Written submission from Certsure LLP (BRC 58)
About Certsure
Certsure LLP is the largest third party certification body in the UK for electrical contractors, with 36,000 registrants with either our NICEIC or ELECSA brands. Though we launched in April 2013 as a joint venture between the Electrical Safety Council (ESC) and the Electrical Contractors’ Association (ECA), with the aim of providing funds for these organisations, our roots and commitment to raising standards in the industry date back 112 years to 1901.
Our responses to questions raised by the Select Committee
1. The extent to which members of the public are aware of the competent person scheme and that certain domestic electrical works need to be reviewed and certified to meet the requirements of Building Regulations
1.1. We acknowledge that awareness of Part P amongst consumers requires improvement and that is why much of our surplus funds the ESC’s campaigns to raise consumer awareness of the value of using a qualified, competent electrician. Moreover, NICEIC itself has promoted Part P through its Don’t Take The P and ASK campaigns and the use of registered electricians on high profile programmes such as DIY SOS and Sarah Beeney’s House of Horrors. Between March 2012 and March 2013 NICEIC received 336 items of coverage across national and regional print and broadcast media.
1.2. Government could commission a survey to provide a detailed picture of consumer awareness; however, a detailed survey would be costly. The ESC carries out an annual consumer survey that gauges consumer awareness of Part P and the need to use registered electricians, the results are used to direct campaign activity throughout the year. More important than ensuring recognition of Part P by name, or awareness of the Competent Person Schemes, is ensuring wide-spread public recognition that registration is important for work in the home and that electrical work can be unsafe and illegal if not done properly.
1.3. There have recently been concerns have been expressed over the potential for confusion amongst consumers as there is more than one register that references electrical firms registered under Part P. In order to overcome these concerns a meeting has recently been held with NAPIT and other industry partners where it was agreed to seek to develop one easily identifiable quality mark underpinned by a register of all full scope Part P registered electricians. (See also Section 5).
1.4. In addition to consumer campaigns, the system of self-certification contributes to raising awareness. Each year, over one million electrical installations are notified to Local Authority Building Control by our registered contractors. Every homeowner receives a certificate from Certsure plus details on an Insurance Backed Warranty. Customers of NICEIC contractors also benefit from a guarantee of standards and this will be available to ELECSA customers in 2014 along with information on using registered electricians and electrical safety from the ESC on any future work carried out. Across all schemes that equates to over 8 million homes having received such a certificate and safety information since 2005.
1.5. There is no doubt that certification carries value because some seek to obtain its benefits without submitting themselves to the rigours of assessment. In response to these attempts to claim certification through use of the brand, Certsure operates a Wall of Shame which displays information on contractors who have never applied or been assessed or where certification has lapsed or been withdrawn.
2. The extent to which those carrying out electrical works are adequately trained to meet the requirements of the Building Regulations and the extent to which all those working for a company are brought up to the same level of skills
2.1. There are two training routes electrical contractors may take into the industry. However training is just the first step on the path to successful certification. To use an analogy, training and qualification is like taking the driving theory test. The actual driving test assessment with an examiner sitting alongside the candidate is what allows someone to drive a car legally and is akin to the certification assessment of competence.
2.2. The traditional route into the industry is a four year apprenticeship with time split between academia and experience with a sponsoring organisation. On satisfactory completion of studies and an AM2 test – a form of practical assessment - the apprentice is recognised as an electrician. Originally aimed at school leavers, this route is not always realistic or practical for those wishing to change careers. As a result, other accelerated routes were developed. This has caused some dissatisfaction among those who have spent a number of years in the industry, but it does not mean those routes are without merit.
2.3. All of the qualifications to be eligible to apply for the Part P scheme are detailed in the Minimum Technical Competence (MTC) documents agreed between industry, regulators and Government. This MTC document is also recognised by DECC for the Green Deal Scheme. Since Part P was introduced in 2005, there has been a gradual uplifting of the MTC. From April 2013, the revised electrical MTC will require authorisation and a Level 3 certificate, which cannot be completed in less than 224 guided learning hours.
2.4. Training and qualifications are set by awarding bodies such as City & Guilds and EAL, the specialist awarding organisation for the engineering, building services and related sectors. Where Certsure offers training and qualifications they do so under license from the awarding bodies. Training is provided separately from the certification functions to ensure that independence and impartiality is maintained and kept under review by the United Kingdom Accreditation Service (UKAS). All surpluses are passed back to the ESC and ECA.
2.5. Once a contractor achieves the correct level of MTC they may apply to be assessed for Part P certification which costs £370. Assessment recommendations are: pass; pass subject to providing additional evidence; rejection (don’t reapply); and further assessment to see additional examples of work.
