Just wanting to get some clarification on low risk work.
“6A Meaning of low-risk, high-risk, and general prescribed electrical work
(1) In these regulations, low-risk prescribed electrical work—
(a) means prescribed electrical work that comprises the maintenance or replacement of a fitting in an existing installation;”
The clause allows for replacement of a fitting as low risk work but no details are given about what you can replace it with. I know that “like for like” is a commonly used term but does not appear in the regulations.
The specific scenario I am looking at is replacing a 2.5mm2 2c+e cable from the switchboard to the range switch with a 6mm2 cable and replacing the 20A MCB with a 32A MCB. The cable run is identical.
It would seem that this falls under replacement as I have not added anything to the installation just replaced what is there. albeit with slightly different characteristics.
In a discussion with another electrician they thought it would be classified as general work as it was an alteration due to changing the MCB rating.
Any clarification on what is deemed replacement is much appreciated.
Low Risk Work
Low Risk Work
I agree thus amounts to an alteration of the circuit; and is not maintenance.
Also agree that "like-for-like" is not a term that appears anywhere in ESRs, and never has.
As a concept it isn't actually very helpful; as it's open to being applied both too strictly and too loosely.
When ESRs first came into force; the the risk categories hadn't been invented,
but there was a distinction (in then ESR 66) between PEW required certification, and PEW that didn't require certification.
the wording for the 'replacement" item of what didn't require a CoC was:
"the replacement of any fitting with a fitting of an appropriate size, type, and rating for the circuit".
Unfortunately those words were lost in 2013 Amendment.
Now we have ESR 59'; that allows 3 methods of maintaining an installation.
The most relevant being maintaining it in "original condition" - ie NOT making any significant changes.
While I accept that in this case you would be, from one point of view, "replacing" a length of cable; and "replacing" a protective device;
the key aspect is that the characteristics of the circuit would change.
I'm absolutely certain what EWRB's view would be, if it came before them
Bottom line: even if the words can be interpreted as perhaps allowing a CoC not to be issued; why wouldn't you issue one?
Or is this discussion more about the fact that there are grey areas in ESRs?
Go to full postAlso agree that "like-for-like" is not a term that appears anywhere in ESRs, and never has.
As a concept it isn't actually very helpful; as it's open to being applied both too strictly and too loosely.
When ESRs first came into force; the the risk categories hadn't been invented,
but there was a distinction (in then ESR 66) between PEW required certification, and PEW that didn't require certification.
the wording for the 'replacement" item of what didn't require a CoC was:
"the replacement of any fitting with a fitting of an appropriate size, type, and rating for the circuit".
Unfortunately those words were lost in 2013 Amendment.
Now we have ESR 59'; that allows 3 methods of maintaining an installation.
The most relevant being maintaining it in "original condition" - ie NOT making any significant changes.
While I accept that in this case you would be, from one point of view, "replacing" a length of cable; and "replacing" a protective device;
the key aspect is that the characteristics of the circuit would change.
I'm absolutely certain what EWRB's view would be, if it came before them
Bottom line: even if the words can be interpreted as perhaps allowing a CoC not to be issued; why wouldn't you issue one?
Or is this discussion more about the fact that there are grey areas in ESRs?
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gregmcc
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Re: Low Risk Work
this is clearly general risk work, 6.0mm is not a like for like replacement 2.5mm, you are clearly uprating the circuit and this is not maintenance.
Re: Low Risk Work
I agree thus amounts to an alteration of the circuit; and is not maintenance.
Also agree that "like-for-like" is not a term that appears anywhere in ESRs, and never has.
As a concept it isn't actually very helpful; as it's open to being applied both too strictly and too loosely.
When ESRs first came into force; the the risk categories hadn't been invented,
but there was a distinction (in then ESR 66) between PEW required certification, and PEW that didn't require certification.
the wording for the 'replacement" item of what didn't require a CoC was:
"the replacement of any fitting with a fitting of an appropriate size, type, and rating for the circuit".
Unfortunately those words were lost in 2013 Amendment.
