Part P explained

On 5 July 2003, the Government announced its intention to introduce legislation “to amend the Building Regulations to include a requirement on electrical safety in dwellings”, and Part P was published on 22 July 2004. This will provide statutory support to BS 7671, the IEE Wiring Regulations, and will introduce Approved Document P of the Building Regulations concerning fixed electrical installations in dwellings in England and Wales.

As a result, this introduces a new statutory regulation and all fixed electrical installations in dwellings will become a controlled service as defined in the Building Regulations 2000. This means that, from 1 January 2005, anyone carrying out fixed electrical installation work in a dwelling must comply with Part P; also, all such work will need to be notified to the local Building Control body before work commences. The only exceptions to this are:

• the proposed work is to be undertaken by a Competent Person (a company authorised to self-certify compliance on completion of the work);
• the proposed work is of a minor nature.

Work commenced prior to 1 January 2005 will be exempt, provided that the work is completed by 31 March 2005.

Competent Persons are formally recognised by the Government as firms adjudged sufficiently competent to self-certify that their work has been carried out in compliance with the Building Regulations.

In terms of Part P, Competent Persons are in fact firms not persons. Of course, firms can be single-person entities.

A firm wishing to join a Competent Person scheme is vetted to ensure it meets a scheme’s conditions of membership, including levels of competence. If it meets these conditions, it is classified as a Competent Person and its work is then not subject to inspection by Building Control bodies.

The Office of the Deputy Prime Minister’s (ODPM) current criteria dictate that assessments should be carried out as required by the Electrotechnical Assessment Scheme (EAS) and that each scheme and certifying body should be accredited by UKAS to EN 45011.

The EAS scheme is published by the IEE and a free copy of this scheme may be downloaded from www.iee.org.uk.

Competent persons

Those wishing to join a Competent Person scheme will need to demonstrate their competence and, if necessary, may be required to undergo additional training. The work of Competent Persons will be inspected at least once a year.

In the past, clients have generally specified that their electrical installation work should be undertaken by an NICEIC or ECA approved contractor. From 1 January 2005, clients and specifiers of fixed electrical installation work within dwellings will be able to specify that the work should be carried out by a Competent Person from any one of the scheme providers.

The ODPM originally approved five Competent Person scheme providers which are named within the Building Regulations, these being:

• BRE Certification (supported by the ECA) – tel: 0870 609 6093 or 01623 404515 or visit www.partp.co.uk;
• British Standards Institution – tel: 01442 278607 or go to www.bsi-global.com;
• ELECSA (who use British Board of Agrément to carry out the inspections) – tel: 020 7864 9913 or www.elecsa.org.uk;
• NICEIC – tel: 0800 013 0900 or www.niceic.org.uk;
• Zurich Certification – tel: 0121 456 1311 or www.zurich.co.uk.

This effectively came down to four when Zurich Certification was acquired by the NICEIC becoming part of NICEIC Certification Services. On 17 November the Government approved NAPIT Certification as a scheme provider (tel: 0870 444 1392 or see www.napit.org.uk).

Building Regulations

Competent Persons that are able to self-certify their own work must have an appreciation of how all of the Building Regulations affect their electrical installation work and need to be competent to confirm that work complies with all the applicable requirements of the Building Regulations, not just Part P.

Such requirements include, but are not limited to:

• Part A (structure) – depth of chases in walls and size of openings in joists or structural elements;
• Part B (fire safety) – fire resistance of ceilings and walls including provision of fire alarm and detection systems;
• Part C (site preparation and resistance to moisture) – moisture resistance of openings or penetrations for cables through external walls;
• Part E (resistance to the passage of sound) – penetrations through ceilings and walls;
• Part F (ventilation) – ventilation rates for areas within a dwelling;
• Part L (conservation of fuel and power) – energy efficient lighting, effective controls including automatic controls;
• Part M (access to and use of buildings) – heights of switches, socket outlets, etc;
• Part P (electrical safety) – fixed electrical installations in dwellings.

Approved Documents may be downloaded free of charge from www.odpm.gov.uk.

Failure to comply with the Building Regulations is a criminal offence and local authorities have the power to require the removal or alteration of completed work that does not comply with these requirements.

A person carrying out electrical work that contravenes the Building Regulations can be fined up to £5000, and £50 each day the contravention continues. Householders may also encounter problems selling their property if work carried out does not comply with the Building Regulations. The householder is responsible for ensuring that all building work, including electrical work, complies with the Building Regulations.