2.6. Over the last 24 months the pass rate has been 81.4%. 6.2% were requested to submit further evidence for review and 12.5% required an additional visit. The high pass rate is a result of a robust pre-assessment process which means only those with a good chance of passing put themselves forward or are put forward for assessment.
2.7. Having passed the assessment, a Qualified Supervisor (QS) has ultimate responsibility for signing off work so in the event that there is an incident caused by bad electrical work they will be held accountable. Certsure makes very clear the consequences for, and responsibilities of, the QS. Following a tragic accident in 2007, caused by a contractor failing to test and inspect properly, Certsure wrote to every QS to remind them of their responsibilities. Seminars are held at industry events and NICEIC & ELECSA live events to educate and update QSs on their responsibilities. The QS system helps ensure safe working practices are institutionalized in a company and not just left to an individual.
2.8. Upon its introduction, Part P caused mixed feelings within the trade, with those who had been involved in the industry for a long time questioning the need to register. However, Certsure is confident that only those contractors who can demonstrate their knowledge and understanding of the regulations through a robust assessment will secure certification.
3. The extent to which those carrying out electrical works, to which the Building Regulations apply, review or have their work reviewed to ensure that it meets the requirements of the Regulations
3.1. All Part P registrants are currently required to be assessed annually through rigorous assessment of their work and knowledge and understanding of the Wiring Regulations. There are over 40,000 contractors registered on Competent Persons Schemes and their notifiable work is tracked and reported to local authorities.
3.2. Certsure and its previous entities have undertaken assessments under UKAS accreditation standard EN45011 since 2002 (NICEIC) and 2008 (ELECSA). We believed this was essential if contractors were to have faith in the system. Not all Competent Person Schemes are currently UKAS accredited but they are required to achieve this by June 2014 and we welcome this.
3.3. Assessments are conducted annually through a minimum of half day of questioning and observation in the presence of a Qualified Supervisor (QS), whose responsibility it is to supervise and sign off the work of others. Additional assessment time is required where there are multiple locations or additional QSs.
3.4. Assessments start with time spent at the contractor’s office or home where insurance details, complaints system, contracts old and new, electrical certificates, health and safety policy, standards and access to appropriate test equipment to carryout testing are reviewed. Following this, the assessor and QS will review a sample of work that is representative of the contractors work activities and are chosen by the assessor. At each location the assessor will ask questions of the QS about the installation against the written specification and the wiring regulations. The QS will show examples of his work and demonstrate how the installation complies with the requirements. The QS will also be asked to demonstrate testing and safe isolation. We are consistently reviewing the standards QSs need to reach and these have recently been upgraded.
3.5. The Government has previously explored the robustness of the QS system and found it to be satisfactory. Moreover, it means that the Competent Person Scheme covers much more than mere technical competence such as complaints, insurance, health and safety, management etc., unlike GasSafe which solely considers the gas technical competence of the individuals.
3.6. Finally, assessments are conducted by assessors, the majority of whom are electrical engineers who are themselves required to have achieved a level of competence in excess of that which they are required to assess. Our assessors are required to update their knowledge on a regular basis, as standards change. They do so through a mixture of CPD, face to face meetings, regional conferences, technical guidance and policy updates. The competence of the assessors is reviewed annually by UKAS.
3.7. We have investigated a report in one of the responses of a four minute assessment. Our assessment report shows that during this assessment we assessed a rewire at one address and an additional circuit at another. The contractor in question was deregistered from NICEIC for non-payment of fees in February 2012, but unfortunately continues to display the NICEIC logo on their website.
3.8. Furthermore, we are happy to write to the Select Committee in specific detail on any evidence that has been submitted where NICEIC and ELECSA have been mentioned.
3.9. We have a team which handles complaints resolution and provides support to consumers. If we receive complaints which are upheld then the relevant information will be discussed with the contractor either at the next visit or immediate steps will be taken if the complaint is serious.
4.1. UKAS accreditation is only awarded to third party certification bodies that meet and continue to meet the requirements of EN45011.
4.2. EN45011 covers much more than mere technical competence and includes issues such as complaints, insurance governance.
4.3. Certification bodies must demonstrate they are independent of any interests that could affect the certification outcome and must be impartial in all of their certification decisions. To achieve this Certsure has a Certification Council made up of industry stakeholders representing users, regulators and the trade. The Council has oversight of certification activities and ensures Certsure is independent, impartial and operating in a way that meets EN45011. The Council can raise issues directly with the Certsure Board and UKAS as necessary.
4.4. The assessment outlined in Section 3 is thorough and it is not possible to pass if the contractor is unable to demonstrate how to work safely. Of those undertaking assessment, a number fail. They are then offered examples of areas on which they need to improve.