Now we have ESR 59'; that allows 3 methods of maintaining an installation.
The most relevant being maintaining it in "original condition" - ie NOT making any significant changes.
While I accept that in this case you would be, from one point of view, "replacing" a length of cable; and "replacing" a protective device;
the key aspect is that the characteristics of the circuit would change.
I'm absolutely certain what EWRB's view would be, if it came before them
Bottom line: even if the words can be interpreted as perhaps allowing a CoC not to be issued; why wouldn't you issue one?
Or is this discussion more about the fact that there are grey areas in ESRs?
Also agree that "like-for-like" is not a term that appears anywhere in ESRs, and never has.
As a concept it isn't actually very helpful; as it's open to being applied both too strictly and too loosely.
When ESRs first came into force; the the risk categories hadn't been invented,
but there was a distinction (in then ESR 66) between PEW required certification, and PEW that didn't require certification.
the wording for the 'replacement" item of what didn't require a CoC was:
"the replacement of any fitting with a fitting of an appropriate size, type, and rating for the circuit".
Unfortunately those words were lost in 2013 Amendment.
Now we have ESR 59'; that allows 3 methods of maintaining an installation.
The most relevant being maintaining it in "original condition" - ie NOT making any significant changes.
While I accept that in this case you would be, from one point of view, "replacing" a length of cable; and "replacing" a protective device;
the key aspect is that the characteristics of the circuit would change.
I'm absolutely certain what EWRB's view would be, if it came before them
Bottom line: even if the words can be interpreted as perhaps allowing a CoC not to be issued; why wouldn't you issue one?
Or is this discussion more about the fact that there are grey areas in ESRs?
- Rating: 16.67%
Re: Low Risk Work
Thanks for the info. I did issue a CoC for the work but reading 6A wondered if it was required. I was unable to find something that defined replacement so was a grey area. 59(3)b makes it much clearer that if you are replacing something then you would need to maintain it in its original condition.
Last edited by Jabba on Tue Dec 07, 2021 7:18 pm, edited 1 time in total.
Re: Low Risk Work
I think a good general rule is that if you are significantly altering the electrical characteristics of a circuit you are making an alteration rather than maintaining. But like most general rules-of-thumb; it can't be applied strictly.
Eg replacing a broken / degraded SERF with another SERF is clearly replacement (and permitted).
Replacing with equivalent-rated mcb makes only a minor change to the circuit's charactristics.
Or if adding BTI has reduced the original CCC of the conductors, replace with lower-rated mcb would - in my view - be restoring to original condition
(on basis that original condition was : load< CCC< protection).
Someone else might think that any change in protection rating amounts to an alteration.
Which shows that when maintaining to "original condition"; it all depends on how you define what the "original condition" was.
Same applies to ""like-for-like"; depends on how you define the likeness.
The key to writing Rules is that they should provide clarity of intent; but it's not possible to be100% clear for 100% of cases.
Simple is good; and the more variables you try to cover, the more complex the rule becomes.
"3000" suffers from this; much of the change in recent years has been trying to improve clarity
both to prevent practices that are poor practice, and to avoid over-zealous enforcement by nit-picking Inspectors.
Eg replacing a broken / degraded SERF with another SERF is clearly replacement (and permitted).
Replacing with equivalent-rated mcb makes only a minor change to the circuit's charactristics.
Or if adding BTI has reduced the original CCC of the conductors, replace with lower-rated mcb would - in my view - be restoring to original condition
(on basis that original condition was : load< CCC< protection).
Someone else might think that any change in protection rating amounts to an alteration.
Which shows that when maintaining to "original condition"; it all depends on how you define what the "original condition" was.
Same applies to ""like-for-like"; depends on how you define the likeness.
The key to writing Rules is that they should provide clarity of intent; but it's not possible to be100% clear for 100% of cases.
Simple is good; and the more variables you try to cover, the more complex the rule becomes.
"3000" suffers from this; much of the change in recent years has been trying to improve clarity
both to prevent practices that are poor practice, and to avoid over-zealous enforcement by nit-picking Inspectors.
- Rating: 16.67%