Early on in the wiring regulations, page 21 of the big yellow book in fact, is Regulation 134.1.1 which states “The installation of electrical equipment shall take into account of manufacturers’ instructions”. So, what happens when the manufacturer says something eye-rollingly daft?
Manufacturers’ instructions are more important than the wiring regulations themselves, so if the manufacturer says you need to install their product in a particular way, then that overrides the more generic advice given in the regs book. The assumption is that the manufacturer knows what they’re talking about and that their way of doing things is no less safe than the requirements of the wiring regulations.
Yesterday Nigel and I were appointed to install a whole-house ventilation unit called a Lofty Remcon which is branded and sold by a company called Breathing Space. We performed the job without issue with it taking a couple of hours on site, and out of interest I looked up the product on the Breathing Space website where I found some incredible statements regarding the installation of this Class I appliance.
It comes with a short unterminated flex designed to either be spliced into the lighting wiring in the attic or to have a plugtop fitted if a socket is available. One way or another, electrical wiring is required, but here’s what the manufacturer/supplier says on their website:
- “The Lofty is designed to be simple to install and requires no specialist knowledge at all”.
- “Any reasonably handy person will find the enclosed instructions a breeze to follow and will compete the job in less than an hour”.
- “[Can be] fitted into the loft space in around 45 minutes”.
- “Beware of contractors offering to supply and fit one of our machines for astronomical sums of money. We regularly receive calls from customers telling us they have been quoted sums of anywhere between £600 to £800 plus VAT to install a Lofty!”
Say what now??
Unbelievably, what we appear to have here is a manufacturer stating that the installation of this fixed electrical appliance can be achieved without the specialist knowledge of pesky overcharging electricians as it’s a simple DIY task or one for a handyman.
Insert. Red. Mist. Here.
To be fair, the actual installation instructions enclosed with the device, and which are also downloadable from the Breathing Space website, do state “the unit must be wired by a qualified electrician’, so this contradicts the advice presented at the point of sale which explicitly states no specialist knowledge is needed and that installation can be performed by a 'reasonably handy' person. I know the wiring regs flits between competent and skilled persons, but I've never seen a definition for reasonably handy! The danger with statements such as these are that it sets up an expectation by the client that there is little or no skill or danger involved, so they may elect to undertake the installation themselves or to appoint the wrong kind of installer for the work. Most of these fans will be spliced into lighting circuits which were not routinely RCD protected until the 17th Edition wiring regulations came out in 2008, and in many cases there are still lighting circuits out there with no earthing, but this is a Class I appliance so what does a DIYer or handyman do when there’s nowhere to connect the protective conductor? Well, from my experience they just chop it off. A manufacturer suggesting a homeowner either has a crack at the electrics themselves or calls on their DIY-mad mate armed with his Aldi battery drill and non-VDE screwdriver set is asking to be taken to court by anyone who has ended up with a shock injury or fire damage as a result of such ill-considered advice, especially on circuits lacking appropriate fault protection, additional protection or with the danger of a borrowed neutral on the landing light that your average DIYer would know nothing about.
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As the instructions do require a 'qualified electrician' to install this product, appointing a handyman or having a homeowner undertake the work themselves would allow Breathing Space to duck out of any warranty responsibility should the thing pack up as they can say it wasn't actually installed according to their instructions. Similarly, if it catches fire or electrocutes someone as a result of improper installation, Breathing Space can cover their arse with the Health & Safety Executive to a certain extent by pointing out their instructions were not followed by their customer.
