation carry out the full range of electrical work and therefore electricians can be transferred between projects of different complexity to reflect resource needs. There is an assessment of each tradesman’s skill level and initially they will be assigned to an appropriate complexity of work. An electrician may work alone on less complex work but when it is more complex it will be done by a team.

BS7671 is used as the basis for their checking with industry guidance to inform the process as appropriate. NICEIC keep them informed of any changes to the system and they are then incorporated into the in-house system and the tradesmen informed of the changes. The organisation has its own skills academy and can teach up to SVQ Level 3. This permits them to train all staff involved as required. The certifiers all have City & Guilds training; all electricians have Scottish Joint Industry Board cards.

No certification work is subcontracted. Specialist works (e.g. commercial fire alarms) may require to be checked by a specialist team but this work would also be checked by the certifiers of construction.

If any problems arose, NICEIC would be contacted for advice. The in-house audit section constantly operates a 10% check on all projects, investigates all deviations and reports these throughout the organisation. If any complaints were received, they would be reported to the audit section. The firm is audited by NICEIC each year and this takes around 31/2 days per year.

The company considers that a gap exists between non-certified and certified work. In-house problems arise and require to be checked. They feel this would be worse in smaller organisations who could not afford the same level of checking. All electrical checking should be by NICEIC or SELECT members. Both organisations audit their members and their processes. In addition all certifiers should have a City & Guilds qualification in electrical testing to ensure a full understanding of the issues.

Certifier 4 As a sole trader, this certifier operates in the south east of Scotland and is a NICEIC scheme member. Table 5.12 gives the summary of the projects review.

55

Interview

The certifier operates as a sole trader (acting as both certifier and co-ordinator) and has been a NICEIC member for four years. The certifier works occasionally with another electrician on projects, but who is not employed by the company full time. The certifier only certifies his own work, and that done by the other electrician. Electrical installations are tested as work progresses, as circuits go live and the final live tests. All work undertaken is low complexity. It is mostly domestic and small commercial works.

The certifier originally joined the scheme as he felt he had to in order to continue working (need to certify electrical work). There are benefits of electrical scheme membership such as the access to training, technical updates, regulation changes and insurance. When he first joined NICEIC, there was encouragement to all installers to do the certification exam, as though they would not get work without the scheme membership. However, this has not been consistent and the message is now not that clear.

The guidance most frequently used is the on-site handbook. Additionally, the certifier uses the full BS7671 document. NICEIC have an online service, which allows technical issues to be checked. NICEIC have a helpline which gives advice by phone and email (so it can be printed and viewed on-site). In addition, the certifier has specialist handbooks (mainly NICEIC publications) at home to check as required.

The certifier is a qualified electrician, having completed 17th edition wiring regulations course including recent amendments and test and inspection and electrical installations courses. These courses were mainly undertaken in night classes.

The company is audited annually by NICEIC. The initial audit was over two days; now it takes half a day. NICEIC check insurance and a number of files, plus they visit three of four sites where the certifier is asked to carry out tests to prove the work has been installed safely. No issues have arisen during the audits.

NICEIC also check on training needs. If there is an update that should be completed then the local NICEIC contact sends out reminders of courses. There is also an annual NICEIC conference where certifiers are informed about upcoming changes, for example to building regulations.

The certifier considers that there is a gap between building warrant and non-building warrant work, not necessarily between certified and non-certified work. A possible solution would be to follow England (Part P), although that process has also had difficulties. In the certifier’s opinion clients don’t want to spend money and generally only get work done that is absolutely necessary, as certification has an additional cost it is often ignored. However, when work requires a building warrant either the certified or non-certified process makes sure everything is done properly.

56

The certifier considers that the incentive for submitting a certificate of construction is not enough to encourage people. The money saved is not worth it to applicants. Most applicants don’t bother indicating their intention to use a certifier for the electrical work on the building warrant application. In reality certification may be more beneficial for complex jobs which include design work, but not necessarily for small scale domestic work.

Certifier 5 The approved body is one of the largest electrical contractors in the south of Scotland. They are approved by NICEIC and have one certifier. The projects review summary is provided in Table 5.13.

Interview

The company work across a wide range of job types, including new build projects, extensions and MVHR system installation. Approximately 30% of their work is new build, 30% refurbishment and 20% industrial. They were advised to join the scheme, hoping that this would be the way that electrical checking would be routinely done in the industry. They joined at the beginning of the scheme and have completed around 50 certificates of construction each year. The production of certificates is driven mainly by client demand, which will be the normal expectation for larger contracts but not so for smaller domestic works and even some new housing developments.

They have 16 electricians, and the manager who is the certifier and the co-ordinator. As the certifier is a senior member of the firm they are required to regularly visit sites and to undertake checks on the work. The certifier programmes site visits to ensure that ‘first fix’ can be seen before being covered up or other work going ahead. The firm also has two certified NICEIC supervisors and one electrician who conduct tests and inspections on a full time basis. The certifier will obtain evidence from other senior staff involved in testing and checking works to assist with the certification process.