In conjunction with the NICEIC, the ECA has produced guidance to help electrical contractors self-certify electrical installation work to comply with all the other relevant parts of the Building Regulations. A free copy may be downloaded from www.eca.co.uk. Printed copies are available from the ECA membership department on 020 7313 4808/4810.

The guidance has been endorsed by LABC Services, the body representing Local Authority Building Control interests, and it is hoped that it will be recognised as an authoritative reference source for both electrical installers and building control officers.

Scope of Part P

Part P applies to fixed electrical installations in buildings, or parts of buildings, comprising:

• dwelling houses and flats;
• dwellings and business premises that have a common supply – for example, shops and public houses with a flat above;
• common access areas in blocks of flats, such as corridors and staircases (not lifts);
• shared amenities in blocks of flats such as laundries and gyms;
• outbuildings such as sheds, detached garages and greenhouses served from a local dwelling, including garden electrics, external lighting and pond pumps, etc.

A dwelling, as defined in Part B of the Building Regulations, which deals with fire safety, is: “a unit of residential accommodation occupied (whether or not as a sole or main residence) by a single person or people living as a family, or by not more than six residents living together as a single household, including a household where care is provided for residents”.

Places of employment and workplaces such as hotels and university campus student accommodation fall outside the scope of Part P. These types of buildings are, however, covered by the Electricity at Work Regulations.

The requirements

The new Part P requirements, as taken from the Approved Document P are:

• design, installation, inspection and testing – reasonable provision shall be made in the design, installation, inspection and testing of electrical installations in order to protect persons from fire or injury;
• provision of information – sufficient information shall be provided so that persons wishing to operate, maintain or alter an electrical installation can do so safely.
• There are limits on application. The requirements of this Part apply only to electrical installations that are intended to operate at low or extra-low voltage and are:
• in a dwelling;
• in the common parts of a building serving one or more dwellings, but excluding power supplies to lifts;
• in a building that receives its electricity from a source located within or shared with a dwelling;
• in a garden or on land associated with a building where the electricity is from a source located within or shared with a dwelling.

The objective of Part P, is “to ensure that, on average, more fixed electrical installations in more dwellings comply more thoroughly with accepted safety standards during their service lives”. The new safety requirements are applicable to alterations and additions to existing installations including rewires, as well as to new build.

These requirements will be met by complying with the “Fundamental Principles” for achieving safety as given in Chapter 13 of BS 7671.

These fundamental principles can be achieved by following:

• the requirements of BS 7671:2001;
• the IEE On-Site Guide and IEE Guidance Notes 1 to 7.

Definitions

In order to implement Part P, the definition of an electrical installation is key. The Approved Document P defines an electrical installation as “an assembly of associated electrical equipment supplied from a common origin to fulfil a specific purpose and having certain co-ordinated characteristics.”

For the purposes of the Building Regulations an electrical installation means fixed electrical cables or fixed electrical equipment located on the consumer’s side of the electricity supply meter.

Extra-low voltage (elv) is defined in BS 7671 as “normally not exceeding 50 Vac or 120 V ripple-free dc, whether between conductors or to earth.”

Low voltage (lv) is defined in BS 7671 as “normally exceeding extra-low voltage but not exceeding 1000 Vac or 1500 Vdc between conductors, or 600 Vac or 900 Vdc between conductors and earth.”

Notifiable work

See Tables 1 and 2 for examples of work that need not be notified and examples of special locations and installations.

The extra-low voltage (elv) category was included within Part P to cover elv lighting installations comprising downlighters. These have been known to be the cause of a number of house fires due to incorrectly sized conductors, substandard installations and breakdown at terminations.

ODPM guidelines have confirmed that any new work on new elv fixed electrical wiring for communication and information technology, signalling, control and the like is non-notifiable work unless the wiring is located in bathrooms and other special locations.

While other elv fixed wiring installations work for domestic ancillary systems within dwellings may not fall within the scope of Part P, and is classed as non-notifiable work, all elv fixed wiring installation work should be installed in accordance with BS 7671 and comply with the relevant safety requirements of this standard.

The notification process

It is presently envisaged that the Competent Person scheme operators will issue a Certificate of Compliance to the client, and will copy information recorded on the certificate to Building Control as a declaration of compliance with Building Regulations 4 and 7.

Some scheme operators may place the onus on the Competent Person enterprise to issue the Certificate of Compliance to the client.

Figure 2 shows how the process may work:

1) the Competent Person will be required to issue BS 7671 certification to the client;

2) the Competent Person will be requested to notify their scheme provider of work carried out upon completion of work;

3) the certification body issues the Certificate of Compliance (with the Building Regulations 4 & 7) and confirmation of Building Control notification to the client;

4) the certification body issues notification of the completed work to Building Control for their records.