So, let’s say the client does appoint an accredited electrician to undertake the work. Breathing Space claim their helpline 'regularly' receives calls from customers who are being quoted £600 - £800 for supply and installation which they consider to be ‘astronomical’ figures. Are such prices unreasonable? Well, I’d say no, and that is probably why they are receiving these calls so regularly. If the regular feedback is that it costs more than they think, then maybe the average installation isn’t as straightforward as they imagine, in which case they need to re-evaluate what is actually going on out in the real world. The fan unit itself as supplied by this company costs £399 with VAT. If the homeowner is purchasing it directly, then that’s the price they pay, but if I’m supplying it then I’ll put a mark-up on it to cover my time in sourcing the item, delivery of it to the client site, acceptance of the ongoing warranty support and, dare I say it, even a little bit of profit for the business, after all I’m not a charitable operation here! I have a 24-month no-quibble on-site warranty for anything I supply, so the percentage I add on helps to cover the odd occasion when I need to go back to a site to repair or replace an item that has failed prematurely. There's nothing new or controversial there, every link in the supply chain will add on a sum to cover their operational costs, ongoing risk and a little profit. It’s not like Breathing Space are flogging these fans at cost price, and at £399 I suspect their mark-up is going to be fairly tidy itself. My mark-up on materials is usually between 10 and 25 percent depending on the item and the likely risk of failure. As I’m not terribly familiar with this particular brand and product, and as it has moving parts which will one day fail, hopefully after a long life, but only time will tell, then my mark-up may be nearer the higher end, but let’s be kind here and call it 10%, in which case the resale cost to my client if I sourced the item would be £439.
Breathing Space make claims of installation at ’45 minutes’ or ‘under an hour’ but is that realistic? Well, no and this is likely to be why they have customers phoning up about higher than expected installation quotes. How can any fan manufacturer make a claim for the installation time when every site is different and has to be taken on its own merits? Practical considerations in the construction of the ceiling, accessibility and condition of the loft space, condition and suitability of the wiring and of the wider electrical installation all need to be taken into account, and there are additional component parts which need to be supplied and fitted as the instructions require the fusing down of this appliance either through a plug and socket arrangement or, more likely, a switched fused connection unit. Yesterday’s installation took me and Nigel two hours. Add on the materials for the junctioning, wiring, pattress, fused spur etc. and if I had also supplied the fan itself then you soon get to a cost figure bordering on what this manufacturer considers to be ‘astronomical’, but then they’re making the unreasonable assumption that all installations take 45 minutes charged for at an unqualified handyman's rate. I charge more than a handyman would, but that’s because I’m qualified, insured and accredited, I am overseen by four external organisations who have independent complaints and dispute resolution procedures to protect my clients if they have any complaints, I do a proper job that’s compliant with the wiring and building regulations and my workmanship is backed up by an in-house (non-insured) warranty and by an external insurance-backed option. If the job takes two qualified and experienced installers two hours to do properly, then who are Breathing Space to be telling my potential clients that it’s a piece of piss which any idiot can take care of in 45 minutes? My client may have ordered this item based on the assumption of the installation cost being at a one-man one-hour rate, but now she has an invoice for two-men over two hours. This risks making me look bad; my client may think I’ve strung the job out to charge her more when in fact we've worked diligently to ensure a safe, high-quality, trouble-free installation.
The ridiculousness of a manufacturer of this kind of equipment making claims about installation time is staggering. There are too many variables when installing this product; they can’t just blag that it’s quick n’ easy in every circumstance! As for stating no specialist knowledge is required, even if we discount the electrical side, the practical mechanical installation isn't straightforward for most people. Cutting a 200mm circular hole into a lathe and plaster ceiling or custom cutting and fitting battens to support the weight on plasterboard will likely be outside the comfort zone for many homeowners who may lack the holesaws, padsaws, decent drills and sturdy ladders a professional keeps on the van. Existing smoke alarms may have to be relocated, specialist access equipment may be requried, asbestos products may have to be worked around and loft boards cut and lifted. Anyway, to cut a long rant short (too late perhaps), I’ve put these points to them in the email below. Let’s see if Breathing Space are wise enough to rethink their advice to customers. If you're thinking of buying one of these things, maybe get in a few quotes for the installation costs first to avoid any surprises after you've taken delivery of your four hundred quid fan!
To:
Good afternoon.