The amount of electrical design information provided to the firm depends on who has commissioned the work. Consultant designed work often comes with lots of information on the design; however housing developers usually leave the design to the contractor. The company can design electrical work as required, although the position of sockets/switches is architect or client led. For timber frame kit builds, the manufacturer will provide drawings, highlighting specific requirements for notches and joists. Often these are provided by the structural engineer.

The electricians use the on-site handbook (pocket guide to 17th edition), as well as the Technical Handbooks, plus smaller guides to building regulations. The NICEIC website is the best source of information. Online training is done by NICEIC every three years, to bring all electricians up to date with changes to the regulations.

57

The electricians working for the company are qualified electricians, qualified supervisors or approved electricians through SJIB. Some also hold BPEC qualifications for ventilation work. Training courses attendance is recorded to ensure everyone is up to date. All installers have a SJIB card, which notes their qualifications, including the 17th edition wiring regulations course and ECS health and safety assessment.

The certifier focuses on work which requires a building warrant. They only certify their own firm’s work or that done by others in the company; they do not certify work done by other companies or vice-versa. It would be unusual in the industry to ask someone to certify for another company. They do however complete Electrical Condition Reports on other firm’s work, when requested to do so by the relevant building standards department. If there is a nominated fire alarm supplier in a project, then it has to be subcontracted. In these cases this will not be covered by the Certificate of construction.

For larger jobs, the company often do a certificate of construction in any case, whether or not it has been requested. For smaller jobs, certificates of construction are not typically issued, but this depends on the client. For each job a risk assessment is carried out, the certification is part of the considerations.

The company is audited by NICEIC annually, in a visit which takes two days to complete. An audit of the certification of construction process is included as part of the wider audit. This part is generally on-site to see how electrical regulations are met; typically three or four jobs as viewed. Insurance and calibration of test equipment is also covered in the audits. The company also get regular updates from their local NICEIC representative.

They follow the scheme guidance rather than an in-house procedure. This prompts issues to be raised and design changes to be made as required. Checks are made on design drawings to ensure that there is compliance with building regulations before work starts.

The certifier has not received any complaints over certified work. There may on occasions be issues around whether or not a smoke detector is needed, especially where there are open plan living rooms with stairs off. Such issues are addressed in the normal course of undertaking a contract.

The company considers that the building standards surveyors do not check electrical installations at the right time in the construction process. Verifiers typically check at the end of a job, once everything is covered. They need to check during the works, particularly at ‘first fix’ when the electrical installation is still visible and before wall, ceiling and floor finishes are completed. NHBC inspectors help to pick up on things which may result in potential issues. The inspector would directly contact the installer to have any matter resolved.

58

They consider that mandatory certification is needed but realise that this is not possible under the current legislation. Where work is non-certified, all information to check the competence of the installer is included on the NICEIC paperwork, so this should ensure the work is of the same level as certified work.

59


Types of projects Nine recent project files were presented covering various complexities.

Two were domestic projects, one a new build flat scheme and one a

conversion. Four were projects within local authority leisure centres,

covering small jobs from the installation of new sockets and lighting to

larger projects involving new circuits and rewiring. Other projects included

a hotel extension, a new build farm store and a conversion into a coffee

shop.

Approach taken to

certification

Most jobs had a certificate of construction, where the certifier has signed off

work done by others. Three had BS7671 Electrical Installation Certificates,

for minor works, or small installations. These were SELECT branded and

completed by electricians or approved electricians. Those which had a

certificate of construction also include BS7671 forms. Additionally,

emergency lighting and fire detection and alarm certificates were also

included for some jobs. For the flatted properties, a certificate was included

for each flat, as well as for the common areas.

Evidence of

competence

All certificates of construction are signed by the certifier and also in his role

as the co-ordinator. The corresponding checklists show that the Certifier

has supervised and checked the work done by others. The BS7671 forms

are SELECT branded and include the company’s membership number.

Completion of

project files

All files were complete as expected.

Issues raised by

verifier or other

parties

One project file contained correspondence relating to an issue with some

dimmer lighting that had been specified. An alternative was sourced and

agreed.

Any involvement

from other parties

No other parties are involved in the process.

Table 5.9: Project Review (Certifier 1)

60


Types of projects Four project files were presented for review; these were the only files

available that had certificates of construction. They were all for low

complexity work (as this is the extent of the work conducted by the

company). Projects included wiring in a new build house, rewiring in a

house conversion, new wiring in a farm building and a circuit extension and

new socket installation in a hotel.

Approach taken to

certification

The electrical installations were monitored throughout by the certifier. Dead

and live testing was conducted, and then the certificate of construction was

completed.

Evidence of

competence

All work is signed off by the certifier.

Completion of

project files

Files were complete as expected.

Issues raised by

verifier or other

parties

No issues have been raised.

Any involvement

from other parties

No other parties have been involved.


