Electro-Technical Council of Ireland
Limited
Response to the CER’s Consultation Paper
CER/14/130
Regulation of Electrical Contractors with
respect to Safety from 2016
ELECTRO-TECHNICAL COUNCIL OF IRELAND LIMITED 2014
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ETCI response to CER’s Consultation Document – 31st July 2014 – Page 2 of 32
Table of Contents:
1.0 Introduction
5
1.1 The Electro-Technical Council of Ireland Limited (ETCI)
7
1.2 What is ETCI?
7
1 3 ETCI's Mission Statement
7
1.4 Objectives of the ETCI
8
1.5 Structure of ETCI
9
1.6 Member Organisations of ETCI
10
1.7 ETCI Membership of International Organisations
11
1.8 The Standardisation Process
11
1.9 ETCI Technical Committees
12
1.10 ETCI's Task Forces
17
1.11 ETCI Procedures
17
2.0 Scope of ETCI’s Response
19
3.8 Electrical SSB Compliance
21
4.2 Modifications
22
5.4 Assessment of Qualified Certifiers
23
6.2 Individual Registration of REC’s
25
6.4 Categories of REC’s
26
9.1 The Certification System
28
9.2 Electronic Certification Scheme
30
9.3 Non-Compliances
31
List of Tables:
Table 1.7 – ETCI Membership of International Organisations
11
Table 2.0 – ETCI’s responses to document by section
19
List of Figures:
Figure 1.5 – Organisation of the Electro-Technical Council of Ireland
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 3 of 32
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ETCI response to CER’s Consultation Document – 31st July 2014 – Page 4 of 32
Electro-Technical Council of Ireland Limited response to CER’s Consultation Document in respect of the
Regulation of Electrical Contractors with respect to Safety from 2016
1.0 Introduction
Technical Standards/National Rules
Rules and regulations for Electrical Installations date from the late 19th century, mainly in the UK and Germany
where they were developed by the professional engineering institutions IEE and VDE respectively. This discipline
has always been distinct from standards work which only commenced in the first quarter of the 20th century,
again mainly by the British Standards Institution (BSI) and the German (DNA) respectively, both voluntary nongovernment bodies, as is the norm in most countries.
Standards concern mainly products, as may be seen from the catalogue of European Standards, which standards
are published in Ireland by NSAI as I.S. ENs.
The nature and method of preparation and maintenance of Rules for Electrical Installations, popularly referred to a
”Wiring Rules” is a different process, requiring as it does co-operation and consensus of all major interests, and a
rapid response to the needs of safety and industry that arise from time to time.
Our National Rules were developed by ETCI, a representative body for the electrical sector, set up in 1972 with
the formal approval of the Department of Industry and Commerce and the Minister, specifically:
•
To advise and co-operate with the IIRS on standards and standardization
•
To produce national wiring rules, drawing on the expertise of its member bodies,
•
To represent Ireland in CENELEC as the Irish National Committee, as a non-government, broadlyrepresentative body which was one of the conditions for membership.
Wiring Rules are not standards in the accepted sense. The European Commission in 1994 it made it clear that an
electrical installation is not a product, and that it would not issue any Directive on the subject. Accordingly,
CENELEC does not produce European Standards for installation rules.
Rules for electrical installations are harmonized (as distinct from being “standardized”) throughout Europe, the
result of four decades of continuing technical discussions and decisions in CENELEC, the European Committee
for Electrotechnical Standardization. These are elaborate and detailed as can be seen in our own National Rules.
CENELEC decisions take the form of “Harmonization Documents” (HDs) and each member country is obliged to
implement merely the technical content thereof. Members are permitted retain their “Special National Conditions”
(SNCs) by agreement. Each country may use its own wording and format as appropriate, which is the case with
our National Rules.
From the above, it may be seen that “Wiring Rules” are quite different from standards and as such require a
different type of organization and procedures.
The present National Rules have evolved over four decades within ETCI and have
•
greatly helped to reduce the level of electrical fatalities and fires due to electricity
•
brought discipline to the electrical contracting industry
•
raised the level of safety in electrical installations to a level amongst the highest in Europe and beyond
•
formed a technical reference in safety legislation enacted by the HSA and the Department of
Environment and Local Government
•
gained universal acceptance in Ireland e.g. by governmental, industrial and private bodies.
There is no existing (or foreseeable), viable alternative to the ETCI National Rules and their supporting
services that would ensure maintaining our present high electrical safety levels
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 5 of 32
Proposed Future Arrangements
It should be made clear that any change from the existing ETCI certification system to some other system similar
to that in use for gas installations would be detrimental in general, but in particular, to the important matter of the
safety of the consumer.
Comparison of gas installations with electrical installations.
In the normal domestic premises, a gas installation will comprise a boiler, tubing, and additionally, in some cases,
gas appliances such as cookers and fires. Inspection, testing and subsequent certification is a simple and
straightforward process which is reflected in the type of certificate used. +
+
An electrical installation is complex and extends throughout a premises. It consists of distribution board,
equipment for heating, lighting, protective devices for every circuit, earthing systems. It must provide protection
against electrocution by direct contact and in case of an electrical fault. Likewise, an installation must provide
protection against thermal effects including fire. Verification by a rigorous series of tests and checks is essential to
ensure that the system will protect life and property in the manner intended.
Certification
The completion of any new installation of necessity requires verification of compliance with the Rules, which
consists of inspection, testing, and recording the results followed by certification. These are laid down in Part 6 of
the National Rules, which implements CENELEC Harmonization Document HD 60364.6.61:2007 and they
cannot be changed without the agreement of CENELEC.
The present certification procedure and form of certificate is the result of many years of experience which has
evolved as an integral part of the National Rules. Moreover, the form of certificate is contained in the Rules and is
therefore copyright.
A presentation was made this year at the meetings of IEC TC64 and CENELEC TC64 (Installation rules technical
committees) describing the ETCI certification system. It was extremely well received by all delegations, which
clearly shows that Ireland now appears to be leading the field in this respect.
The ETCI certification procedure for electrical installations includes recording the many inspections and tests
that verify compliance with Chapter 6 of the Rules. Any dilution or simplification of this procedure would be a
retrograde step that would inevitably result in a lowering of safety levels in installations with consequential
increased risk to life and property.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 6 of 32
1.1 The Electro-Technical Council of Ireland Limited (ETCI)
The Electro-Technical Council of Ireland Limited (ETCI) is a not for profit organisation consisting of nineteen
organisations representative of all aspects of electro-technology in the Republic of Ireland. Formally constituted in
1972, the Council is the national body responsible for the harmonisation of standards in the Electrotechnical field
in collaboration with the National Standards Authority of Ireland (NSAI). ETCI was incorporated as a company
limited by guarantee in April 2000. The Company is registered with the Companies Registration Office, Dublin;
Registration number 240152.
