13/01/2020

Electrical safety checks – soon with added regulation

The draft of The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020 has been laid in Parliament. The regs require a resolution of each house, so this will not be an immediate approval, but should be soon – it looks like the intention is for the Regs to be in force from 1 April 2020. (But there is some confusion in the draft regs. The ‘coming into force date is given as 1 April 2020. But then s.1 says ‘come into force 1 June 2020, to have effect for “all new specified tenancies from 1st July 2020”, then existing tenancies from 1 April 2021. Which is either the usual year’s grace, or isn’t, depending on which in force date is right. I presume this will be clarified before the regs are passed).

From the draft, there will be a requirement on private landlords (save for specified exceptions) to ensure that an electrical safety check is done before the commencement of the tenancy (for all new tenancies after the Regs are in force), and for every existing tenancy, by 1 April 2021. Then electrical safety checks are to be done no more than every 5 years thereafter,

There is a constant obligation on the private landlord to “ensure that the electrical safety standards are met during any period when the residential premises are occupied under a specified tenancy;”.

The check must result in a report giving the results and the date of the next inspection, and this must be supplied to the tenant within 28 days. If the Local Authority request a opy it must be provided within 7 days. Copies must also be provided to prospective tenants on request, and to new tenants before taking occupation.

Any remedial works must be done within 28 days, or whatever shorter period specified in the report (with written confirmation of work done).

Now, enforcement…

Enforcement is by the Local Authority, by ordering remedial action or urgent remedial action. The penalty for breach of such an order is a ‘civil penalty’ (as per Housing Act 2004 and Housing and Planning Act 2016) of up to £30,000.

But this ‘up to £30,000 penalty’ also applies to any duty under Reg 3. So the Local Authority can levy a penalty on the landlord for failing to provide the tenant or prospective tenant with an electrical safety certificate at the required times. (There is the usual appeals process for such penalties, and a way to appeal remedial action and urgent remedial action notices.)

The options for the tenant are less straightforward. There is, for instance, no restriction on the ability for the landlord to serve a section 21 notice (probably sensibly, in view of the Govt’s intention to end section 21 – maybe this is a precursor of the financial penalties that might replace the restrictions on serving a s.21 on other matters). But Part 6 of the regulations adds a new condition to mandatory or additional or selective licenses (via Schedule 4 Housing Act 2004) to the effect that:

(c) where the house is in England, additionally—

(i) to ensure that every electrical installation in the house is in proper working order and safe for continued use; and

(ii) to supply the authority, on demand, with a declaration by him as to the safety of such installations;

Breach of condition of a licence under s.95 Housing Act 2004 is a Rent Repayment Order offence, so I think (on a first look) – as things stand – that a tenant’s application for a rent repayment order may be possible where the property is subject to licensing, but not otherwise. If that is the case, I’d suggest it doesn’t make an awful lot of sense to restrict possible RROs in this way. But it is only breach of s.95(1) that is a RRO offence – not having a licence when required. s.95(2) – breach of licence conditions is not an RRO offence, so there is no RRO possible on breach of the electrical safety regs.

Otherwise, I don’t think the tenant has much recourse (or compensation) beyond a complaint to the Local Authority – save, of course that an unsafe electrical installation will fall under s.9A, and possibly s.11, Landlord and Tenant Act 1985.

Some tenancies are excluded from the regs – private register providers of social housing, lodgers, tenant sharing accommodation with landlord’s family, long leases, student halls of residence, hostels and refuges, cares homes, hospitals and hospices, and other NHS provided accommodation.

If I’m honest, I’m not sure why half or more of these are excluded, nor why council tenancies aren’t included. But there we are.

And I must say, about time! These regs have been rumoured for literally years and are much needed.

 

 

Giles Peaker is a solicitor and partner in the Housing and Public Law team at Anthony Gold Solicitors in South London. You can find him on Linkedin and on Twitter. Known as NL round these parts.

41 Comments

  1. ROBERT CROSSLAND

    I wonder if this could apply to commercial buildings occupied by “property guardians”?