61


Types of projects Nine project files were reviewed. These were all medium or high complexity

jobs including domestic rewires, new build domestic developments, health

and leisure facilities. Also included were three files for inspection and

testing of lighting within common ‘close’ areas in domestic buildings.

Approach taken to

certification

In all cases, a certificate was completed on-site and was then certified by an

in-house certifier.

Evidence of

competence

The projects are all signed off by an in-house certifier.

Completion of

project files

The copies of project completion certificates within the project files are not

signed by the certifier; the certificate issued to the verifier would be

appropriately signed.

Issues raised by

verifier or other

parties

If these exist, they are not recorded in the files kept by the company.

Any involvement

from other parties

In some occasions, a site supervisor may also be involved.


62


Types of projects All project files reviewed were low complexity, domestic jobs. These ranged

from new sockets or lighting points, to partial and full rewires and new

wiring for new kitchens and house extensions.

Approach taken to

certification

Most of the projects had certificates of construction. These were

accompanied by the checklist to confirm that the Certifier was confirming his

own work. These projects also included BS7671 Electrical Installation

Certificates or domestic electrical installation certificates, and in some cases

also fire detection and alarm certificates.

Three projects did not have certificates of construction, but had relevant

BS7671 certificates and where appropriate fire alarm and detection

certificates. Again, these were all completed by the certifier.

Evidence of

competence

The accompanying checklist confirms that the certifier has followed a

process of checking his own work. All paperwork is NICEIC branded and

included certifier, approved body and NICEIC membership number.

Completion of

project files

All files were complete as expected. Few included drawings, as the

electrician explained these are often kept with the architect.

Issues raised by

verifier or other

parties

There was no documentation included from the verifier within the project

files.

Any involvement

from other parties



63


Types of projects Only three project files were available for review. These were two new build

houses and one complete rewire of an existing office building.

Approach taken to

certification

In all cases, a certificate of construction was completed. For the domestic

projects, the files included a domestic electrical installation BS7671

certificate and a fire detection and alarm system certificate. The certificates

of construction indicated that the fire system was also certified. The

certification checklist indicated that the certifier was confirming work done

by himself, but rather this was work done an approved electrician and a

qualified electrical tester employed by the company.

The non-domestic rewire project included a BS7671 electrical installation

certificate, plus certificates for emergency lighting and a fire detection and

alarm system. The certificate of construction covers all three elements.

Again, the checklist indicates that the certifier is confirming his own work,

but all the supplementary certificates are completed by an approved

electrician working within the company.

Evidence of

competence

All forms are NICEIC branded and include the certificate number, the

approved body number and the certificates of construction also include the

approved certifier number. The certifier has completed the checklist for the

three jobs.

Completion of

project files

The project files presented only included the certificates. No drawings or

notes were included. It seems that these are held separately, as a second

file for the non-domestic project included drawings, contracts and notes.

Issues raised by

verifier or other

parties

There was no indication of any issues being raised.

Any involvement

from other parties

No other parties were noted in the files.


64

6 Discussion The research carried out on the approaches to determining the compliance of electrical work with building regulations has involved desk based reviews, surveys, interviews and project reviews. Interviews have been held with approved bodies (including approved certifiers of construction) and a number of local authority verifiers. These were structured in order to determine how approaches to electrical certification and checking were undertaken.

The aim of the research was concerned with the existence, or not, of a gap between the certified and non-certified approaches. The research was not designed to forensically examine actual electrical installations undertaken, but instead to consider process, competence and variations involved. Indeed, there is no known correlation between poor electrical safety of buildings and the relationship to certification or not of the electrical work.

The research has demonstrated that the processes are different and therefore they are not necessarily directly comparable. There are in effect two routes, but the same outcome should be reached.

6.1 Robustness of the certification approach

Certification process and approach There is one scheme for electrical certification of construction, with SELECT and NICEIC acting as scheme providers. Both scheme providers follow common procedures with regards to the training, assessment of competence and auditing of membership. The scheme provides a robust method to assess electrical work by enabling suitably qualified professionals to certify building such installations.

The successful operation of the scheme relies on the certifiers carrying out their work and/or checking in a thorough manner. The interviews and project reviews supported the professional approach of individuals.

Certifiers follow the SBSC checklist (Scottish Building Services Checklist) to check and confirm that electrical installations comply with the Building Regulations. They can either confirm the compliance of their own work; work carried out by another competent person; or have a competent third party confirm work (e.g. where specialist elements are included). The checks undertaken include both the electrical work itself, for safety, but importantly the impact on other parts of the regulations. This required the certifier to ensure attendance on site at various times if they were not carrying out all or part of the installation themselves.

65

The checklist has to be completed although some items will be not applicable, they can then complete and sign the certificate of construction. The certification coordinator then completes the relevant section of the form. This is now generally done online, and a print out of the certificate of construction is passed to the applicant to be submitted to the local authority. The checklist is intended to be kept by the certifier as proof of their process if audited, but often copies of these were included in the submissions to the local authority.

