Towel Rail Replacement and Electrical Notifiable Work


Postby to88 » Mon Aug 15, 2016 3:58 pm

So my towel rail heater is bust and I don't like the look of the current rail itself. I want to replace it. The connection to the wall is well outside the notifiable special location as is where it connects to the rail. Over 1 meter from the tub.

However, the far side of the rail from the connection sits inside 0.6m of the tub. About 30cm off.

Am I technically doing notifiable work? (I'm not interested if I can get away with it, I want to know where I stand by the book). As far as I can see the "addition or alteration" to the circuit is outside the zone, is this correct?

If it is notifiable can someone point me to any legislation that can clarify this (if it exists)?

Currently looking at page 14 of this amongst other things:
http://webarchive.nationalarchives.gov. ... p_2013.pdf

Thanks
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Postby kbrownie » Mon Aug 15, 2016 6:51 pm

So you are replacing an existing appliance in the same location? If so the regulation allow you to do this, without requiring an application for notification. But you must still comply to Part P of the building regulations, which will require you to make sure/proof the work is performed safely and is safe to put into service.
If this was a new appliance with new electrical parts of circuit (rather than a replacement), then as the appliance is within zone 2, you would then be required to notify the work, although a grey area could be argued that the connections are outside the zones.
There would also be a requirement for RCD protection, for any circuit entering a bathroom
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Postby to88 » Mon Aug 15, 2016 9:46 pm

Thanks for the response. Yup. It would be a new rail with a new heating element but with connection outside zone 2. As far as I can find too it does look like a grey area.

RCD wise luckily the original installer preemted the 17th edition and put it alongside the ring sockets on an RCD.
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Postby kbrownie » Tue Aug 16, 2016 8:15 am

I would in your situation, considering the electrical installation is not being altered and a rail was already existing. So just a replacement, therefore notification is not required.
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Postby ericmark » Tue Aug 16, 2016 11:43 am

The rules do change between England and Wales, but as said it is normally considered like for like replacement is permitted without notification.

The Part P rules can be argued about until the cows come home, they do not use the BS7671 definitions, and do not publish a set of definitions of their own so if you really want you can argue about near every point made.

However the idea with Part P, EAWA, and BS7671 is to make it safe. And to ensure things are safe we inspect and test. So in general if it needs an installation certificate then it needs registering, if a minor works is enough then in England it does not require registering unless within a set distance from the shower head, bath etc.

But the whole idea of completing the minor works, is to prompt the electrician to test those areas which will ensure the installation is safe. For the owner occupier DIY is not really a problem. It is very unlikely that anyone will take him to court because he has made a genuine error. Courts etc. normally take the attitude that if your error has injured or killed a family member that is enough, without the court doing anything as well.

However where the injured party is not within the family group then a very different attitude is taken. When you read reports of court cases you often feel the person found guilty was not really responsible for the accident. There is no qualification required to be an electrician, only the ability to do the work safely. When it goes wrong, then hard to show some one had the ability, or it would not have gone wrong.

Scotland is the odd one out, you have to show training in Scotland before you can test and inspect, but in real terms unless you have some bits of paper to show you have the ability to do the work, then for rented accommodation don't touch the electrics as courts seem to love blaming landlords.
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Postby to88 » Tue Aug 16, 2016 5:25 pm

Thanks ericmark.

(England btw)

Its such a shame so much effort goes into regulations alongside standards yet it leaves itself wide open to subjective discussion. Even the way Part P is written. 3.13. uses the words "should be ... in accordance with BS7671". That just implies obligation. Be explicit, use words like must and must not!

I don't encourage anyone else to do so, but I'll switch it round and do what tests I can to satisfy its safe for me and anyone I'm responsible for in the short term. Long term, for future owners/tenants, I'd certainly get a full survey done down the line.

I'll do a MEIWC as it satisfies the replacement of equipment although I'd be short some answers on Part 3 for impedence and RCD disconnection times as I don't have the equipment.

I'm not the gun hoe type so by all means anyone step in and slap my wrist if you think this is a wrong move. With the weather as it is a warm snuggly towel is not my immediate priority.
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Postby ericmark » Tue Aug 16, 2016 10:30 pm

This may now change, but law wise one could wire a house in UK to German standards and Part P would have to allow the LABC to pass the house.

However as far as BS7671:2008 goes the house would fail because it has sockets where the line and neutral are not fixed i.e. you can plug in either way around.

Will be interested to see what happens as we leave the EU. Clearly we are leaving because we don't like the EU rules so we can't really make all the EU rules into British rules, each one will need to be taken on it's own merits.

In the future Part P may stipulate following BS7671:2008 but I don't think so, as the regulations (BS7671) are designed to guide us rather than being a fixed method. There have been errors, when RCD's came in they forgot to say for low voltage only. With separated extra low voltage a RCD can't work, the supply is separated. Same applies for shaver sockets, there is no RCD protection on a shaver socket outlet. It will be corrected, but if BS7671 was law it would be a problem when any errors are made.

A consumer unit is a type tested distribution unit, if you don't use the recommended items inside a consumer unit it loses it's type testing so is no longer a consumer unit. I am sure Part P writers intend any distribution unit to require a compliance or completion notice, but that is not what it says. Same with a circuit, a circuit is the wiring protected by an over current device, so fitting a FCU then a few sockets forms a new circuit. However it seems as far as Part P goes that is not considered as a new circuit.

What Part P does is make it easy to take the cow boys to court, but for the owner occupier it means nothing, all I need to say is I designed it before 2004 and it does not need registering. How daft is that?
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