Registered offices: Unit H12, Centrepoint Business Park, Oak Road, Dublin 12
The governing body of ETCI is its Council which is comprised of one representative from each of the member
organisations. ETCI operates through a process of consultation leading to consensus through the agency of a
number of executive sub-committees and technical committees. The organisation chart shows the relationship
between the Council of ETCI and its various committees. Contribution to ETCI is made at organisation level
through full elected membership or by sectional interest in participating in the work of the relevant Technical
Committee.
The Electro-Technical Council of Ireland Limited (ETCI) is a not for profit organisation, consisting of nineteen
organisations representative of all aspects of electro-technology in the Republic of Ireland. These member
organisations are listed. A representative from each of the nineteen organisations forms the Council of ETCI.
The Technical Management Committee (TMC) first introduced ETCI's Manual of Procedures in 1997 with the
aim of regularising ETCI's activities and of standardising procedures. The purpose of these procedures is to equip
members in understanding the modus operandi of ETCI. These procedures are password protected, and can be
found in the ETCI Members section
1.2 What is ETCI?
The Electro-Technical Council of Ireland Limited (ETCI) has two primary roles: electro-technical standardisation
and the promotion of electrical safety.
ETCI represents all aspects of electrotechnology in Ireland and is the Irish Electrotechnical Committee to the
International Electrotechnical Commission (IEC) and the European Committee for Electrotechnical
Standardisation (CENELEC). ETCI is the Irish member of the Electricity Section of the International Social
Security Association (ISSA).
1 3 ETCI's Mission Statement
ETCI contributes to the development of national and international standards through the participation of members
of its Technical Committees, with their counterparts from EU and other countries, in the deliberations of the
relevant IEC and CENELEC electro-technical bodies to which standard-making is entrusted. ETCI refers the
resulting agreed texts to NSAI for publication as Irish Standards
Accordingly, the Mission Statement of ETCI may be defined as follows:
"To provide the representative voice of the Irish Electrical Industry on electro-technical matters relating to
safety and standards both in National and International Fora."
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 7 of 32
1.4 Objectives of the ETCI
1.
2.
3.
4.
To promote and co-ordinate standardisation in all branches of electro-technology in harmony with
international agreements and in collaboration with the National Standards Authority of Ireland (NSAI).
To establish liaison with similar bodies in other countries and with international bodies.
To promote safety in electrical equipment and installations and to encourage an awareness of electrical
safety among the general public
To advise and make recommendations on any matter pertaining to electrotechnology.
In realising the first two closely-related objectives, ETCI
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contributes to the development of international standards through the participation of members of its
Technical Committees with their counterparts from EU and other countries, in the deliberations of the
relevant IEC and CENELEC technical bodies to which standard-making is assigned.
refers the resulting agreed texts to NSAI for publication as Irish Standards.
participates in the formulation by CENELEC and its constituent bodies of international schemes of
certification and mutual recognition of the quality and safety characteristics of Electrotechnical products.
The third objective is achieved through
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the preparation and publication of National Rules for Electrical Installations and of guides to their
effective implementation in practice.
publishing brochures, in collaboration with ESB, on precautions for the safe use of electrical equipment
and appliances, for the benefit of the general public and of particular communities within it, such as those
engaged in agriculture.
In pursuance of its joint objectives, ETCI provides a reference and advice facility whereby copies of its
publications are made available and specific enquiries on their interpretation are processed.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 8 of 32
1.5 Structure of ETCI
Organisation for the Electro-Technical Council of Ireland Limited:
Figure 1.5 – Organisation of the Electro-Technical Council of Ireland
Council - The governing body made up of one representative from each member organisation. Information on the
Council can be accessed by clicking here.
ETCI Board - The Board of Directors, which consists of the Officers, Past-Chairman and nominated persons, is
responsible for the functioning of the organisation. Information on the Board can be accessed by clicking here.
International Policy Committee (IPC) - The scope of the IPC is to determine the ETCI position on policy and
administrative matters of IEC and CENELEC
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 9 of 32
Training Committee - The scope of the Training Committee is to plan, develop and market the ETCI training
programme and to oversee the implementation of this programme.
Technical Management Committee (TMC) - Coordinates and monitors work programmes of the Technical
Committees.
Technical Committees - Set up by the Council to deal with specific sectors of electrotechnology.
Task Forces - Set up by the Council to carry out a specific task.
1.6 Member Organisations of ETCI
The Electro-Technical Council of Ireland Limited, (ETCI), is a not for profit organisation of nineteen
organisations representative of all aspects of electrotechnology in the Republic of Ireland. These member
organisations are listed below. A representative from each of the nineteen organisations forms the Council of
ETCI.
Association of Consulting Engineers of Ireland
Association of Electrical Contractors Ireland (AECI)
Association of Electrical Wholesalers
Chartered Institution of Building Services Engineers (CIBSE)
Dublin City Council
Dublin Institute of Technology
Eircom
Electrical Contractors Association
Electricity Supply Board
EMDA - The Electrical Manufacturers and Distributors Association of Ireland
Engineers Ireland
Health and Safety Authority
Institution of Engineering and Technology
Irish Cable Makers Association
Irish Engineering Enterprises Federation (IEEF)
National Consumer Agency (NCA)
National Irish Safety Organisation (NISO)
Radio Telefis Eireann
Technical, Engineering & Electrical Union
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 10 of 32
1.7 ETCI Membership of International Organisations
ETCI is the Irish Electrotechnical Committee to CENELEC and IEC and is Irish member of ISSA.
The International Electrotechnical Commission (IEC)
The European Committee for Electro-Technical Standardisation (CENELEC)
The Electricity Section of the International Social Security Association (ISSA)
Table 1.7 – ETCI Membership of International Organisations
1.8 The Standardisation Process
The Electro-Technical Council of Ireland (ETCI) is the National Electro-Technical Committee responsible for the
harmonisation of standards in the Electrotechnical field, in collaboration with the National Standards Authority of
Ireland (NSAI).
ETCI promotes and co-ordinates standardisation in all branches of electrotechnology in harmony with
international agreements, and in collaboration with the National Standards Authority of Ireland (NSAI). The
Council also establishes liaison with similar bodies in other countries and with international bodies.
ETCI contributes to the development of international standards through the participation of members of its
Technical Committees, with their counterparts from EU and other countries, in the deliberations of the relevant
IEC and CENELEC technical bodies to which standard-making is entrusted. ETCI refers the resulting agreed texts
to NSAI for publication as Irish Standards.