The certification process could be tightened by ensuring that records are made and kept on the project file of all site checks that form the certification process. The project reviews indicated that there was variation in record keeping by certifiers, which should be addressed by the scheme providers.

Often British Standards certificates (Electrical Installations, Fire Detection and Alarm Systems, Emergency Lighting) are completed on-site and are submitted along with the Certificate of construction. The certificate of construction and associated checklist is all that is required to confirm the compliance of the electrical installation, but there was evidence of some verifiers also requesting the BS7671 certificates, and these were viewed in verifier project files which included a certificate of construction.

There was a certain confusion of language around certification of electrical work. For some firms, and indeed verifiers, reference to certification could include certificates of construction, BS7671 certificates, Electrical Condition Reports, other electrical reports, or indeed combinations of them all. This is an unhelpful situation and should be addressed by the scheme providers and indeed the verifiers.

The scheme providers conduct regular audits of their members to ensure that the processes are robust. The frequency of audits is determined on a risk based approach; larger companies and those with quality management accreditation are audited less frequently, whereas small companies and sole traders are audited more often. The scheme providers undertook audits of certification of construction activity as part of a wider package of audits on members’ work. There is a risk that the certification aspects could become ‘lost’ within other matters and its importance reduced.

6.1.1 Qualifications and competence

For electrical installations that are certified, the qualifications of the certifier are most important. To be accredited as an approved certifier the electrician must meet the requirements (set out above in section 3.3), and be employed by an Approved body. The certifier will, therefore, be a Level 3 Diploma NVQ qualified electrician. Further qualifications in periodic inspection and testing, as well as the 17th Edition (IET) wiring regulations will also be required. There is no variation in this approach, which is agreed by the scheme providers (SELECT and NICEIC).

66

The certifiers interviewed all met these requirements. They also indicated that the scheme providers were proactive in reminding certifiers and members of necessary updates to training and qualification renewal dates. It was confirmed that when the certifiers apply to renew their membership of the scheme that they are reminded of the lapse dates of their training and that membership would be suspended or cancelled if the necessary courses were not completed.

Competence of approved certifiers is assessed by the scheme providers, and relates to the necessary qualifications and ongoing training requirements. For certified work, the verifiers rely on the competence of the certifier and their approval through the scheme.

6.2 Robustness of the non-certified approach

6.2.1 Process and approach

The response to the survey (based on 15 local authorities who completed this part of the survey) indicated that in two local authorities virtually no certificates of construction were submitted over a three year period (no. 4 and 5) (see section 4.6). One local authority however had 100% certificates of construction (no. 10), with no other reasonable inquiry route being used. The other twelve had variable amounts of certificates of construction, but none were above 50%, with most around 10%.

Verifiers use the various types of guidance that is available, with the SBSA/SABSM guide, BS7671 and the Technical Handbooks being the most used.

The majority of respondents (92% of the 24 verifiers who completed the survey) indicated that they requested relevant documentation from the installer to confirm that the installations meet BS7671 (i.e. BS7671 certificates). This is therefore the most common approach to reasonable inquiry for non-certified work.

For the non-certified route the skills and qualifications of the installer are checked by verifiers in addition to the BS7671 documentation. Approved certifiers, members of appropriate trade associations, qualified electricians or SJIB graded electricians all being commonly accepted. One third stated that completion of the BS7671 electrical wiring course was sufficient. A number of verifiers had rejected completion certificates where the competence of the installer could not be proven. One verifier required electrical installers to effectively prove that they were the equivalent of a certifier of construction (see Verifier 6 interview in Section 5).

Some verifiers clearly favour the use of certificates of construction, the low level of current usage was not considered to be the fault of the verifier (i.e. by verifiers), although there was a perception that this is the case. It would benefit verifiers by reducing paperwork and removing a burden from ‘over-stretched’ staff.

Where electrical installations are not certified, the process within the majority of local authorities is to check the validity of the documentation they receive and the

67

competence of the electrician. However, there was found to be an inconsistency of approach regarding the types of documentation that would be accepted, and also in the level of competence required and in the level of checking of competence.

Although most local authorities used the LABSS Guidance document; many authorities had an internal policy or process which was followed by the building standards surveyors. These were based on the LABSS Guidance. These internal policies outline the documentation that will be accepted. Some authorities also had a building warrant checklist that included a section to check for competence, however, many of the verifier project files that were reviewed did not include proof that competence had been checked. One local authority included within their files a print out of their online check of the competence of installers (check of the membership number on the scheme provider website).

Most verifiers would accept a BS7671 certificate (including inspection and testing schedules) for the electrical installation along with confirmation that the installer was competent. Where an electrician is not a member of either SELECT or NICEIC, some local authorities will accept a copy of an SJIB card as proof of competence. Some local authorities will only accept certain SJIB cards, notably those of technician, approved electrician or electrician. The SJIB card includes on the back, a list of qualifications held by the individual. As noted above, one authority indicated that their consortia would require more than the SJIB card, effectively meaning that the installer needed to demonstrate full equivalence with the certification of construction scheme.