I am an electrical contractor who was appointed to install one of your Lofty Remcon units for a client yesterday. An interesting product, in fact I am considering one for my own home, although I'll wait to see what my client thinks of hers first.
As I am interested in this item, I took a look at your website where I was rather dismayed to find you making claims of easy installation requiring 'no specialist knowledge at all' with it being possible by 'any reasonably handy person' in as little as '45 minutes'.
As a manufacturer and/or supplier of electrical appliances, I would suggest that stating such is potentially dangerous to yourselves and to your customers. It is certainly true that nobody is under a legal obligation to use an accredited contractor to undertake electrical alterations on their own home, but a manufacturer/supplier should always suggest that installation is performed by persons qualified to do so at least in order to cover themselves against an unfortunate outcome as a result of work being undertaken by someone lacking in the ability to do it right. Suggesting it is a simple DIY job or one for a handyman may lead to an improper installation with the risk of shock or fire. Someone facing prosecution for having caused injury or damage as a result of poor workmanship may well point their finger back your way at your claims of simplicity with no specialists needed.
I also take issue with the 45 minute installation claim which could only ever apply in the very best of circumstances. It took me and my colleague two hours to install your unit yesterday as we were faced with an overboarded lathe & plaster ceiling, we had to install a switched fused isolator outside the loft both for overload protection and so the client had an accessible means of isolation, and we performed the necessary electrical testing and certification which means we warranty the workmanship of the installation and accept the ongoing legal liability for the safety of our work. Suggesting to prospective buyers that installation is quick and simple is misleading and may result in customers feeling ripped off by the professional trades when they receive the invoice for the actual work involved. I could perhaps install this product in 45 minutes if it was a simple plasterboard ceiling with a non-boarded, non-insulated, easily accessible loft above it and if an electrical source was close by and no fused isolator was fitted. I would imagine this product is more likely to be installed in older properties where retrofit energy saving measures such as double glazing, loft insulation and cavity wall insulation are causing airflow and condensation issues, and such properties are more likely to have lathe and plaster ceilings and filthy awkward loft spaces. With the custom battening requirements for this product, I doubt many installations, if properly undertaken, come close to this 45 minute claim.
My invoice for yesterday's work came to £184.88 inclusive of VAT and materials which I consider to be a reasonable price based on the labour rates published on my website, but I notice you list pricing that you believe to be 'astronomical' charged by other contractors on other installations. I would advise against informing prospective customers on pricing you believe to be out of line, and instead encourage them to shop around for competitive pricing from legitimate local installers. You believe £600-£800 for installation is unreasonable, but you're not in a position to review any given installation. What if the loft is boarded and/or filled with contents that require removal? What if vermin are or have been present? What if the lighting circuit has no earth - the Remcon is a Class I appliance after all, but the practicalities of getting a working earth to the loft for fault protection may be difficult. What if the lighting circuit you want to splice into is in poor condition and unsuitable for modification? In this case, remedial work may be required beforehand or even a whole new circuit may need to be installed, maybe even from a new secondary consumer unit in order to comply with the regulatory requirements for RCD protection. If an installer is faced with these circumstances, then the bill will be higher. Had I also supplied the Remcon unit yesterday, then my invoice would have been £184.88 plus the £399* price the Remcon currently commands which would bring my invoice to £583.88, just shy of the lower end figure you consider to be 'astronomical'.
Your assumption that every installation should be quick and simple is nonsense. Leave it to we professional electrical installers to figure out how quick or easy a job may be and to price it accordingly. I spend a large amount of my time, and my clients spend a large amount of their money, righting the wrongs from bad DIY/handyman installations. While it can be relatively simple for someone to connect a brown and blue wire to get this item working, that doesn't mean it's been done safely or properly. There's a world of difference between a quote from a proper accredited electrician who has to run this thing from a new RCD protected circuit for a safe installation that is compliant with the wiring and building regulations and an ignorant handyman who intends to just splice it into old rubber non-earthed cabling using a non-enclosed choc-block with no fused isolator and no certificate to accept liability.