This harmonisation of standards is achieved by a process of consultation leading to consensus, through the agency
of a number of executive sub-committees, Technical Committees and Task Forces.
ETCI is the National Electro-Technical Committee to the International Electrotechnical Commission (IEC) and
the European Committee for Electro-Technical Standardisation (CENELEC).
CENELEC produces three types of documents, European Standards (EN), Harmonisation Documents (HD) and
European Pre-Standards (ENVs). European Standards are intended to be published or endorsed, in all Member
Countries, as identical national standards. For Harmonisation Documents, the technical content is intended to be
incorporated into the national standard, but not necessarily identically. The HD allows national deviations for a
specified period. Membership of CENELEC confers obligations to implement both documents. ENVs are
European Pre-Standards published by CENELEC to gain experience in newly developed areas of
electrotechnology and are intended to be converted into ENs within a few years.
ENs and HDs are based on IEC standards, or in the rare case that a suitable one does not exist, CENELEC may
initiate the work. IEC does not start new work in areas where CENELEC has declared an interest. Their relative
contributions are now determined in the framework of the IEC/CENELEC Co-operation Agreements.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 11 of 32
1.9 ETCI Technical Committees
ETCI promotes and coordinates standardisation in all branches of electrotechnology in harmony with international
agreements and in collaboration with the National Standards Authority of Ireland (NSAI). This is achieved
through the participation of members of ETCI Technical Committees and Task Forces with their counterparts
from EU and other countries in the deliberations of the relevant IEC and CENELEC technical bodies to which
standard-making is assigned.
There are over 200 members on ETCI's committees who contribute their experience and expertise on a voluntary
basis. ETCI recognises this expertise as the organisation's greatest asset and, in appreciation and in defence of the
commitment and professionalism of these experts, expects the members of its Technical Committees (TCs) and
Task Forces (TFs) to abide by the tenets of the ETCI Code of Ethics. ETCI's committees are concerned with the
following subjects:
Technical Management Committee (TMC)
ETCI has established seventeen Technical Committees/Task Forces. The work of these Technical
Committees/Task Forces is monitored and coordinated by the Technical Management Committee. More on TMC
International Policy Committee (IPC)
The ETCI International Policy Committee formulates policy decisions particularly in relation to Ireland’s
participation in CENELEC and IEC. The committee meets on a regular basis particularly prior to international
meetings or when the Irish national position on international matters must be agreed. More on IPC
Training Committee (TRGTC)
The scope of the Training Committee is to plan, develop and market the ETCI training programme and oversee
the implementation of this programme. More on TRGTC
TC 1 Safety of household and similar electrical appliances
ETCI TC1 is responsible for the Irish contribution to standards in the field of safety of electrical household
appliances, including those used on commercial premises and on farms. The committee participates in the work of
IEC and CENELEC TC61 which provide International and European Standards for this Electrotechnical area.
More on TC1
TC 2 Electrical Installations
ETCI TC2 has been in existence since January 1971 when it took over the work of the National Wiring
Regulations Committee. TC2 members are drawn from the main organisations concerned with electrical
installations. TC2 consists of the Main Committee, whose primary task is the publication of the National Rules for
Electrical Installations, and Sub-Committees and Working Groups. More on TC2
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 12 of 32
TC 3 Power installations exceeding 1 kV a.c. (1.5 kV d.c.)
ETCI TC3 is the Committee responsible for preparing standards for high voltage power installations exceeding 1
kV a.c. (1.5 kV d.c.) located indoors or outdoors, including earthing. The standards will specify the design
requirements of the installations, and the selection and erection of electrical equipment in order to ensure the
safety of persons and the proper operation of the installations.
The standards will not be applicable to overhead and underground lines between consumers' separate installations.
More on TC3
TC 4 Switchgear, control gear and associated equipment
ETCI TC 4 is actively involved in the work of IEC TCs 17B, 17D and 23E and CENELEC TCs 17B, 17D and
23E, except RCDs. The matter of Residual Current Devices (RCDs) was delegated to a Task Force on which some
members of TC4 also serve.
The current work of the committee is to maintain the two published Codes of Practice:
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Code of Practice for the Design, Selection and Erection of Low Voltage Switchboards for Industrial and
Commercial Applications.
Code of Practice for the Design, Selection and Erection of LV Switchboards for Residential Applications.
More on TC4
TC 5 Electrical safety and statistics for accidents and fires caused by electricity
The scope of the ETCI Safety Committee, TC5 includes the examination and reporting of electrical accidents and
the provision of advice, including literature, on safety matters.
TC 5 achieves this through:
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Compilation of electrical accident statistics, both fatal and non-fatal, analysis of the cause of such
electrical accidents, and the provision of advice on the most appropriate measures to prevent recurrence.
Publication of information leaflets, booklets, and videos on electrical safety for the home, farm,
workshop, factory, shop, office or other such location.
Reviewing statutory regulations and guidelines on electrical safety and inputting into any reviews of
same.
Interacting with other ETCI Technical Committees on matters of electrical safety, including EMC and
EMF issues.
Participation on national and international bodies associated with electrical safety.
Participation in seminars, radio and TV programmes that require advice and demonstrations on electrical
safety.
More on TC5
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 13 of 32
TC 6 Equipment for potentially explosive atmospheres
ETCI TC6 has been in existence since 1976; TC6 provides the broad national framework for ensuring that the
views of manufacturers and users of electrical equipment for explosive atmospheres are taken into account in the
drafting of European and International Standards for this type of equipment. Members of TC6 have been involved
in the development of over 40 standards in the field by attendance at IEC and CENELEC sessions since 1977.
The work of TC6 has led to the publication of European standards which in time have been transposed into Irish
Standards and have been published by NSAI. More on TC6.
The first edition of the National Rules for Electrical Installations in Potentially Explosive Atmospheres was
published in 1984, the second edition was published in 2001 – culminating in the third edition in 2011. Numerous
other publications include a Guide to the Selection of Electrical Apparatus for use in Potentially Explosive
Atmospheres – ET202:2001, A Recommended Maintenance and Inspection Routine for Electrical Installations in
Potentially Explosive Atmospheres – ET209:2003 and TC6 have developed a Training Manual in Potentially
Explosive Atmospheres – ET216: 2007. TC6 are currently engaged in the provision of very successful joint
ETCI / SGS Baseefa courses and seminars in respect of hazardous areas and potentially explosive atmospheres.