Additionally, emergency lighting and fire detection and alarm system certificates were also accepted to confirm the compliance of these systems with the relevant standards. In other cases, the verifier requests commissioning certificates to confirm the specialist electrical elements of a building.

When work is not certified, the electrical installer is only responsible for the electrical installation. It is within the remit of the verifier to confirm that the electrical work has not compromised any other elements of the building regulations. However, site checks of electrical installations are often done at completion stage, where it would no longer be possible to view the majority of the electrical installation. Verifiers (who have no electrical qualifications) rely on the competence of electrical installers to confirm the compliance of installations with Regulation 4.5 (Electrical Safety) and 4.6 (Electrical Installations).

Local authority verifiers rely entirely on the competence of the certifier. The verifier will check that the certificate number, the approved certifier number and the approved body number on the certificate are correct using the certification register. There was not always evidence to prove that this check had been conducted; though one local authority included a print out of the online check on the certification website within the project files which indicated that all numbers were valid which was ideal. However, this

68

‘paperwork’ check is all that is done; no further checks are made of the electrical installation or its interference with the other elements of a building.

Applicants can receive a 1% discount on building warrant application fees if they indicate in their application that they intend to use a certifier of construction. In reviewed files it appeared that applicants do not always inform Building Standards at application stage, but go on to use a certifier. The applicant therefore, does not receive the discount on their application fee. Clearly applications cannot always have information on the electrical installer and whether or not they are a certifier, therefore some adjustment to the warrant application process would benefit certification of construction.

6.2.2 Qualifications and competence

None of the local authority verifiers interviewed had specialist electrical knowledge or qualifications, and as such rely solely on the competence of the installer, even when the installation is not certified. Local authority verifiers are generally building standards surveyors, with degree level qualifications.

Those verifier staff with professional membership had a requirement to undertake regular CPD which will incorporate necessary updates to building regulations. Many of the local authorities also provide additional training to their verifiers.

The verifiers were able to check completed work with regards to numbers and positions of electrical sockets. They could also check the impact on other parts of the regulations (structures, fire, etc.), but there was limited evidence that checks were made at first fix. The completed works would be inspected, but as the installation was covered by plasterboard or other internal linings it could not be checked.

The verifiers indicated that they were able to process the paperwork for non-certified electrical work, but they were not qualified to check the information on an electrical test, condition or other report. There was no evidence that the information supplied by applicants was subject to further checks. This applied to larger projects and higher risk projects as well as small works.

Verifiers used evidence that a firm was an approved body or certification of construction scheme to approve work that was not certified, or they had membership of the trade bodies forming the scheme providers. The possession of an appropriate SJIB cards was also evidence accepted by some verifiers. It was not clear if this evidence was based on checking the approved body or that the specific certifier was involved. Although verifiers had procedures in place, the recording of evidence in a file could be lacking.

69

Most BS7671 certificates submitted to the verifiers were SELECT or NICEIC branded, and included certificate and membership numbers which can be confirmed with the relevant body to prove competence in line with the membership requirements.

Verifiers generally required inspection and testing schedules along with BS7671 certificates, but particularly where the forms are unbranded, there is no way of knowing that the schedules are correct or applicable. As none of the verifiers interviewed had electrical knowledge to check or confirm the contents of these reports then the training in the interpretation of electrical forms would be beneficial.

6.3 Gap between certified and non-certified work

As discussed above the research has not focused upon the impact of the different approaches on the quality and safety of the installations. However, it has addressed the gap between the processes, qualifications and competence of those involved.

Process and approach The research has determined that there are substantial differences between the processes and approaches between certified and non-certified work.

The research has demonstrated differences of opinion between verifiers and those involved in certification as to whether or not there is a gap between the two approaches. The verifiers consider that although the approach is different and indeed that there is an accepted lack of consistency amongst verifiers that the end product is the same. The approved certifiers take a different view and consider that there is much more done in certification than through the non-certified approach.

Involvement of certifiers and verifiers

Certifiers can act in different ways, either to certify their own work, that of electrical installers in their firm or installers in other firms. However, they need to check the physical installation at key points in order to certify that it complies with all sections of the building standards, as opposed to solely the electrical safety referred to in Standards 4.5 and 4.6. In practical terms it is more efficient to certify work that is within the firm’s own workload rather than another company, which is reflected in current practice by certifiers. There are risks in a certifier missing key parts of installations where other trades do follow on work, and to minimize such risks medium and larger firms should seek to have more certifiers employed in their firm. Consideration could be given to certifiers of construction working in teams rather than as individuals.

The non-certified approach is based primarily on the verifiers undertaking reasonable inquiry through assessing and checking the competence of installers. The verifier has limited technical skills that can directly inform them on the safety of electrical work. In particular, the verifier is therefore effectively undertaking a parallel process to the checks on certificates of construction. However, the non-certified approach is not

70

entirely consistent across the local authorities. There do appear to be risks in the checks undertaken, particularly around potential fraudulent use of SJIB cards or BS7671 forms. There is a certain reliance on ‘local knowledge’ of electrical installers, which some attracting more attention than others.

