Communities and Local Government CommitteeWritten evidence from Richard Hall

Executive Summary

Electrical installation work is easy to make “work”, and even easier to do wrong, but there maybe a long delay before the problems become apparent.

The Part P self certification scheme has willed the ends but not the means to prevent incompetent electrical work inside private dwellings.

Public ignorance of the implications of Part P remains huge.

The existing arrangements put competent and conscientious trades people at a competitive disadvantage, and is therefore having the opposite result to that intended.

Public policy makers need to choose between an effective system of regulation and a more laissez faire approach.

Introduction

As someone who has only been working as an electrician for six years I have no experience of how domestic electrical work was policed before “Part P” was introduced. However, I can say that when I did my training course it was common currency that the new system was only being introduced because “an MP’s daughter was electrocuted” (this was Jenny Tonge’s daughter).

I decided to make this submission because I sincerely believe, for the reasons I discuss below that what was undoubtedly a well meaning attempt to improve standards is not only failing to achieve this laudable aim but actually causing more and more domestic electrical work to be done without proper regard to BS7671.

A short technical note about electrical circuits and the implications for those trying to earn a living as an electrician

Unlike most modern technology an electrical circuit is;

(a)extremely easy to install with very little skill or technical know how so that it works, in the sense that it will supply an electric current to electrical apparatus;

(b)can continue to operate to the apparent satisfaction of the end user installed incorrectly for an extended period. This is particularly true of the bizarre arrangement, unique to Britain (I believe), known as a ring final circuit—the most common arrangement for the installation of standard square three pin 13 amp socket outlets in the United Kingdom; and

(c)consumers have an extremely optimistic view of the safe lifespan of an electrical installation, and little understanding that wiring just like an electrical appliance wears out, degrades or from time to time is superseded by new equipment. Most people do not consider the wires hidden in their walls but focus on the aesthetic properties of the visual aspects of the system or light fittings and the convenience of the locations and quantity of sockets. No one ever had their friends round to show them their new consumer unit.

But the more technical part of the job is:

(a)to be able to understand in general terms the practical implications of BS 7671 (the Wiring Regulations -a volume of 464 close typed A3 pages in its latest version) for a particular project. Correctly applied these regulations will ensure that the correct cable and associated equipment are installed for a particular application; and

(b)to be able to conduct tests using specialist instruments, and understand and interpret the results of those tests, that can confirm the safety and long term integrity of an electrical circuit before mains voltage electricity is passed through it.

But in practice lack of this knowledge or wilful disregard of it will not prevent incorrectly installed circuits and equipment Working. For example, an electrical circuit wired in the wrong cross sectional area (size) of cable may operate for years before it finally fails, or, more likely, finally causes a fire from over heating or arcing (sparks jumping across incorrectly wired cables and fittings). Similarly a circuit may work satisfactorily for years with no connection to electrical earth, until a fault occurs and someone receives an electric shock, because there was no way for the voltage to pass safely back to earth.

This creates a dilemma for those who are trying to earn a living doing the work properly, which obviously takes longer and costs more. This has probably always been the case but the inept system of regulation known as Part P self certification has simply entrenched the situation.

Problems with the current Part P regulation

General building control relies on enforcement when it is obvious that a building’s structure or use has been changed without permission. As the great majority of electrical work is internal, and therefore hidden, there is no effective means of detection of such changes and hence of enforcement.

To comply with “Part P” those electricians who wish to trade legally but avoid the necessity to pay for a local authority building control officer to certify their work (and become hopelessly uneconomic as a result) must join one of a number of organisations licenced to administer the Part P regulation scheme so that they can certify their own work as compliant with BS7671. But because of the enforcement problem (see above) there is no effective sanction if they do not -only the theoretical sanction of prosecution if their work causes harm to people or damage to property.

Joining a Part P scheme imposes a significant financial disadvantage. Scheme membership typically costs around £400 per electrician per year. In addition each job notified as compliant will attract an additional charge, and each operative within a business that is in charge of issuing the official certificates for a job must have an annual inspection. This typically takes half a day, when one cannot earn money. It involves asking the favour of a particular client to re-visit work done. (And as an aside as the operative selects the job to be inspected a reasonable person might also query the effectiveness of such an inspection, as only a fool would choose a job where they knew problems would be revealed).

Another inherent weakness of the inspection regime is that those being inspected are those paying the bills. For the several organisations (unlike the single one for gas) this creates an invidious position. They inevitably compete with one another for paying members. If these competing inspection organisations set their standards too high trades people will simply switch organisation. It is common currency amongst practitioners that the largest of the “Part P” organisations is the largest for the simple reason. It has the lowest standards.