The National Rules for Electrical Installations in Potentially Explosive Atmospheres – ET105:2011 3rd Edition
has been recently up-dated to bring it up to date with latest national and international practice and to coordinate
the publication with the provisions of the Fourth Edition of the National Rules for Electrical Installations
(ET101:2008) and the legal requirements of the Safety, Health and Welfare at Work (General Application)
Regulations (S.I. 299 of 2007).
The implementation date for the National Rules for Electrical Installations in Potentially Explosive Atmospheres
was the 3rd January 2012.
TC 10 Electrical equipment in medical practice
ETCI TC10 is responsible for the standardisation of electrical equipment used in medical practice. The Committee
contributes to CENELEC TC62 and also to IEC TC62 and its four subcommittees:
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SC62A: Common Aspects of Electrical Equipment used in Medical Practice
SC62B: Diagnostic Imaging Equipment
SC62C: Equipment for Radiotherapy, Nuclear Medicine and Radiation Dosimetry
SC62D: Electro medical Equipment
ETCI TC10 provides a national focal point for the development of the IEC 601 series of standards. The goal of the
IEC 601 standards is to improve safety in the use of medical electrical equipment by providing a body of
standards that assist:
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Manufacturers in designing and assembling safe medical electrical equipment and systems.
Manufacturers, test houses and regulatory authorities in assessing compliance with requirements set forth
in the standard and
Health care professionals in managing the risks associated with use of these products.
ETCI TC10 is also responsible for co-ordinating the participation of Irish experts in a number of the 32 Working
Groups integral to IEC TC62. More on TC10
TC 11 Safety of Electronic Equipment within the Field of Audio/Video, Information Technology and
Communication Technology
ETCI TC11 is the national committee responsible for co-ordinating national standardisation in the area of safety of
electronic equipment within the field of audio/video, information technology and communication technologies.
Committee members are active participants in the international standards work of both CENELEC TC108 and
IEC TC108. The Committee takes a particular interest in the development of IEC Publication 60950-1, which
addresses the general safety requirements of information technology equipment. More on TC11
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 14 of 32
TC 12 Electronic Communication Systems
ETCI TC12 is responsible for co-ordinating standards development in the area of electronic communication
systems. It monitors and participates in the international work of IEC TC46 (Cables, wires, waveguides, R.F.
connectors, R.F. and microwave passive components and accessories), IEC TC86 (Fibre optics) and IEC TC100
(Audio, video and multimedia systems and equipment). The work of IEC TC100 covers a wide area of technology
including specifications for the performance, methods of measurement, application and interoperability of
consumer and professional AV and multimedia systems and equipment. The work of TC12 leads to the eventual
publication of European Standards, which in turn are transposed into Irish Standards. More on TC12
TC 13 Alarm Systems
TC13's remit is the Standardisation for alarm systems for the protection of persons and property, and for elements
used in such systems. The scope includes in particular systems for intruder and hold-up alarms, access control,
periphery protection, combined intruder-fire alarms, social alarms, and CCTV, as well as other monitoring and
surveillance systems related to security applications, and associated and dedicated transmission and
communication systems. More on TC13
TC 14 Electric Cables
ETCI TC14 is the Committee responsible for standards in the area of low, medium and high voltage cables and
accessories. In this context work is monitored and contributions are made to both IEC and CENELEC TC20
committees, sub-committees and working groups. TC14 is also extremely active in the data cable sector, attending
and contributing to the responsible CENELEC TC46 committee. More on TC14
TC 15 Human Exposure to Electromagnetic Fields
The scope of TC15 is to develop standards in the area of Electromagnetic Fields and Human Health. This is be
achieved through participation in the work of CENELEC TC106X (Electromagnetic fields in the human
environment) and through the continued monitoring of IEC TC106 (Methods for the assessment of electric,
magnetic and electromagnetic fields associated with human exposure).
The following aspects are considered in this work:
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Provision for compliance with basic exposure restrictions to prevent harmful effects
Specification of appropriate measurement techniques
Provision of guidance on the reduction of exposure of people
Guidance on the reduction of indirect effects of exposure (contact current effects)
More on TC15
TC 16 Electromagnetic Compatibility
TC16 is responsible for the Irish input into standards dealing with electromagnetic compatibility across the entire
frequency spectrum. TC16 participates and contributes to the work of CENELEC TC210, SC210A, IEC TC77,
SC77A and IEC/CISPR. The areas of interest of these various CENELEC and IEC technical committees (TCs)
and subcommittees (SCs) are as follows.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 15 of 32
CENELEC
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TC210 Electromagnetic Compatibility (EMC).
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ACEC Advisory Committee on Electromagnetic Compatibility
TC77 Electromagnetic Compatibility (EMC).
SC77A Low Frequency Phenomena.
SC77B High Frequency Phenomena.
CISPR International Special Committee on Radio Interference.
CISPR/A Radio Interference Measurements and Statistical Methods.
CISPR/B Interference Relating to Industrial, Scientific and Medical RF Apparatus.
CISPR/D Interference Relating to Motor Vehicles and Internal Combustion Engines.
CISPR/F Interference Relating to Household Appliances, Tools, Lighting Equipment and Similar
Apparatus.
CISPR/H Limits for the Protection of Radio Services.
CISPR I Electromagnetic Compatibility of Information Technology Equipment, Multimedia Equipment
and Receivers
CISPR S Steering Committee of CISPR
More on TC16
IEC
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TC 17 Automation and Programmable Systems
This Technical Committee was established in late 1998. Prior to this, it operated as a Task Force. The Automation
and Programmable Systems Technical Committee follows the work of CENELEC Subcommittee 65CX (Fieldbus)
and IEC Subcommittee 65C (Digital Communications) which develop standards for a common fieldbus. More on
TC17
TC 18 Marine Energy - Wave, Tidal & Other Water Current Converters
TC18 was set up in 2008 to mirror the work of IEC TC114 whose scope is to prepare international standards for
marine energy conversion systems and its primary focus will be on conversion of wave, tidal and other water
current energy into electrical energy. More on TC18
TC 19 Insulators & Surge Arrestors for greater than 1kV
TC19 was set up in 2008 in response to a request from Irish industry to monitor and contribute towards the work
of IEC TC 36 (Insulators) and IEC TC37 (Surge Arrestors). More on TC19
TC20 Smart Grids, Renewables, Electric Vehicles and Energy Efficiency
TC20 was established in 2010 dealing with Smart Grids, Renewables, Electric Vehicles and Energy Efficiency.
