Taking the posts in order.
BTW, I’ve not had time to proof read this so there may well be spelling, grammar and minor errors! Apologies in advance. I need to do some other, paying, work tonight!
OK, first Neil,
A few clarifications of terms.
A Degree in Electrical Engineering, does not an Electrician or Electrical Installer make. It does make an Electrical Engineer though (with suitable post qualification experience to cement competence).
A time served Electrician is not an Engineer, however, that does not make them incompetent to design and install electrical systems under BS7671 and associated guidance.
Now, machinery, forget BS7671 it is totally irrelevant as Machinery, covered by the “EU Machinery Directive” is specifically excluded from the scope of BS7671.
Machinery electrical systems as under the scope of the “Machinery Directive” are to the C type Standard EN 60204-1.
So if your electrician is undertaking works on machinery & fixed wiring then he must be totally familiar with both of these standards and their requirements.
It is your responsibility as his employer to ensure that he has access to these standards, and the training etc. so that he can comply.
There is no reason, nor mechanism for him to be registered with the NICEIC or the like. Such registrations are on organisations/enterprises not individuals.
So, if you as an organisation are undertaking your own electrical works, then it is for you as an organisation to ensure that they are undertaken correctly, and meet any “scheme” requirements, not your employed electrician personally.
He should really have done the 17th Edition course by now, this document is now on its’ 3rd amendment and has been published since 2008 that’s 5 years!
Your organisation should have updated this employee by now.
The overarching regulations are, HASAWA, EAWR89, MHSWR, PUWER98, ESQCR etc. as I am sure most of you know.
Now IF, you refer to BS7671, this document states that a fixed electrical installation designed and completed in accordance with BS7671 is likely to meet the requirements of EAWR89.
So, from this you could deduct that testing, inspection and certification of works under BS7671 is required for compliance with EAWR89.
Ergo, your Electrician must be testing, and in accordance with BS7671 certifying the work he does to comply with EAWR89…
Next, if you are getting a 3 yearly check done by a 3rd party and this is showing up deficiencies in the installation covered by BS7671, then this is wrong. Either the 3rd party is looking for work, your Electrician has issues with the work he is doing, damage is being caused to the installation and not being reported/repaired, or, there are unauthorised works on the installation being undertaken.
Now at this point I would like to re-iterate that machinery is NOT covered by BS7671, so if your 3rd party inspectors are coding machinery defects under BS7671 then they are incompetent.
Unless your insurer requires the 3 yearly test, BS7671 does not, IF, the installation is adequately maintained. If you are having C1 or C2 defects then the installation is not adequately maintained, why is the company not meeting their obligations under EAWR89, a C1 or C2 would be a breach under EAWR89.
PUWER98 also requires that machinery is correctly maintained electrically, so if your electrician is not trained, competent in and familiar with and with access to EN 60204-1 & the associated A, B & C type standards for the machinery, especially if he is undertaking modifications, no matter how minor, as well as repairs, then the company is not compliant.
Whilst you could say that repairs are not relevant to the design and manufacturing standards, how would you know this without checking, I have seen repairs which are blatant significant functional changes to machinery.
So summary:
Engineer or Electrician?
Why are you not training him adequately?
Does he have access to the relevant test equipment, calibrated or otherwise verified as suitable to meet the requirements of BS7671 provided & maintained by the company? If not why not?
Does he have access to the required documentation provided by the company, BS7671, EN 60204-1 etc.? If not why not?
What is the scope of his works?
He does NOT need to be “NICEIC”, that is the responsibility of the company, as is his training, the provision of suitable and sufficient tools and test equipment to meet the standards and the provision of the relevant information.
Next, Robert, (twice)
About right, but, remember it is the responsibility of the company to train their people, not to force the employee to spend their money on training to meet the needs of their employer.
Oh, and the use of the term Engineer, please see above.
JohnW,
Now I’m guessing by now that you have read this far.
A factory MUST have its installation works certified fully to comply with EAWR89.
Now this is one simple method of showing that you have done as much as is reasonably practicable to meet your requirements under EAWR89 for installations that come under BS7671, i.e. you have fully complied with the requirements of BS7671.
There is no formal legal requirement to undertake an EICR.
If your installation is under the control of a suitably qualified Engineer, or other suitable competent person, with a suitable planned and preventative maintenance regime in place, with all works undertaken in accordance with BS7671 and documented accordingly (a requirement of BS7671 anyway) then an EICR would be a waste of money as the installation would be fully compliant and documented as such.
Next Robert again,
The IET are not a regulatory body as such, however, as the IEE then they write BS7671 with BSI.
They also publish a lot of other guidance on BS7671 etc.
I TOTALLY agree that a Domestic Installer should never be “let loose” on 3 phase work, anywhere, and in fact possibly not even single phase work in a commercial or industrial environment.
There also needs to be a distinction between a domestic installer and an Electrician.
A huge difference.
As Robert has suggested, anyone undertaking inspections & testing on installations under BS7671 must (IMHO) be qualified to do so, and the C&G (EAL) qualifications assist in proof of this competence.
Next, JohnW again,
Yes, installations works in a factory covered by BS7671 must be inspected, tested and certified to comply with BS7671, which is generally accepted by HSE as a method of compliance with EAWR89. So you could say that to comply with EAWR89, you should comply with BS7671, which requires inspection, testing and certification to BS7671. Now, how can you prove that the installation is safe and compliant with EAWR, if it is not inspected and tested? Also there is no other recognised standard or method to demonstrate this, other than compliance with BS7671.
As far as the scope of the electrical installation, this is that covered by BS7671, machinery is excluded as is High Voltage systems.
BTW, 400V a.c. 3 phase is NOT High Voltage, no matter what anyone thinks, it is defined in international standards as LOW Voltage.
Chris42, exactly.
JohnW, please see above.
David,
I am wary of the term Engineer, yes an Electrical Engineer should be able to assess the installation for compliance, if competent to do so, as far as actually making it safe, or installing a safe installation, not so.
An Electrical Engineer, may well not be trained in installation practices, why would they be, the actual installations works is trade level, Engineering is just that, not clipping cables to joists or chasing walls, that is not taught on a degree course which an Engineer should have attended, they may have undertaken a trade, then a Degree, so they then should be competent to undertake both roles.
Whilst the “piece of paper” does not make the install safe, I totally agree, IF the installation covered by BS7671 has been subjected to a full and suitable EICR under BS7671 then the document would provide evidence that the installation was safe at the time of I&T. Noting that it is like a car MOT. As long as it was undertaken by a competent person (Regina Vs Octel & Dancerama etc.).
There is no reason that the competent person cannot be a full time employee.
I trust this helps.