It must be remembered that Competent Persons that self-certify compliance with Part P will also have to certify compliance with all other relevant parts of the Building Regulations that have been affected by the electrical work that has been carried out.

Qualified supervisor

An enterprise seeking Competent Person status is required to have at least one Qualified Supervisor, someone who has direct responsibility on a day-to-day basis for the safety, quality and technical standard of the work, and ensures the results of the inspection, testing and verification process are accurately recorded on the appropriate certification forms as required by BS 7671.

Depending on the volume of work undertaken and the geographical spread of a firm’s operations, it may be the case that a firm will require more than one Qualified Supervisor.

A firm may be asked by an assessor to justify the number of Qualified Supervisors it has in place. Firms should be aware that an assessor will apply the following test: “Is the number of proposed Qualified Supervisors sufficient to safely support the firm’s activities as a Competent Person given the composition, scale and geographical spread of its workload?”

Firms applying for Competent Person status are strongly advised to establish the appropriate number of Qualified Supervisors they require and ensure that each of them meets the required criteria.

Qualified Supervisors should have the appropriate knowledge and experience of the design, installation, testing, certification and reporting procedures for the electrical installation work within dwellings. In addition, they must be conversant with the following:

• The Electricity at Work Regulations 1989;
• The current issue of BS 7671;
• The applicable Building Regulations (not just Part P, but any other part of the Building Regulations that may apply to a particular work activity).

Any individual who wishes to become a Qualified Supervisor under Part P must possess a qualification that is referenced in the edition of the IEE Wiring Regulations current at the time the course was undertaken.

Examples of suitable qualifications are given below but these are not exhaustive and others may be accepted after individual consideration:

• S/NVQ Level 3 in Installing and Commissioning Electrotechnical Systems and Equipment;
• NVQ Level 3 in Electrotechnical Services (Installation – Buildings and Structures);
• a registered electrical apprenticeship;
• EAL Level 2 Certificate for Domestic Electrical Installers;
• City & Guilds 2380;
• City & Guilds 2381;
• City & Guilds A, B or C certificate;
• City & Guilds 236 Part 1, 2 or C certificate;
• City & Guilds 2360 Part 1, 2 or C certificate;
• City & Guilds 2356 Part 1 or 2;
• City & Guilds 2391;
• City & Guilds 2400;
• SQA tailored award in Design and Verification of Electrical Installations.

Competent person costs

The process of becoming a Competent Person and operating as a Competent Person will entail costs. The application, assessment and initial registration of a Competent Person provide the most obvious and immediate example of this, but there are other costs, some of which will be borne by the Competent Person enterprise and some of which will be directly charged to the client.

The main costs will be:

• application, initial assessment and registration;
• annual surveillance;
• certification;
• notification;
• warranty cover;
• complaints process.

Applicants to Competent Person schemes will be charged a fee for the initial assessment and registration process.

The UKAS EN 45011 accredited status and the requirements imposed by Government as a condition of approving self-certification schemes require the annual surveillance of the installation work of registered firms.

Competent Persons are required to comply with BS 7671. This includes complying with the certification requirements set out in this standard. Firms are advised to use the model forms set out in BS 7671, copies of which can be freely downloaded from the IEE web site (www.iee.org.uk) or, as appropriate, forms from the ECA, NICEIC, etc.

Competent Person schemes are required by Government to provide the relevant local authorities with information about the work carried out by registered firms. In order to be able to do this, firms will be required to tell their scheme operator about the work they have done, the address of the dwelling in which it was carried out, and the date of completion of the work. This must be done for each job carried out by a Competent Person that is in scope to Part P.

The scheme providers will levy a charge per job to carry out the necessary notification – this will include sending clients a Building Regulations compliance certificate. This charge will be levied on Competent Persons, and they in turn, if they so choose, can separately itemise this cost in the quotation to their customer.

Competent Person schemes are required by Government to make arrangements such that all customers of scheme members have an opportunity to purchase an insurance-backed warranty as a minimum against non-compliance of work with the Building Regulations.

Competent Persons will be required to offer the householder or person ordering the work the opportunity to purchase the guarantee/warranty against non-compliance of electrical installation work with the Building Regulations. However, uptake of the offer is optional and not compulsory.

The costs of complaint investigation may be absorbed in the costs of the initial assessment and subsequent surveillance for some providers. Others, however, may require an additional charge for this service to be provided.