The committee will monitor similar work being carried out in CENELEC and IEC. More on TC20
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 16 of 32
1.10 ETCI's Task Forces
ETCI's Task Forces, TFs, are established to carry out a specific task normally within a definite time period. The
following are the current ETCI TFs:
Lightning Risk Assessment Task Force
As a result of queries from Irish industry regarding I.S. EN 62305-2: 2006 (Protection against
Lightning - Part-2: Risk Management) ETCI was requested by Irish industry to examine this standard relative to
Irish meteorological conditions and to propose, if necessary, a National Forward to I.S.EN 62305-2:2006. More on
LRATF
Photoelectronic Controls Task Force
The PCTF was set up to pursue the conversion of the Irish standard, I.S.428 - Photoelectronic Controls - into a
European standard (EN) at CENELEC. The CENELEC Technical Board (BT) set up its Task Force, BTTF 74-1,
to carry out this work. The ETCI PCTF's function is to provide the Irish contribution to this BT Task Force. More
on PCTF
Residual Current Devices Task Force
The RCDTF was established in September 1996 to provide a specialist focus for formulating standards for
residual current devices. The Task Force is responsible for monitoring the work of CENELEC Technical
Committee TC23E (Circuit breakers and similar devices for household and similar applications) in so far as it
relates to RCDs and for providing appropriate advice to ETCI Council. More on RCDTF
Qualifications of Installation Contractors Task Force
The Qualifications of Installation Contractors Task Force was set up in 1998 to represent the Irish input at the
CENELEC TC218 on Qualification of Electrical Installation Contractors. The task of TC218 was to prepare a
draft standard defining the characteristics and relevant general criteria and references for qualification of electrical
power works, electronic and telecommunication works and other electrical installations, included under Directive
93/37/EEC. This has now been accomplished and a Technical Specification TS 50349 has been published.
The primary task of the QICTF has therefore been concluded, but it was felt that the group should remain in
existence to deal with related matters (where relevant) and to monitor developments during the required
maintenance phase. More on QICTF
1.11 ETCI Procedures
The Technical Management Committee (TMC) first introduced ETCI's Manual of Procedures in 1997 with the
aim of regularising ETCI's activities and of standardising procedures.
At the time, it was stated that the procedures were live documents and not intended to be dogmatic in their nature.
As such, the Procedures are subject to change as the necessity arises. Based on the procedures' first year of
operation, the TMC introduces this revised manual which includes amendments and additional procedures to the
initial version. More on ETCI Procedures
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 17 of 32
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ETCI response to CER’s Consultation Document – 31st July 2014 – Page 18 of 32
2.0 Scope of ETCI’s Response
The consultation document requests respondents to consider 27 specific themes; the Electro-Technical Council of
Ireland Limited has considered the contents of the CER’s Consultation Document in respect of the Regulation of
Electrical Contractors with respect to Safety from 2016 and has decided to make submissions in respect of the
following:
Ref:
1
2
3
4
5
6
7
8
Document Themes
3.8 Electrical SSB Compliance
4.2 Modifications
5.4 Assessment of Qualified Certifiers
6.2 Individual Registration of REC’s
6.4 Categories of REC’s
9.1 The Certification System
9.2 Electronic Certification Scheme
9.3 Non-Compliances
Table 2.0 – ETCI’s responses to document by section
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 19 of 32
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ETCI response to CER’s Consultation Document – 31st July 2014 – Page 20 of 32
3.8 Electrical SSB Compliance
The CER is inviting comments regarding the introduction of any further measures to ensure Electrical SSBs
compliance with the Terms and Conditions of Appointment and the Criteria Document.
Current Arrangements
The Criteria Document sets out the qualifications required for appointment as an Inspector. These should
include the following:
(i)
Technical qualifications not less than those of an electrician. (e.g. National Craft Certificate
recognised by FETAC or equivalent plus recognised apprenticeship as an electrician);
(ii)
Experience of or responsibility for electrical installation work for not less than three years;
(iii)
Fully conversant with:
-
the Technical Rules;
the Building Regulations;
Health and Safety legislation as appropriate;
the DSO’s “National Code of Practice for Customer Interface”; and,
any such other relevant legislation, standards and documentation as may be specified by the Body
or the CER.
(iv)
Successful completion of a Safe Pass and Manual Handling Courses (and renewals as required);
(v)
Qualified on a recognised “Verification and Certification Course”. This qualification shall have
been awarded in the three (3) years prior to appointment and the Inspector shall be required to
successfully complete this course every three (3) years; and,
(vi)
such other qualifications/accreditations, as the CER may determine, within such timeframe as may
be specified.
Response:
ETCI suggest the following change in wording:
Item (ii) Experience of or responsibility for electrical installation work for not less than five years;
Item (iii) Have a detailed technical working knowledge of:
a. the Technical Rules;
b. the Building Regulations;
c. Health and Safety legislation as appropriate;
d. the DSO’s “National Code of Practice for Customer Interface”; and,
e. any such other relevant legislation, standards and documentation as may be specified by the Body or the CER.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 21 of 32
4.2 Modifications
Current Arrangements
The CER has, in the past, made modifications to the Criteria Document following consultation with stakeholders,
where appropriate, including ETCI, ESB Networks and both of the Electrical SSBs.
The CER proposes that when making changes to the Criteria Document these proposed changes will, in general,
either be circulated for comment to representatives of the ETCI, ESB Networks and any organisations that are
designated as Electrical SSB(s) or published for public consultation. The CER would reserve the right to make a
change to the document without going through these processes if that modification was deemed important from a
safety perspective.
Response:
It is important to maintain the general consensus with all stakeholders when amending the criteria documents. Any
attempt to unilateral change or amend the criteria documents without consultation with the stakeholders is
unacceptable.
When making changes to the Criteria Document the proposed changes or amendments must continue, in general,
either be circulated for comment to representatives of the ETCI, ESB Networks and any organisations that are
designated as Electrical SSB(s) or published for public consultation.
The notion that CER would reserve the right to make a change to the document without going through these
processes if that modification was deemed important from a safety perspective, is unacceptable, consultation with
the stakeholders is of paramount importance. It is ridiculous to suggest that the CER has a monopoly on safety.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 22 of 32
5.4 Assessment of Qualified Certifiers
The CER invites comments from interested parties on whether the scope of assessments should cover the full
scope of controlled electrical works.
Current Arrangements
Each REC must have at least one person to act as a Qualified Certifier. A Qualified Certifier is required to have
successfully completed a recognised course in “Verification, Testing, and Certification” of Electrical
Installations to ‘The National Wiring Rules’ in the previous number of years. If the recognised course that was
completed was accredited the period is 5 years. If the recognised course that was completed was not accredited
this period is 3 years.
Comments are also requested on whether the current Electrical training and verification assessment scope be
increased to include the full scope of controlled electrical works. For example:
1. Should the assessment cover all a set exam on all of the National Wiring rules given that it is
the national standard that RECs must install electrical installations to?