Even if it is a straightforward installation and a contractor wants to charge £800 for it, the client is under no obligation to accept that price and is always free to shop around. It's not your position to decide what anybody else's time and expertise is worth, as installers it's up to us to figure that out, and it's the responsibility of our clients to ensure they know what they're getting for their money. Perhaps you think my advertised labour costs are unreasonable, but that's immaterial, you're just the hardware supplier, not the guys on the ground performing the installation work. I know what I have to charge to make my business work and I'm not interested in your opinion on my pricing. I certainly don't want you giving misinformation to my potential clients on how simple the job should be site unseen or telling them that some unqualified non-accredited uninsured handyman can do it cheaper by cutting corners on safety.
On the subject of pricing, I might add that you're charging £399 for a fan, the manufacture cost of which will be a fraction of this amount while your own mark-up is quite healthy I imagine, so perhaps watch out for your own glass house before hurling stones at the installation prices levied by professionals such as myself.
Do please change your website's advice, it could be interpreted as bordering on reckless.
Kind regards,
David Savery.
**Assuming the Remcon unit was supplied at cost price and with no mark-up.
Update, 10/04/18
A month on and no response, which is perhaps no surprise. The following follow-up has been sent to Breathing Space today...
To:
Good afternoon.
Following on from my previous email which you decided not to respond to, I didn't buy one of your Lofty Remcon products as the eyebrow-raising statements you make at point of sale regarding installation left me wondering if any of the other claims you make about any of your products can be believed. Instead I bought a Nuaire DRI-ECO thing, although as it turns out they also make a ludicrous claim on installation time ("Easy & simple installation - Under one hour"). It took me about three hours to install this on my own home with a known electrical installation, plasterboard ceiling and non-boarded attic, about as ideal as conditions get. Still, at least Nuaire don't make judgements about actual installation costs for sites they've never seen which is the real bone I have to pick with you.
You know, it's interesting how similar your website is to the Nuaire site - almost like you lifted their look and feel, but then knocked an arbitrary quarter-hour off their installation claim to make your product look more appealing. Both products have about the same installation requirements and are never likely to be installed in under an hour.
Consensus on Twitter amongst other electricians I've canvassed is that 3 hours is about what's needed for these kind of products, from turning up at site to putting the ladders back on the van upon completion. If I'm asked to install another Nuaire then that's what I'd set aside in the diary for it. If asked to install another Breathing Space product then I would have to tell the client that I'd decline the job as claims made at point of sale may have misled them into thinking it would be quicker and cheaper than it may end up costing. I wouldn't want any unrealistic expectations to cause arguments when the invoice lands.
Here's a free of charge offer I'm prepared to make for you. Check your client database for the Lofty Remcon products you've sold in Warwickshire, then contact those clients and ask them if they were only charged for an hour's labour on installation if they got someone to fit it for them. Ask if they'd be happy to have the installation surveyed. If so, I will go out at no cost and evaluate the installation for you to see if there has been any breach of safety. I'd look for missing earths, fuses not fitted, exposed conductive parts inadequately enclosed, installation adjacent to smoke detectors, security of fixing to ceilings, presence/disturbance to asbestos materials, improper/inadequate wiring, improper certification and any other shortcuts a bad electrician or an ignorant handyman may have made to minimise time and costs.
Somehow I doubt you'll take up my free offer for your valued customers. I doubt you'll find anyone who was charged under an hour's labour for fitting this product, and you'd be concerned that if I find any poor installations then you may be partly liable for them because of how it was sold. If you believe 45 minutes is a normal installation time, and that it is cost effective for an installer to install this equipment in a fully compliant manner in that time, then why not put together your own installation team to go out and fit this product?
I suspect you wouldn't be in business for long if your own people were out there charging one hour for labour per fitting.
Kind regards,
David
Additionally, as a Which? Trusted Trader, I have today forwarded to Which? the details of all this. I don't suppose much will happen, but we'll see if they have anything to say about Breathing Space's dubious point of sale blarney.
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