Perhaps the most significant difference that has arisen in the research is that certified electrical work has to take account of other relevant parts of the building regulations, whilst non-certified work focusses on electrical safety. The electrical installation work should not compromise other areas of the regulations in the non-certified approach, but these matters are checked as part of the wider process of reasonable inquiry.

In the certified approach the certifier must be able to demonstrate that they have been involved at all relevant stages of the installation. However, in some cases the verifiers’ first inspection may be following the submission of the completion certificate. However, they do not undertake the tests themselves as they are not qualified.

Qualifications and competence There are clear differences between a verifier who undertakes a process of reasonable inquiry for electrical installations and a certifier who either installs or checks work undertaken. Certifiers need to be qualified experienced electrical installers and can demonstrate competence.

In the verifier teams the building standards surveyors are not qualified in electrical installations, but hold more general building standards related qualifications. The surveyors know the regulations, standards and guidance, but the checks undertaken on electrical work are primarily paper based. None of the verifiers interviewed indicated competence in interpreting electrical forms and rely on the competence of the installers.

Electrical installation work that has been undertaken through the certified route should not result in poor quality or safety standards as qualified electricians are involved. In the public interest this route should be preferred. In addition, it assists the building standards process and ensures that completion can be approved in an efficient manner.

6.4 Alignment of the approaches

The relevant objectives were as follows:

“Where gaps are shown to exist, identify ways for certification and verification to be further aligned to improve compliance with the building regulations.

Identify whether any additional levels of certification or verification checking are needed for work covered by the scheme.”

It should not necessarily follow that because there is no identified difference in building performance that there is equivalence between the two approaches. It should though

71

be recognised that the two approaches can never be entirely equivalent. However, there are several aspects in which the approaches can be aligned more closely and these are discussed in this section of the report.

Process and approach The process and approach can be aligned by verifiers ensuring that they are involved in further site checking relevant to the electrical installation and testing. The risk assessment and reasonable inquiry plan should include provision to view electrical work on first fix as a routine element.

The process need not necessarily include all electrical work, but would be risk based. At present verifiers indicate that a risk based approach is used, but there is a lack of evidence any site checks carried out and there is an over-reliance on checking the competence of the installer at the end of the installation. Verifiers should undertake more routine checking of electrical installations in non-certified work and have appropriate training for this purpose.

At present certifiers do need to check work at various stages of installation in order to certify compliance with the regulations. There is a need to ensure that certifiers record site attendance in a structured fashion and what has been checked each time ensuring all key stages are covered. The scheme providers should lead on this matter and provide appropriate training and model processes. This is primarily a matter of record keeping in support of the activities that the certifier has to undertake at present. The file record should be kept in addition to providing the checklist with the certificate of construction.

There may be scope to allow certifiers to work as teams on larger projects. This would require approved bodies to employ more certifiers who are capable of checking work. Ultimately a lead certifier would need to sign a certificate, but team work could ensure that checks are fully undertaken even on the largest project.

Competence In order to align the approaches the competence of those checking non-certified electrical work should be controlled by each verifier. This should be on the basis of the risks involved in each project, with the risk being assessed each time. Verifier staff in the local authority should be provided with further training to aid their understanding of electrical forms that are submitted by applicants.

Appropriate training should be provided for those involved in compliance checking. The training would be appropriate to the types of projects that they assess for compliance. Resources would therefore need to be provided for this purpose. The training should apply to all local authorities no matter how they manage the electrical installation checking.

72

Guidance In order to support alignment of the approaches it is important that consistency is improved in the non-certified approach. The verifier guidance previously developed can be a base from which new procedures will be developed. The guidance should be developed and kept up to date by the Scottish Government working in collaboration with the Building Standards Managers at the local authorities. The guidance should cover technical aspects of checking installations at first fix as well as testing at the end of the installation work.

It should also be recognised that there are costs involved in the certification approach. In some instances the certifier can recover these costs through additional fees. However, for small building work the clients are often individuals who cannot finance additional certification fees. It may be possible to reduce certification requirements for very low risk work. This would ensure that the economics to do low value work are more attractive. This could apply perhaps to alterations and extensions of a certain type or an upper financial value for the work, but not to any new build project. Efficiency may be found by reducing the checklist for small works.

Changes to the scheme scope and approaches would require to be undertaken by the scheme providers in association with BSD. The support of the verifiers would also be essential to the success of any such move and the confidence that the scheme would still supply the same level of safety in the public interest.

6.5 Findings

The discussion presented above has provided the basis for the findings. The discussion used the evidence from the research to assess the gaps and how the approaches could be better aligned. At the same time the limitations on the two approaches mean that complete alignment is not possible. A number of findings are therefore made with regards to improving the alignment between the two approaches.

The improved guidance, process and verifier training should be the means to improve the transparency of the electrical checking of non-certified work.