2. Should the assessment cover industrial electrical testing and certification?
3. Should the assessment cover potentially explosive atmospheres electrical testing and
certification?
4. Should the assessment cover earth electrode testing?
Response:
The module descriptor developed by the Dublin Institute of Technology (DIT) in collaboration with ETCI in
respect of the Qualified Certifier in the Inspection, Testing, Verification and Certification of Electrical Installations
in Ireland describes in detail every aspect of the training requirements; these include the following:
1.
2.
3.
4.
5.
6.
7.
8.
Module description
Module Aims
Learning outcomes
Learning and teaching methods
Module assessments
Suggested reading materials
Recommended web-links
Further details of candidate entry requirements
This is a two-day course and provides the academic requirements in part-fulfilment of the Qualified Certifier’s
requirements to meet the conditions laid down in the CER’s criteria documents. The aim of this course is to
provide a means of assuring the competence of Qualified Certifiers and to ensure safety in electrical
installations. This will enable those personnel inspecting, testing, verifying and certifying electrical installations
in Ireland to be certified as being properly qualified to do so. The Safety Supervisory Bodies would then register
applicants according to their particular requirements.
1.
2.
3.
4.
No: this is a Qualified Certifier’s course the assessment is designed to examine the requirements of Part 6
of the National Rules of Electrical Installations ET101. There is no need to expect Qualified Certifier’s to
memorise the entire contents of the National Wiring Rules, each REC including qualifies certifier’s are
obliged to have a current copy of the rules. They can simple consult the rules whenever they wish.
The assessment already caters for domestic, industrial and commercial electrical installations.
There is no difference in the practical aspects of inspection, testing, verification and certification of
electrical installations in potentially explosive atmospheres. There is however a difference in the
documentation, there are additional requirements in respect of the National Wiring Rules. In addition to
the National Rules for Electrical Installations ET101 REC must comply with the National Rules for
Electrical Installations in Potentially Explosive Atmospheres ET105.
No: The details of Earth Electrode Testing can be accessed in Annex 61D of the National Rules for
Electrical Installations ET 101 – Measure of Earth Electrode Resistance (TT Systems) this is a normative
annex.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 23 of 32
DIT are an independent academic institution with the capacity to make decisions with respect to changes in their
module descriptor, they will carry-out course monitoring and will amend the content of their module descriptor is
the light of current and new developments.
Should the need arise DIT will include items such as the measurement of “Earth Electrode Resistance” if
feedback from students on the qualified certifier’s course or the course programme committee recommend it.
5.4.2 Proposed Future Arrangement

Assessments
The CER invites comments from interested parties on whether the scope of assessments should cover
the full scope of controlled electrical works
Response:
We agree that it is worthwhile to review assessment. If the concept of membership Categories goes ahead, we
recommend that HV be added, and suggest that the Qualified Certifier must have the testing and verification and
qualification plus those relevant to the Membership category of his/her REC. Some sectors such as ATEX and
HV are quite specialist. It is possible for a REC to be perfectly competent in e.g. LV and not in ATEX. HV Rules
are about to be published and it is established practice that a minority of contractors operate in this
field. Provision for future testing against the HV Rules should be made but should not, in our view, be a
requirement unless a REC wishes to certify in that area. Presumably this is the logic behind the concept of
membership category.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 24 of 32
6.2 Individual Registration of REC’s
Please comment on whether there should be a move to individual registration for electrical contractors.
Please consider the points below in your response:
(a) Should the current system be retained or should there be a move to some form of individual
registration?
(b) Should individuals who are currently employed by RECs without a trade certificate get
some form of electrical labourer status? Should apprentices have their own status? Should
each electrical industry participant’s card identify their respective status?
(c) Should each individual be required to carry out the accredited T, V & C course (or some
other course)? If so, how will this be funded – is the individual responsible or should the
company who employs the individual be responsible (there would be no change in the case of
a self-employed electrical contractor)?
(d) In the scenario where each individual is required to carry out the accredited T, V & C course
(or some other course), is the additional cost that will need to be passed on to the customer
acceptable?
Response:
Comment: No – there is no need to change the current system, if individual registration is contemplated this will
add to the financial burden which is already too heavy and may result in reduction in employment. We
see a benefit in the legal entity i.e. the REC being registered. In the case of e.g. an issue with a major
project, there would otherwise be the potential for unclear responsibility between individuals.
6.2 (a) the current system should be retained.
6.2 (b) the only persons engaged in electrical work should be competent to carry out this work see Safety, Health
and Welfare at Work Act 2005.
(2)(a) For the purposes of the relevant statutory provisions, a person is deemed to be a competent
person where, having regard to the task he or she is required to perform and taking account of the
size or hazards (or both of them) of the undertaking or establishment in which he or she
undertakes work, the person possesses sufficient training, experience and knowledge a ppropriate
to the nature of the work to be undertaken. (See page 14 of the SHWW Act 2005).
In order to be competent the person must possess:
1.
2.
3.
Sufficient training
Experience
Knowledge appropriate to the nature of the work undertaken
There should not be any form of electrical labourer status.
Electrician apprentices already have a legal status, see the following:
 Industrial Training Act 1967
 Labour Services Act 1987
 Apprenticeship Rules 1997 – S. I. No. 168 of 1997 (which came into effect 1 st May 1997).
Any attempt to change the status of any of the 26 designated trades which includes electricians will require a
change in legislation and agreement with the social partnership and other government agencies such as the
Department of Education and Science, Solas (formally Fás) and the electrical trades unions.
6.2 (c) the present position is adequate in respect of testing, verification and certification of electrical installations,
only qualified certifier’s should carry out this work.
6.2 (d) the answer to this question is yes, ultimately it is the consumer that benefits from accredited training
courses, training is expensive, this cost must be passed on to the customer.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 25 of 32
6.4 Categories of REC’s
Comments are requested on whether there should be more categories of RECs.
Current arrangements
There is currently only one category of REC for which applications can be made to register with the Electrical
SSBs.
Response:
Response:
The Criteria Document already prescribes the following categories of registration:
1) Registered Electrical Contractor
2) Registered Associated Contractor
3) Registered specialist contractor
To require more categories of RECs will only serve to complicate the sector by sub-dividing it into multiple
sectors; with the additional financial burden that any associated mandatory (accreted) training (to become RECs in
such sectors) will bring. Training should always be both advocated and supported (something ETCI has developed
over the years), but not in such a rigid and mandatory fashion.
