Amendment 2 to BS 7671 (18th Edition), effective from 28 September 2022, significantly extended the requirement for RCD protection. All socket outlets up to 32A in care homes now require RCD protection, and all lighting circuits in locations containing a bath or shower must be RCD-protected.
Amendment 2 to BS 7671 (18th Edition), which took effect from 28 September 2022, extended the circumstances in which residual current device protection is required. Under the amended regulations, RCD protection is now required for socket outlets rated up to 32A in a much broader range of situations than previously, and lighting circuits serving locations containing a bath or shower now also require RCD protection, closing a gap that previously existed for lighting in these higher-risk areas.
Care homes have an unusually high proportion of rooms containing a bath or shower relative to a typical domestic or commercial building, given the number of assisted bathing facilities and en-suite wet rooms across resident accommodation. The lighting circuit requirement introduced by Amendment 2 therefore has a disproportionate impact on care settings compared with the office and retail premises the wider RCD requirements are often discussed in relation to.
An EICR completed before 28 September 2022 was assessed against the requirements in force at that time and will not have flagged the absence of RCD protection on circuits that only became subject to the requirement under Amendment 2. This means a care home can hold a current, satisfactory-looking EICR that nonetheless does not reflect today's standard, creating a gap between passing a historic inspection and being compliant with the wiring regulations as they now stand.
Amendment 2 does not retrospectively require every existing installation to be upgraded immediately -- BS 7671 changes generally apply to new work and alterations rather than forcing wholesale rewiring of compliant older installations. However, where an operator is aware their installation predates the amendment and serves rooms with a bath or shower, commissioning a targeted review of the affected circuits, rather than waiting for the next scheduled EICR, is the more defensible approach given the vulnerability of the resident population.
Ask your electrician to confirm explicitly, in writing, whether socket outlets and bathroom lighting circuits across the building meet the Amendment 2 RCD requirements, rather than relying on a general 'satisfactory' EICR outcome. Where gaps are identified, record them as findings with a remediation plan and timescale in the same way as a C2 observation, even if the original EICR predates the amendment and did not formally flag them.
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