4.5. Furthermore, contractors are required by law to notify scheme operators of any electrical works which they themselves deem as notifiable. This is done via an online tool which captures the information requested by Local Authority Building Control and sends this information electronically to the correct Local Authority. A certificate is then sent to the homeowner confirming who did the work and that the contactor has made a declaration that the works comply with Parts 4 and 7 of the Building Regulations. Homeowners may be asked for this information by a conveyancer if they sell their property.
4.6. Independent verification of assessment reports and certification recommendations is conducted by qualified and competent staff to determine whether the report is sufficiently detailed and if the assessment recommendation should be upheld or if further evidence or assessment visits are required.
4.7. From June 2014, UKAS will accredit all scheme operators. UKAS are able to spot check our operation without giving any notice.
5.1. Our scheme authorisations from DCLG and also compliance with UKAS accreditation (EN45011) require us to publish / make available a register of our contractors.
5.2. As stated in 1.3 we have agreed to seek to develop one easily identifiable quality mark, underpinned by a register of all full scope Part P registered electricians, that provides a single point of reference for consumers to refer to when seeking an electrician to do electrical work in their home.
5.3. It is anticipated that the proposal will include all licensed Part P scheme operators in England and Wales who meet the new scheme requirements in line with DCLG’s timeline, and would lead to the removal from the market place of both existing registers (ElectricSafe Register and the Electrical Safety Register). We have written to the Department setting out our intentions and seeking Government support in this regard.
5.4. We are keen to work closely with both the Committee and the Department on the development of a new mark, to ensure it meets the objectives of policy makers, and will keep all parties informed of ongoing developments.
5.5. However, we maintain that competition and choice is fundamentally good for the electrician and homeowner. Competition and the need to distinguish ourselves from others encouraged us to be amongst the first to seek UKAS accreditation, and drive up standards.
5.6. Contractors need us to ensure we promote them and choose schemes on the basis of which brand gets them work. Competition ensures more promotion to consumers.
5.7. Behavioural change and an increase in standards are best achieved by using both sanctions and incentives. A competitive landscape creates the business benefits of registration which complements the legislative framework of Part P.
5.8. Certsure is concerned by some of the claims of corporate greed which have been put forward by respondents. Certsure LLP is wholly owned by the ESC and the ECA. Initial assessment and annual registration fees – one of the smaller costs faced by a contractor compared to other operating costs - are £370 for the Part P scheme under ELECSA and the NICEIC, a fee which has been held for four of the last five years. All profits made from our assessment and certification activities are reinvested back into the industry through the ESC or ECA. DCLG requires scheme operators to ensure the schemes they operate are financially viable and self-sufficient within a reasonable timescale. Any surplus may only be used for the general benefit of the sector in which the scheme operates.
6.1. DCLG licenses scheme operators to run schemes and conditions of that license can be changed to raise standards. The original scheme authorisation in 2004/5 required Part P scheme operators to achieve UKAS accreditation within 3 years. The new conditions of authorisation are intended to make all schemes equal and to allow DCLG to terminate licences where the conditions have not been met.
6.2. DCLG supervises the schemes through the UKAS, which is a scheme requirement from 6 June 2014 but to which we already subscribe.
6.3. DCLG provide regular feedback through the Competent Persons Forum on areas for improvement and engage with scheme operators at an individual level on complaints.
6.4. Competent Person scheme operators also work with trading standards to enforce relevant consumer law when required.
6.5. Certsure operates in a transparent and open manner and we would extend an open invitation to all members of the Committee to see our operation and technical expertise first hand. A DCLG representative and the Local Authority Building Control have already visited our offices to find out more about our business activities.
7. Conclusions
7.1. The current accreditation scheme, built on the 1956 model, provides robust standards for the industry. When the Committee reviewed Part P it stated: “A strengthened Part P Building Regulations regime would be better than a fully mandatory scheme at the present time”. Like the Committee, we do not believe the review of Part P in 2012 and the reduction of notifications in kitchens and bathrooms will benefit electrical safety and may present a real safety issue for householders. We do not believe there is any evidence to suggest that the initial conclusion of the Committee should be revised.
7.2. We have a culture of continuous improvement and welcome steps taken but not yet fully implemented to raise standards further in Part P.
7.3. Contractor feedback is important and we take it seriously. However, we are confident of the integrity of the many examples of electricians who have volunteered their satisfaction with the value of registration. The scheme’s annual growth indicates the success and respect for our brands in the marketplace.
7.4. Certsure’s roots in developing electrical safety standards and operating schemes stretch back for 112 years.
7.5. All surplus from the activities of Certsure are reinvested for the benefit of the industry and consumers.
7.6. We are happy to write to the Select Committee in specific detail on any evidence that has been submitted where NICEIC and ELECSA have been mentioned.
December 2013