The current position should be retained; there is no need to extend the current categories. The training of
electricians is more than adequate for the existing categories of REC’s
The electrical training which is provided by a combination of Solas (formally Fás) and the Institutes of
Technology under the auspices of the Department of Education and Science and FETAC and approved by QQI in
which each of the seven modules of training are appropriately assessed at every stage culminating in the award of
the Advanced Craft Certificate.
The current system offered by the Institutes of Technology and in particular by the Dublin Institute of Technology
(DIT); which provides for lifelong learning for its former apprentices and electricians offers development
opportunities in a wide range of courses from Certificate in Electrical Services Engineering to Doctorate level.
Potential fire and explosion hazards in respect of a lack of competence
Concern has been expressed at recent ETCI TC 6 committee meetings regarding potential problems associated
with a lack of competence among REC’s in respect of electrical installations in hazardous areas potentially
explosive atmospheres.
Disquiet also exists within that the Safety Supervisory Bodies (SSB’s) are not well positioned to oversee the
safety of REC’s work in electrical installations in hazardous areas and potentially explosive atmospheres.
Unsafe wiring and unsafe practices in hazardous areas and potentially explosive atmosphere may have
consequences leading to the deaths of hundreds of people and massive destruction of homes and properties in
areas adjacent to plants producing products containing gases, dusts, hazardous materials and various fertilizers etc.
See web-link to a fire and explosion published on 18th April 2013.
http://edition.cnn.com/2013/04/18/us/texas-explosion/
6.4.2 Proposed future arrangements
We would add HV to the list after 6 and before 7 on the Commission’s proposed list in 6.4.2. We note that HV
installations are currently controlled works even in advance of the publication of the Rules so there is a logic to a
category. If the Commission chooses not to activate this category, it should be included as a dormant category
until arrangements are fully in place.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 26 of 32
Controlled works which must be certified by REC’s are defined as;
1. the installation, commissioning, inspection, and testing of a new fixed electrical installation requiring
connection or re-connection to the electricity network;
2. the installation or replacement of a Distribution Board or Consumer Unit, or new electrical installation in
special locations as defined in Part 7 of the National Wiring Rules ET 101 and ET 1O5;
3. the installation or the replacement of one or more extra circuits in an existing installation, including the
installation of one or more additional protective devices for such circuits on a distribution board;
4. Subsystems installed in Commercial, Industrial, and Domestic installations where the electrical installation falls
within the remit of the National Wiring Rules;
5. the inspection, testing and certification of existing electrical installations (in accordance with Chapter 62 of the
Wiring Rules (ET 101-Fourth Edition- 2008 and to conform to Regulation 89 of the SHWW (General
Application), Regulations S. I. 299 of 2007 and as amended by S. I. No 732 of 2007).
Points 2 and 4 in particular above explicitly set out that explosive atmospheres and industrial installations are very
much part of the controlled-works regime.
It is therefore vital that the Safety Supervisory Bodies (SSB’s) have, within their ranks, the requisite competence
to audit the safety of any work carried out by their REC’s in a hazardous area or a potentially explosive
atmosphere.
Consultation between HSA, CER, ETCI, the electrical SSB’s ESBN and other industry stakeholders should also
be considered to ensure that any REC’s who does not have adequate competence to carry-out work on an electrical
installation in a hazardous area or a potentially explosive atmosphere is excluded from doing so, without adequate
training, additional technical knowledge and where necessary adequate supervision to ensure the safety of any
work done, which might give rise to an ignition hazard.
The ETCI is willing to engage positively with CER and other stakeholders to explore avenues where any
deficiencies that exist in the regulatory regime and the registered contractors could be addressed.
Currently, electrical installations in hazardous areas and potentially explosive atmospheres are designated as
controlled works. These should be re-designated as restricted works, i.e. work within areas defined as being in a
hazardous area and in potentially explosive atmospheres should be restricted to persons who are competent or to
those under the direct supervision of a competent person. This should involve RECs obtaining additional approval
from their respective SSB’s. Such approval should be underpinned through a demonstration of competence (or
meeting competence criteria), before such RECs are permitted to carry out work, or supervise electrical work, in
Potentially Explosive Atmospheres.
REC’s working in hazardous areas and in potentially explosive atmospheres are required to observe the statutory
requirements contained in the Safety, Health and Welfare at Work (General Applications), Regulations S. I. 299
part 3 and part 8 and schedule 10 see web-link below for information:
http://www.hsa.ie/eng/Legislation/Acts/Safety_Health_and_Welfare_at_Work/General_Application_Regulations_2007/General_Application_
Regulations_2007_SI_2007_Unofficial_Copy.pdf
In addition REC’s are required to comply with the Wiring Rules. In addition to the National Rules for Electrical
Installations ET101 REC must comply with the National Rules for Electrical Installations in Potentially Explosive
Atmospheres ET105.
See web-link below for information:
http://www.etci.ie/explosiveatmospheres/index.html
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 27 of 32
9.1 The Certification System
Should the CER continue to use ETCI certification (for electronic and/or paper based certificates) or should a
process be implemented whereby the Electrical SSB(s) would provide the certificates without sourcing them from
a third party? Respondents should be conscious that the latter approach could impact on the ETCI’s ability to
continue to work in the area of the National Wiring Rules.
Response:
The CER must continue to use the ETCI certification both for electronic and paper based certificates, the status
quo should prevail in this instance.
Current Arrangements – Under the current arrangement the Electrical SSB’s purchase certificates from the ETCI
and sell these on to REC’s, who are required to issue these certificates to customers, this arrangement should be
continued.
Objectives of the ETCI
1.
2.
3.
4.
To promote and co-ordinate standardisation in all branches of electro-technology in harmony with
international agreements and in collaboration with the National Standards Authority of Ireland (NSAI).
To establish liaison with similar bodies in other countries and with international bodies.
To promote safety in electrical equipment and installations and to encourage an awareness of electrical
safety among the general public
To advise and make recommendations on any matter pertaining to electro-technology, subject to the
statutory powers, duties and functions of other bodies.
In realising the first two closely related objectives, ETCI:



Contributes to the development of international standards through the participation of members of its
Technical Committees with their counterparts from EU and other countries, in the deliberations of the
relevant IEC and CENELEC technical bodies to which standard-making is assigned.
Refers the resulting agreed texts to NSAI for publication as Irish Standards.
Participates in the formulation by CENELEC and its constituent bodies of international schemes of
certification and mutual recognition of the quality and safety characteristics of electro-technical products.
The third objective is achieved through:



The preparation and publication of National Rules for Electrical Installations and of guides to their
effective implementation in practice.
Publishing brochures, in collaboration with ESB, on precautions for the safe use of electrical equipment
and appliances, for the benefit of the general public and of particular communities within it, such as those
engaged in agriculture.