    Reply
    • Giles Peaker

      Almost certainly not. Specifies tenancies.

  2. Ben Reeve-Lewis

    That was my immediate thought as well Robert. Property Guardians. I know a couple of ‘For profit’ PRPs as well, who are anything but social in outlook and why exclude occupants of care homes, refuges etc? Dont they deserve protection? I also foresee an increase in the common tactic of rogue landlords arguing, “Its a care home/refuge/hostel/holiday let/lodger/not an HMO” delete as applicable

    Reply
  3. Orson

    Excellent news, not …..but I don’t expect that the buffoons in suits that have been pushing for this for ages have given a single thought to where the electricians to carry out the tests are going to magically appear from? I use three electricians (that I trust to do work correctly)…. one has said that it’s not the type of work he wants to do at all and won’t be taking any on. Another said he’ll fit it in around his day to day jobs so may be two or three tests a week. the third said he may set aside a day a week for testing if it can pay for itself, which is doubtful. So please tell me where all these sparks are going to come from? Btw go any of you have the foggiest idea how long an average test in say, a three bedroom house take……..no, thought not.

    Reply
    • Giles Peaker

      You are complaining about £40 a year, or less? For an inspection every 5 years? That is really quite some top level complaining.

    • Sparks

      Sorry Giles, you don’t really understand the practicalities of this.

      “Then electrical safety checks are to be done no more than every 5 years thereafter”

      Is simply incorrect;

      http://www.legislation.gov.uk/ukdsi/2020/9780111191934
      “(a) at intervals of no more than 5 years; or
      (b)where the most recent report under sub-paragraph (3)(a) requires such inspection and testing to be at intervals of less than 5 years, at the intervals specified in that report.”

      EICR’s are often given 12 monthly intervals, especially on older properties.

      Making daft statements about landlords killing tenants helps no-one.

    • Giles Peaker

      I think rather than ‘simply incorrect’ you mean correct but incomplete. The requirement at a) is that the check must be done within the next 5 years.

      The post was a quick introduction, not a comprehensive analysis – that will wait for the final approved regulations. So it is ‘headlines’ only.

      And, well, tenants have been killed by unsafe electrical installations. I actually said surely any responsible landlord would want to be sure they weren’t at risk of killing their tenants. That seems to be a fairly uncontentious statement to me, so I’m surprised to see you arguing with it.

    • wrhite

      Where could they come from? [thinks…] Are there any neighbouring countries that could fill the vacancies? In the EU perhaps? Oh…

  4. Alex

    A proper through test of a three bed house with which you as a spark do not have a previous report for and with whose wiring you are not familiar will take at least half a day and probably cost upwards of £200

    Reply
    • Giles Peaker

      And that lasts 5 years, with the subsequent reinspection being cheaper? £40 a year for the first 5 years? And less thereafter?

      Wow. Such hardship. Where of course any responsible landlord would in any event be having checks, just to make sure they ween’t at risk of killing their tenants.

  5. David Heal

    Giles why have you assumed that anybody is complaining about the cost? The question raised by Orson was where all the electricians needed to carry out the work are going to come from.

    Reply
  6. Simon BB

    It’s not about the costs. Most of my houses are HMO’s and we have a **continuous** problem with getting electrical safeties actually done by the sparks. We now chase 3-4 months before expiry to make sure there is no gap.

    The underlying issue is that the sparky is putting their career on the line for wiring they cannot see and have never seen. Additionally 99% of all houses no longer meet the current electrical regs (as they change every few years). So a consideration needs to be made in regards to this as well. Also consider that electrical safeties is not normal business for a sparkly, so it’s going to be a massive upheaval for the rental market.

    For a gas guy, the pressure test + boiler + appliances is fairly straightforward. The annual pressure check is fairly straightforward, but certifies the whole pipe work from a ***single point***. For the sparky on a house 70 years old – how much wiring was carried out personally by a prior owner in the loft for a single bulb that was poorly done? How is this even checked?

