ÐÇ¿Õ´«Ã½

The ÐÇ¿Õ´«Ã½ Regulations Advisory Committee has advised, the minister Phil Hope has spoken and four applications to operate a competent person scheme for Part P have been submitted to the ODPM (see EMC, Nov 2003, p7). One of these comes from BRE Certification, in partnership with the ECA and the IEE. This scheme will meet exactly the Government's requirements – it will deliver inspection against the industry-approved Electrotechnical Assessment Scheme.

It is anticipated that the minister will announce early in the New Year which of the four applications have been successful and will be formally recognised as Part P schemes. Only then will legislation be enacted for the purposes of introducing Part P, which is expected to come into effect during the second half of 2004.

As the electrical contracting industry is now preparing itself for this long-awaited addition to the ÐÇ¿Õ´«Ã½ Regulations, does Part P hold any surprises for the industry that has lobbied so long and hard for it?

The industry's lobby focused primarily on bolstering the status of BS 7671 by giving it better statutory support. Certainly, Part P would seem to provide this. The draft Approved Document P states clearly that the new requirement for electrical safety will be met by adherence to the "fundamental principles" for achieving safety given in BS 7671: 2001 Chapter 13.

However, the world of ÐÇ¿Õ´«Ã½ Regulations is more extensive than that of BS 7671, and firms that wish to become competent persons for Part P will need, at the very least, to gain a familiarity with this larger world.

Competent person schemes are schemes whose members are adjudged sufficiently competent to self-certify that their work has been carried out in compliance with all applicable requirements of the ÐÇ¿Õ´«Ã½ Regulations.

Electrical contractors inevitably carry out builders' work in connection with their own specialist BS 7671 work and this builders' work may well be covered by the ÐÇ¿Õ´«Ã½ Regulations.

The competence of a competent person for Part P is something broader than the competence to carry out work in compliance with BS 7671

For example, electrical contractors are frequently called upon to install extractor fans, which are covered by Part F (ventilation). Their work might entail penetrating walls, floors and ceiling – Part B (fire safety). They must consider the accessibility of switches and socket outlets – Part M (access). Clearly their installations will include lighting systems – Part L1 (energy efficiency); and (heavens forbid!) they might be tempted to notch joists – Part A (structure).

This builders' work carried out in connection with BS 7671 work must also comply with ÐÇ¿Õ´«Ã½ Regulations and the certificate of compliance issued by a competent person to a building owner will say, in effect, that it does. The issue then becomes one of the ability of a competent person for Part P to carry out this builders' work in compliance with the ÐÇ¿Õ´«Ã½ Regulations. Clearly, it is not the intention that electrical contractors should turn themselves into builders in order to become competent persons for Part P.

Essentially, what will be required of electrical contractors that are competent persons is an appreciation of how the ÐÇ¿Õ´«Ã½ Regulations bear upon electrical installation work carried out in dwellings. In conjunction with their application to ODPM to run a competent person scheme, BREC/ECA/IEE are developing guidance material that addresses this requirement. This material is aimed, primarily, at qualified supervisors and once Part P has been introduced, competent persons should expect their work to be assessed for its compliance with all applicable requirements of the ÐÇ¿Õ´«Ã½ Regulations.

There has been comment in the trade press to the effect that members of existing certification schemes for electrical contractors can expect to be simply rolled over seamlessly into competent person schemes. This is potentially misleading – the competence of a competent person for Part P is something broader than the competence to carry out work in compliance with BS 7671.

Thus, in the world of the ÐÇ¿Õ´«Ã½ Regulations, the interface and overlap of the work of electrical contractors with that of other trades is being brought sharply into focus. Detailed thought is now being given to the various competences involved and the ways in which schemes can be aligned, so that they are complementary and do not undermine one another.