In pursuance of its joint objectives, ETCI provides a reference and advice facility whereby copies of its
publications are made available and specific enquiries on their interpretation are processed.
Certification activities are provided for by three technical committees:
TC 2 has responsibility for the National Rules for Electrical Installations – ET101
TC 6 has responsibility for the National Rules for Electrical Installations in Potentially Explosive Atmospheres –
ET105
TC 3 has responsibility for the National Rules for Electrical Installations for Power Installations exceeding
1 kV a.c. (1.5 kV d.c.) – ET103, this is a new publication which has completed the public consultation process and
is scheduled for publication shortly.
ETCI has 19 technical committees and several task forces all feeding their expertise into the many ETCI
publications, which has contributed to the electrical health and safety of the nation at no cost what-so-ever to the
exchequer.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 28 of 32
The income generated by the sale of certificates on average represents approximately 23% of the cost of
certificates to REC’s. The cost of certificates to the REC’s on average represents a 73% mark-up which goes to
the SSB’s when completion certificates are sold-on to REC’s. There is a substantial cost to the SSB’s in
maintaining the registration system and this cost will be still in place even if CER changes the existing
arrangements, it is difficult to comprehend how the cost of the certification process would result in a reduction in
costs to the REC’s given the costs involved in the registration process.
ETCI have not increased their proportion of the cost of completion certificates since 1st January 2011.
If CER discontinue the current arrangements in respect of ETCI certification the loss of income from certificate
sales may result in the collapse of ETCI activities with the consequential loss of four decades free and impartial
advice to the electro-technical community in Ireland.
The consequential loss of income from sales of completion certificates may have the unintended results of making
ETCI financially unviable and may lead to the unravelling of the “so-carefully nurtured safety system” that exists
in Ireland.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 29 of 32
9.2 Electronic Certification Scheme
The CER is minded to have an electronic certification scheme in the future. A number of questions are posed in
relation to this below on which the CER is seeking views on:
Please comment on the completion certificate system addressing the points below.
(a) Should any electronic system cover certificates for all controlled works and minor works?
(b) Should any electronic system be mandatory for all RECs to use (with no paper based system)? Alternatively
should it be incentivised to get RECs to move to the electronic system but not make it mandatory for all
RECs?
(c) Should it be mandatory or incentivised to get RECs to move to an electronic system over a phased basis?
(d) Should all Electrical SSBs be required to offer and promote the electronic system?
Response:
The proposal to develop an enhanced electronic certification system would have a number of benefits to the
electrical industry as outlined by the CER such as:
1.
2.
3.
4.
5.
6.
Facilitate compliance
Facilitate recording, issuing and control of certificates
Improve efficiency
Reduce costs
Improve traceability
Validating and recording data to assist with research in the quest for improved fire prevention and
improved electrical safety.
ETCI are of the view that any system that makes it easier for REC’s to comply with their obligations in respect
of certification is welcomed.
9.2 (a) all controlled works and minor works should be covered by electronic and paper formats. An electronic
completion certificate in the form of a Non-DSO Completion Certificate for compliance with ET101 for Minor
Electrical Works and the installation of Smart Metering Installations which can be printed-off by the REC’s is
required.
9.2 (b) as it is the intention of CER going forward to have an electronic completion certificate system; ETCI’s
view is that an electronic certification system should be developed to cater for electronic certification only,
however this system should not be mandatory. An electronic system that has the facility of printing-off paper
copies can be easily adapted by REC’s. ETCI are of the view that CER should encourage REC’s to use
completion certificates (with the appropriate test record sheets) as a means of self-protection in the event of an
electrical accident or a fire. Adequate record keeping in the form of completion certification can be crucial for
the REC’s in the event of a fire or shock hazard due to the failure of protective devices. Testing, verification
and certification of electrical installations and adequate records are in the interest of the REC’s as well as the
customer. In the event of a fire or in the event of shock hazard the adequacy of test results by means of
completion certificates and the associated test record sheets can eliminate electricity as an ignition source and
thus eliminate electricity as the cause of the fire, provide legal protection for the REC’s, and permit the
investigation of the fire to examine other potential ignition sources as possible causes
9.2 (c) It may be possible to introduce the ‘mandatory’ requirement for all new RECs, and the ‘incentives’ be as
described in (b) above.
9.2 (d) YES, all RECs should have the electronic system available to them regardless of which SSB provides
their REC membership.
We would strongly advocate that the HV certificates, once approved, are built-into to the electronic system and
flexibility for future certificates provided for.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 30 of 32
9.3 Non-Compliances
Comments are requested regarding how issues relating to:



non-completion of post connection tests; and,
the non-issuance of certificates in cases where customers do not request the certificate should be
addressed.
What obligations, incentives or controls should be put in place to ensure certificates are issued to
customers and all certificates issued are returned to the relevant Electrical SSB?
Response:
The completion certificate is integral to the success of the regulatory scheme It provides a link from the REC
to the customer and assurance to the customer that they electrical work has been carried out in line with the
appropriate standards.

The non-completion of post connection tests makes the certificate null and void, in the event of an
electrical accident or a fire the customer will have an incomplete certificate and will need to revert to the
courts for compensation or some form of redress. This situation is totally unacceptable. The onus must
be placed on the REC and on the respective electrical SSB to ensure that their REC’s have fully
documented the completion certificate and that the respective test record sheets in respect of the perconnection tests and post-connection tests are accurately recorded in an appropriate manner.

The non-issuance of certificates in cases where customers do not require the certificate certainly needs to
be addressed. A possible solution to this problem is to remove the option of whether the customer
requests the certificate or not. CER should consider changing the requirements to ensure that all electrical
work is properly certified. CER should consider the possibility of a publicity campaign on Radio and TV
to highlight the need for completion certificates and to highlight how the certificates provides a link from
the REC to the customer and assurance to the customer that t h e electrical work has been carried
out in line with the appropriate standards.

Qualified Certifier’s are responsible for inspection, testing verification and certification electrical
installations, in accordance of Part 6 of the National Rules for Electrical Installations – ET101. Their
certifier’s number appears on all completion certificates. The onus must be placed on the REC and on
the respective electrical SSB to ensure that certificates are issued to customers and all certificates
issued are returned to the relevant electrical SSB. CER should carry-out random spot checks to ensure
that completion certificates and the relevant test record sheets are fully compliant; in the event of noncompliance an investigation fee may be levied on the offending REC and on their respective electrical
SSB.
ETCI response to CER’s Consultation Document – 31st July 2014 – Page 31 of 32
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ETCI response to CER’s Consultation Document – 31st July 2014 – Page 32 of 32