The Remedial Safety Gap
Many organisations are falling into a dangerous gap between electrical safety testing and remedial work. We regularly see situations where sites have been tested but the subsequent observations have not been actioned. In instances like this we find that the reason is often down to cost.
However, the Electricity at Work Regulations 1989 regulation 3 states that this is only applicable when the cost is grossly disproportionate to the risks imposed on the end users. If the essential remedial work is not completed following testing then organisations could be culpable of fault and negligence. It’s also likely that insurance for the site would be compromised and in severe circumstances it could be proven that the duty holder was liable and in breach of his/ her statutory requirements.
Following on from inspection and test a report should be issued that details any ‘damage, deterioration, defects and dangerous conditions within the installation’. Satisfactory reports present no immediate danger however they could list a number of Code 3 (C3) remedial actions. These highlight parts of the installation that no longer comply with the current edition of the wiring regulations. As BS 7671 is not retrospective installations installed to earlier editions may present non-conformances under the current version. In scenarios like these we must identify these as C3 observations (requires improvement) and advise duty holders to have these remedied.
Unsatisfactory reports however list the observations and their location, and a code is assigned against each. Any fault reported as Code One, Code Two or F/I (Further Investigation) must be remedied before the installation can be deemed satisfactory. There should be no lack of clarity about faults in the testing reports or certification. Any fault found that would render the installation unsatisfactory will be clearly marked within the “Schedule of items inspected” with a code. The observation will then be detailed within “section K” of the EICR.
This testing and reporting procedure assumes that the duty holder will then establish what remedial work is required (note that the scope of the testing engineer is to provide ‘a factual report on the condition of an installation, not a proposal for remedial work’) and make swift arrangements for it to be carried out. The danger is that the report is simply filed and the duty holder’s responsibilities considered fulfilled.
The report will give written notification on Code One faults that require remedial action that should be taken without delay. The regulations require that, wherever practicable, items classified as ‘Danger present’ Code One (C1) should be made safe on discovery, for instance by switching off and isolating the affected part of the installation until remedied. Where it is not possible to rectify the C1 fault at the time of discovery the engineer should make the duty holder aware of the danger that exists and agree the appropriate action to be taken to remove the source of danger before continuing with the inspection or testing. In some cases this may prevent further inspection and testing work from progressing.
If left unremedied minor faults can become more serious and costly C1 faults, and one practical way to avoid further disruption to services is to appoint one supplier to undertake both testing and repair work with minor faults being rectified at the time of the time of testing. This is particularly efficient in multi-site environments where costs can be saved by sending an electrical engineer to each branch to test and scope remedial work followed by an electrician to undertake the repair work, rather than a test engineer followed by a separate technician to quote for remedials and another engineer visit to fix the faults. This cuts the process to two-step rather than three. For this to be possible budget limits must be pre-agreed so that necessary work can be done without delay.
In summary, it’s imperative to appreciate that periodic fixed installation testing is only one part of electrical safety compliance. Essential remedial work must be completed in a time-frame appropriate to the coding of the fault or faults found – and in the case of C1 faults this means urgently. Safety of employees and business continuity are fundamental principles for any business owner and an experienced electrician can help improve performance, increase control and reduce costs.
To discuss your electrical remedial works and repairs please contact our Remedials team on 01242 587080.