    It’s going to be an interesting few months…

    Reply
    • Giles Peaker

      Fair point. I was picking up what Alex said. But compared to gas inspection, this is once every 5 years, not annual, and I would think relatively quick and simple after an initial inspection (subsequent inspections would be entitled to rely on the findings on the nature of the installation in the first, I would think).

      The relevant standards are specified in the draft regs:

      “electrical safety standards” means the standards for electrical installations in the eighteenth edition of the Wiring Regulations, published by the Institution of Engineering and Technology and the British Standards Institution as BS 7671: 2018(5);

      So, as things stand, any future changes to standards would not apply unless and until incorporated into the regs by amendment.

  7. Tom

    Not read the draft but I would be interested to see how/if they define ‘remedial works’ as observations are coded in order of severity on reports from (something like) immediate danger of death to would look much nicer if…

    Reply
    • Giles Peaker

      Required to meet safety standards.

  8. John-Paul Keates

    There are 1.9 million properties affected and about 15 months to do them in.

    Getting the work done is going to be impossible – most properties won’t pass the first time, because the standards changed in 2018 to require a higher spec metal consumer units rather than plastic, which was previously the norm.

    So there are going to be roughly two call outs per property all of which have to be done by next April, then almost no inspections for five years and then they’ll all need doing at the same time again.

    Anyone know of decent electricians with that any available capacity?

    Forget the cost, the implementation is just badly thought through.

    Reply
    • David Heal

      According to the ONS the number of households in the private rented sector in 2017 was 4.5 million so even allowing for multiple occupation of some properties, 1.9 million is likely to be a significant under estimation.

      I understand that there is also a new requirement for Arc Fault Detection devices to be installed – I had a new metal consumer unit installed in one property in 2019 following an EICR but as far as I am aware it did not include AFDDs. In another property the electrician did not consider it necessary to upgrade the consumer unit as no other electrical work was being done so in each case a further full inspection within a year will be required. There may well be further changes of which I am not aware.

      MCHLG have apparently given “assurances about capacity in the supply chain” – wishful thinking gone mad.

    • Orson

      Exactly my point, some sparks won’t even entertain this testing work because its bloody boring work that doesn’t pay particularly well. Getting the properties tested in the timescale is an impossibility. This is what happens when you allow buffoons in suits that have never got their hands dirty in their lives (but probably have a First from Oxford in ancient Greek) to meddle in technical matters that they just don’t understand.

    • Michael Barnes

      I have been reading posts on a Sparky site regarding these regulations and the ‘availability’ of sparkies to do the work, and many of them are saying they are not qualified to undertake the inspections and will not be undertaking the additional training required to enable them to do so.

  9. Simon BB

    The plastic consumer units are ok if the rest of the installation meets regs (or easily meets regs – i.e. can easily install RCD components for example) – this will be judgement call for the “Qualified person” carrying out the work. On the EICR report it will mention any items that don’t meet the standard, but are ok to keep on using (C3).

    – Just looking at an EICR I had carried out in Oct 2019 for one of my HMOs, the report marked the plastic consumer unit as a C3 item (ok to keep on using, but not current regs). So this should be ok as long as the rest of the installation is **satisfactory**.

    I’m now planning to arrange EICR reports for all my non-HMO rentals in the next month – I would rather be ahead of the game and under existing rules vs any quirks in the new rules once they go live in June (assuming this becomes law of course!). Welcome to 2020! ;-)

    Reply
    • David Heal

      I fear that your interpretation is not correct. The draft regulations stipulate:

      “electrical safety standards” means the standards for electrical installations in the eighteenthedition of the Wiring Regulations, published by the Institution of Engineering and Technologyand the British Standards Institution as BS 7671: 2018

      3.—(1) A private landlord who grants or intends to grant a specified tenancy must—
      (a)
      ensure that the electrical safety standards are met during any period when the residential premises are occupied under a specified tenancy;

      This means the end (but only for rented properties) of the currrent pragmatic approach that upgrading of an installation which complies with previous standards and is still in good condition is only required if it is being modified or added to. I hope I am wrong but this probably means that what is now coded C3 will attract a requirement to carry out remedial work

  10. Simon BB

    I will contact the Ministry of Housing, Communities & Local Government for confirmation. Lets hope for the best, your scenario is not deliverable as the majority of housing stock across the UK does not have metal consumer units (for example) and this is a NOT a simple change.