Guidance The guidance for verifiers would be procedural and process driven as opposed to fully technical, it would provide a methodology for risk assessment. The guidance should be for use by all local authorities and would be maintained by the Scottish Government working with the Building Standards Managers.

The guidance would encourage a greater degree of technical checking rather than simply a paper based process to ensure the competence of the installer.

The scheme providers should consider how risk is assessed in smaller low complex and larger more complex works. For smaller works there may be scope to reduce the

73

need to sign off against some of the other criteria, whilst for larger projects documented evidence of site visits and checks carried out should be completed by certifiers.

Competence of electrical checkers After completion of the guidance it is suggested that each verifier should provide training for staff in checking and testing of electrical work at each relevant stage. For more complex or higher risk projects then those undertaking the electrical checking should develop a full plan to ensure that the work can be checked and tests witnessed by competent verifier staff. This does not take away from the need to ensure that the installers are competent, but will provide a greater alignment with the certified approach.

The training for verifiers would include issues such as the following:

Understanding the basics of electrical installation work, BS7671 and electrician competence

Electrical installation items to be inspected on site, including ‘first fix’ and completed works

Electrical testing requirements, including understanding electrical test results

Installation and testing of important equipment, e.g. fire alarms.

Training and CPD The training would ensure that surveyors and engineers keep up to date with new standards and are competent in understanding and interpretation of electrical installation, condition and testing forms.

The amount of training and CPD should be proportionate to the level of checking that the individual is carrying out and their prior experience. The provision of training to building standards surveyors will also provide assistance in improving communication between the verifiers and the electrical installers.

74

7 Conclusions The aim of the research was to address the certified and non-certified approaches to the checking of electrical installation work. Standards 4.5 and 4.6 of the building regulations set the electrical safety requirements of buildings in Scotland, while other standards must be met for a Certificate of Construction to be issued. These technical standards reference a range of other standards and guidance that can be used in design and electrical checking, in particular BS7671. In certified work the assessment of compliance with building regulations also includes checks on a range of other issues within Sections 1 to 7. To date there has been no evidence provided that the different approaches result in differences in the ultimate electrical safety and the risk to the public.

The research has demonstrated that as far as electrical certification of construction is concerned that there is widespread support from the local authorities, scheme providers (SELECT and NICEIC) and the individual certifiers. However, the volume of certificates of construction for electrical work is well below the potential of the whole market. One of the key issues raised was concerned with client demand and the lack of knowledge, particularly in the domestic market where individuals (alterations, extensions and re-wiring) rather than house-builder or commercial developers are the client group. All parties have a role in advising clients, but a consistent message is needed. Various respondents indicated that better incentives for those clients that use certifiers would be beneficial.

The following conclusions are made from the research:

The electrical scheme for the certification of construction has been shown to be robust and to set high standards for approved bodies and approved certifiers of construction. It covers the competence of those within the scheme and sets standards for certification activities. There is flexibility in the scheme operation, which is based upon the complexity of the project and nature of the business undertaking the work.

In non-certified work the electrical installation is typically controlled by experienced building standards surveyors. Each verifier has their own approach, although most follow the existing LABSS Guidance (Guidance on Electrical Installations not certified by an Approved Certified of Construction for Verifiers in their role as Enforces of Powers vested in the Building (Scotland) Act 2003) or a variation on it. The verifiers have limited competence in electrical work and do not have the qualifications to check installations and carry out testing. The verifiers are primarily checking that installers are competent.

75

There was lack of consistency and indeed transparency in the approach amongst the verifiers to electrical installation checking. The approach typically reflected the differences in the degree of risk perceived. One authority required almost an equivalent to the certification scheme as evidence for each installation, but typically SJIB cards and membership of trade bodies were enough evidence.

The scheme sets a template for consistency in the approach amongst different Approved bodies and approved certifiers of construction. It is clear that over the years a robust approach to auditing the membership has improved standards and consistency between certifiers. Although the approved bodies and certifiers found the audit process difficult it had benefits for the membership that were ultimately invaluable.

There was no evidence that the end products of certified and non-certified approaches were different. However, there were clear differences in the approaches, processes and competence of those involved. The certified approach is more highly regulated by the scheme and there is scope to improve the consistency and transparency of the non-certified approach.

A number of findings have been presented by the research, which are aimed at closing the gap between the approaches. The findings are achievable and proportional to the levels of risk involved in electrical checking. There is scope to make the non-certified approach more consistent and transparent. The electrical scheme may be able to consider adjusting requirements around low complexity/risk projects and high complexity/risk. At least more emphasis on documenting site visits, checks and any corrective actions taken should be required by the scheme providers. The certifiers interviewed had not necessarily recorded dates of site visits or what was assessed. Most especially in longer and more complex projects a greater degree of recording would be preferred. Smaller jobs may only require one visit and therefore the level of record keeping required would be more limited.

