BRE
Final report on the level of
checking of electrical
installations to BS7671
Date: November 2014
A9721553
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:
Fax:
e-mail:
web:
standards
01506 600 400
01506 600 401
buildingstandards@scotland.gsi.gov.uk
www.scotland.gov.uk/Topics/Built-Environment/Building/Building-
© 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.
2
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 3
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
4
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.
5
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.
6

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.
7
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
8

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.
9
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
10
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
11
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 NonDomestic)
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.
12
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.
13
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 autodisconnection 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.
14
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
15
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:
16
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
17
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.
18
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
19
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.
20
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 (pre1995) 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.
21
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
4.1.1
Use of guidance documents
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)
22

Building Standards Technical Handbooks.
What guidance do you use when undertaking reasonable
inquiry on non-certified Electrical Installations to BS7671?
60%
50%
40%
30%
20%
Always Use
10%
Use Often
Other
Building Standards
Technical Handbook
On‐site Handbook
BS 7671
SBSA/SABSM 2006
Guidance for Verifiers
0%
Use Occasionally
Do Not Use
Figure 4.1: What guidance do you use when undertaking reasonable inquiry on non-certified Electrical
Installations to BS7671 (Question 2)
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.
23
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
4.2.1
Most common means of reasonable inquiry
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.
24
Where electrical installations are not certified by an Approved Certifier,
what is the most common means of conducting reasonable inquiry?
Inspection by Building Standards Surveyor
0%
Arrange for an independent inspection and test to be carried out by a competent external consultant
0%
Another route is taken
8%
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 employee of the Local Authority (not a Building Standards Surveyor)
0%
Acceptance of completion certificate and no further action
0%
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)
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:
25

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.
What other means of conducting reasonable
inquiry are used within your Local Authority?
60.0%
50.0%
40.0%
30.0%
20.0%
10.0%
0.0%
Arrange for an
Arrange for an
Inspection by
independent
independent
Building Standards
inspection and test inspection and test
Surveyor
to be carried out by to be carried out by
a competent
a competent
external consultant employee of the
Local Authority (not
a Building Standards
Surveyor)
Acceptance of
completion
certificate and no
further action
Another route is
taken
Figure 4.3: What other means of reasonable inquiry are used within the Local Authority? (Question 6)
26
4.3
4.3.1
Competence of the electrical installer
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.
What level of qualification, skills and experience would
you accept for electrical installers?
100%
90%
80%
70%
60%
50%
95.2%
81.0%
40%
30%
57.1%
20%
57.1%
33.3%
10%
SJIB Graded
Completed
'Requirements
for Electrical
Installations to
BS7671: Wiring
Regulations'
Course
Qualified
Electrician
(SVQ/NVQ Level
3)
Member of
appropriate
trade association
Approved
Certifier
(SELECT/NICEIC)
0%
Figure 4.4: What level of qualifications, skills and experience would you accept for electrical
installers? (Question 8)
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.
27
When a project has a specialist element, or
if highly complex, is the same approach
used?
No
14%
Yes
86%
Figure 4.5: For specialist elements, is the same
approach used? (Question 9)
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
4.5.1
Issues and rejections of completion certificates
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.
28
Other reasons included fraudulent or incorrect information included in BS7671
certificates and situations where work was clearly incomplete despite a certificate being
issued.
Have you ever had to reject a
completion certificate for electrical
installation related reasons?
Yes
39%
No
61%
Figure 4.6: Have you ever had to reject a
completion certificate? (Question 23)
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.
29
Has there ever been cause to raise comment
on the certificate or the installation with the
applicant or Certifier?
Yes
43%
No
57%
Figure 4.7: Has there ever been cause to raise comment on
the certificate? (Question 24)
4.6
4.6.1
Estimation of processed completion certificates
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.
30
May 2010 - April 2011
3500
3000
Number of completion certificates processed
which included electrical installation work?
2500
2000
Number of these completion certificates which
were submitted WITH A CERTIFICATE OF
CONSTRUCTION for the electrical installation?
1500
Number of these completion certificates which
were non‐certified, i.e. they were submitted
WITHOUT A CERTIFICATE OF CONSTRUCTION?
1000
500
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
May 2011 - April 2012
3500
3000
Number of completion certificates processed
which included electrical installation work?
2500
2000
Number of these completion certificates which
were submitted WITH A CERTIFICATE OF
CONSTRUCTION for the electrical installation?
1500
Number of these completion certificates which
were non‐certified, i.e. they were submitted
WITHOUT A CERTIFICATE OF CONSTRUCTION?
1000
500
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
May 2012 - April 2013
3500
3000
Number of completion certificates processed
which included electrical installation work?
2500
2000
Number of these completion certificates which
were submitted WITH A CERTIFICATE OF
CONSTRUCTION for the electrical installation?
1500
Number of these completion certificates which
were non‐certified, i.e. they were submitted
WITHOUT A CERTIFICATE OF CONSTRUCTION?
1000
500
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Figure 4.8: Number of Certificates (Question 25, 26, 27)
31
4.7
4.7.1
Additional comments
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.”
32
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.
33
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 – multidisciplinary 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.
34
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
35
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.
36
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.
37
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.
38
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 noone 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.
39
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.
40
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.
41
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
42
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.
43
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 nonelectrician (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.
44
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)
Category
Description and comments
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.
Table 5.4: Project Review (Verifier 2) 45
Category
Description and comments
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.
Table 5.5: Project Review (Verifier 3) 46
Category
Description and comments
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
47
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.
Table 5.6: Project Review (Verifier 4)
Category
Description and comments
Types of projects
Nine projects were reviewed. These covered a mix of domestic and nondomestic 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 nondomestic 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
No other parties were involved.
Table 5.7: Project Review (Verifier 5) Category
Description and comments
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;
48
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.
Table 5.8: Project Review (Verifier 6)
49
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.
50
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 nonconformities were found. They have a quality assurance manager who is subcontracted. 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.
51
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.
52
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.
53
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. Inhouse 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.
54
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.
55
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.
56
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.
57
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.
58
Category
Description and comments
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)
59
Category
Description and comments
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.
Table 5.10: Project Review (Certifier 2)
60
Category
Description and comments
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.
Table 5.11: Project Review (Certifier 3) 61
Category
Description and comments
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
No other parties were involved.
Table 5.12: Project Review (Certifier 4) 62
Category
Description and comments
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.
Table 5.13: Project Review (Certifier 5) 63
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.
64
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).
65
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
6.2.1
Robustness of the non-certified approach
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
66
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
67
‘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.
68
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
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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
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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.
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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
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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.
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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 rewiring) 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.
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
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.
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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/)
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19. Electrician Job Profile (Website)
(https://nationalcareersservice.direct.gov.uk/advice/planning/jobprofiles/Pages/Elect
rician.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?
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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?
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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?
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