For the individual trader there also exists a considerable dilemma. As discussed above diy (or poor quality paid for) refurbishment work that goes on inside a property is effectively unenforceable. As discussed above this is a particular problem for electricians.

But because it is easy for the unregulated operative, doing work that neither he nor the customer will report to the local authority to install equipment that works—albeit dangerously—the bona fide trader is under cut by the cow boy, who does not have to pay for the overhead of joining a scheme. In practice such a practitioner is most unlikely to be prosecuted until the worst happens—and someone is hurt or worse as a result of their work.

By the time the problem occurs the most likely scenario is that the householder will have no records, or not even be the owner that commissioned the work that caused the problem. I routinely ask customers if I can see the certification, and building control notification for work that has clearly been done since the Part P scheme began. It is unusual for customer to have such documentation. (I wonder if members of the committee have such paperwork for their own properties, or know when their electrical installation is next due for inspection?)

In economics as the committee are no doubt are well aware the aphorism is that “bad money drives out good” but in the case of electrical work it would be fair to adapt it to say that bad installations are driving out good ones—by charging less and cutting corners with safety. The Part P organisations will only intervene to help a consumer where it can be demonstrated that one of their members is at fault. But the majority of problems are caused either by trades people who never joined a scheme at all or did a “cash” job without issuing the proper paperwork.

Another commercial problem for those trying to work within the rules is the level of public ignorance. Even years after its introduction the great majority of the general public have only the haziest notion of what “Part P” is and what this means for their relationship with a trade that, by its very nature, most of us will only need a handful of times in our adult lives. Indeed, CORGI the now defunct Gas installation inspector has far higher true recognition than any of the electrical associations managing Part P self certification schemes.

On my website http://www.redkiteelectrical.co.uk I try to explain the value that Part P electrical work brings to the commissioner of electrical works, and to explain why more modern electrical devices like consumer units are a major improvement in safety when compared with the old fuse board. This message is not getting through.

A routine part of my working life is explaining to customers with an old style rewireable fuseboard that I am not allowed to add a new socket, or change the light circuit until I have modernised the disconnection apparatus, or installed a missing main equi-potential bond cable. I am often greeted with a response along the lines of “but we’ve never had any problems with it”, which is a euphemism for the thought that the customer does not know what I am talking about, and suspects I am trying to add unnecessary costs to the bill. All too often in these circumstances I hear nothing more from the potential customer. One can only speculate how much work then gets done without regard to Part P rules.

In conclusion I believe the Part P regulation system is not helping domestic electrical safety. Its rules are only observed by those competent professionals who would have done the work correctly anyway without the system being in place. Because those of us that are trying to play by the rules are being commercially undermined by those that are not more and more work is won by those who do not know how design and test a safe installation, or do not care, and will most probably be untraceable by the time their hazardous wiring causes a problem.

Recommendations

Overall public policy makers need to be clearer about what they are trying to achieve. Specifically:

1.If the aim is to drive out the hazard of bad workmanship from the electrical trade by regulatory action then prosecutions must be brought against unregulated traders for trading outside of the “Part P” system, not only in the event that they actually do some harm and can be found. Quite simply if one takes money to perform electrical work in someone else’s home without being in a Part P scheme you are guilty of an offence.

2.Those entering the profession should be required to demonstrate literacy and numeracy skills sufficient to understand the wiring regulations, complete and calculate test documents and communicate the results to their customers effectively.

3.As part of this tighter regulatory regime DIY “sheds” should no longer be able to sell equipment such as consumer units to general public the installation of which must, by definition, be part of job notifiable under Part P rules. An amateur or unqualified person can’t buy most gas fittings so why can they buy a consumer unit or other electrical item which must necessarily form part of a notifiable job?

4.If a tighter regime of consumer protection is desired, then some onus should be placed on the householder to provide up to date documentation on the routine inspection of their installation and its safety at the time of a house sale, coupled to a public education campaign.

5.If tighter regulation is the aim the system cannot be administered by competitive commercial organisations.

6.Similarly it cannot work effectively if those that are being regulated are paying for the service, and simply go elsewhere if they are not happy with the result of their inspection.

7.I do not believe that altering the list of work that is notifiable will address the problems of the current regulatory system. It will merely serve to confuse the consumer still further and create new opportunities for unscrupulous installers who are not part of any organisation for Part P self certification.

8.Conversely decision makers may take the view that in an imperfect world the best role of the public authorities is to publish simple clear advice to the general public on selecting a competent tradesman and leave citizens to make their own decisions about who, and on what terms, they engage an electrician.

9.The status quo is undermining not assisting electrical safety in British homes.

February 2012