76

8 Appendices

8.1 Appendix 1 – Reference list

The desk based review has included the following documents:

1. Building Standards, Certification Leaflet (2012)

2. Building Standards, Certification (Electrical Installations to BS7671) (2009)

3. Building Standards Division, Certification Handbook (2012)

4. Building Standards Division, Procedural Guidance on Certification including information to be submitted with a Building Warrant Application (2010)

5. Building Standards Division, Improving Compliance with Building Regulations, Consultation Report (2010)

6. Scottish Building Services Certification, Certification of Construction (Electrical Installations to BS7671) Scheme Guide (2013)

7. SELECT, Certification of Construction, Technical Guide 2010

8. SELECT, Code of Practice (2008)

9. NICEIC, Rules Relating to Registration for Certification of Electrical Installations in Scotland (2012)

10. NICEIC, Code of Conduct (2014)

11. Building Standards, Technical Handbook – Non-Domestic, Section 4: Safety (4.5 Electrical Safety and 4.6 Electrical Fixtures) (2013)

12. Building Standards, Technical Handbook – Domestic, Section 4: Safety (4.5 Electrical Safety and 4.6 Electrical Fixtures) (2013)

13. BS7671: 2008 Requirements for electrical installations (as amended)

14. Electrical Safety First, Best Practice Guides 1 – 8 (2014)

15. Institution of Engineering and Technology, Electrical Safety: A perspective based on incidents (2013)

16. SABSM (now LABSS), Guidance on Electrical Installations not certified by an Approved Certified of Construction for Verifiers in their role as Enforces of Powers vested in the Building (Scotland) Act 2003 (2006)

17. LABSS, Verification during Construction: Guidance to Support the Application of Reasonable Inquiry (Domestic and Non-Domestic) (2013)

18. Electrotechnical Certification Scheme (Website) (http://www.ecscard.org.uk/)

77

19. Electrician Job Profile (Website) (https://nationalcareersservice.direct.gov.uk/advice/planning/jobprofiles/Pages/Electrician.aspx)

20. SJIB (Scottish Joint Industry Board for the Electrical Contracting Industry) (Website) (http://www.sjib.org.uk/index.php)

21. Electrical Safety First (Website) (http://www.electricalsafetyfirst.org.uk/)

22. Institution for Engineering and Technology – Electrical Excellence (Website) (http://electrical.theiet.org/courses/index.cfm)

23. Health and Safety Executive – Electricity at Work (Website) (http://www.hse.gov.uk/electricity/index.htm)

8.2 Appendix 2 – Example Certificates

The example certificates acknowledged in this report are in pdf format and as such are included as separate files to this document.

8.3 Appendix 3 – Verifier Survey Questions

The survey questions are in pdf format and will be included as a separate file with this document.

8.4 Appendix 4 – Verifier Survey Responses

The verifier survey responses are compiled in an excel spreadsheet and will be included as a separate file with this document.

8.5 Appendix 5 – Verifier Interview Questions

1. Can you discuss your approach to verification of electrical work in your

authority? What controls and checks are put into place to ensure the approach is robust?

2. Has the approach changed over the years?

3. Do verifiers carry out any checking (of electrical installations) themselves?

78

4. Is the checking routinely outsourced?

5. If outsourced, who do you use and what do you expect of the consultant (standards, qualifications, reporting, etc.)?

6. How are specialist electrical design elements checked on site for compliance?

7. If you undertake in house checking of electrical installations, what qualifications are required from those undertaking these checks?

8. How do you check that those undertaking checks keep up to date with technical developments (e.g. changes to BS7671)?

9. Do you ever make checks on certified work? If so, why?

10. If a member of the public raised an issue over certified work, would you seek to check it? How? Would you report it to the Scheme Provider?

11. Do you think that a gap exists between certified and non-certified work? If so, what can be done to close that gap?

12. What do you think can be done to align electrical work checking by certified and non-certified routes?

8.6 Appendix 6 – Certifier Interview Questions

1. Please described your set up as an Approved body (including the number of

certifiers, locations, scheme provider)?

2.

a. What is your approach to certification of construction (e.g. installers are certifiers, only one member of staff is a certifier)?

b. What guidance do certifiers use for compliance checking?

c. How do you assess risk with regards to building certification – how would you differentiate between low, medium and high complexity work?

3. What qualifications are held by the certifiers?

79

4. What processes do you undertake to certify electrical work? Is it outsourced?

5. If it is outsourced, who do you use and what do you expect of them?

6. How are more complex buildings / specialist design elements checked?

7. How do you ensure that the certifier has the qualification, experience and competence to do a specific job, especially higher risk / more complex projects?

8. How do you check that those undertaking certification keep up to date with technical developments?

9. What quality assurance procedures do you have for certified work?

10. If a member of the public, or a verifier, raised an issue over certified work, would you check it and how? Would you report it to the Scheme Provider?

11. Do you think that a gap exists between certified and non-certified electrical work? What is the gap and what is its impact? If yes, what can be done to close that gap?

12. What do you think can be done to align electrical checking by certified and non-certified routes?

13. How many audits have you had by the scheme? Were there any issues, and how were improvements made?

final report on the level of checking of electrical installations to

Documents