    Reply
  11. Simon BB

    Update – a quick call with the Ministry confirmed that this legislation is just extending the requirement for EICR reports to cover the whole residential lettings sector.

    – They don’t expect the current EICR testing regime to change and my existing EICR reports are valid and should return the same results if I asked for them again post the law going live (assuming the electrics inside the property have not changed and the prior report was generated post the IET 2018 standards change going live).

    Obviously, the devil is in the legal detail and to cover my back***e (and this is a legal blog – thanks to Giles for this existing at all!) – Ring up/contact the ministry yourself if you still have concerns and want further clarification.

    Reply
  12. David Heal

    Interpretation of the phrase “ensure that the electrical safety standards are met” is key and will require a detailed look at the wiring regulations. If code C3 will still be permitted and my two EICRs from 2019 remain valid, that will be a relief, but I am not holding my breath. Legislation does not always achieve what Government intends or expects.

    Reply
  13. Simon BB

    I did discuss C3s with the Ministry and their view is that this stays as is – i.e. C3 = Improvement recommended, but not required.

    Reply
    • Giles Peaker

      I would say keep a careful eye on the regulations when they are finalised. What the MHCLG say is the intention and what the regs legally do are far from being definitely the same thing – witness the history of the deposit scheme rules.

    • David Heal

      In that case why have they defined the required standards by reference to the 18th edition regulations?

  14. Giles Peaker

    The specified regulations *will* be the threshold for what constitutes safe, at least on the current wording.

    Reply
    • Orson

      So every CU pre the 2018 18th edition will be deemed unsafe, that’s literally millions of CU’s. These clowns really have no idea what they’re doing, do they.

  15. Bev Shields

    It’s not only the CU that will need changing. The new 2018 18th edition calls for many new requirements for circuits, zones, energy loss from cables, no plastic clips or conduits and many other items which will probably mean a rewire for most properties. With tenants in situ, walls and floors to be chased, lack of electricity for periods, massive upheaval, the mind boggles. Eviction and or sale of the properties will be the result. This really will be the last straw for Landlords.

    Reply
    • Gerard

      Hi Bev. Just to clarify. I’m an electrical contractor and also a small landlord. The consumer units, if plastic, don’t need to be changed as it is a recommendation (C3). This doesn’t affect the safety of the installation. If the cabling in the property is twin and earth, there is no need to rewire. The plastic, or non combustible issue is to protect against premature collapse in the event of a fire, so not typically relevant in a domestic situation. Hope this helps.

    • Michael Barnes

      Gerard,
      The issue is not what the electrical regulations say, but what the proposed regulations say about the application of the electrical regulations to PRS property; in particular 3(1)(a).

      As written, 3(1)(a) could be interpreted as requiring the electrical installation to be brought up to 18th edition requirements for new work (i.e. include C3s and Observations in items requiring remedy).

      What I believe 3(1)(a) is trying to say is “anything that has given or would give rise to a C1, C2, or F1 categorisation under an inspection to the electrical safety standards must be addressed”, and I cannot see that there can be any reasonable objection to such a requirement.

      BUT what is important in law is what the regulations say, not what the authors intended them to mean.
      It is the wording that will be considered by judges and used by the lawyers of anti-landlord organisations such as Shelter.

      @Simon BB
      If you have the ear of the Ministry, then perhaps you could explain the legal position regarding the intention and the actual wording of the regulations to them, and also point out that the disruption that remedial work might require could mean that landlords evict blameless tenant form electrically safe homes in order to comply with the regulations as currently written.

  16. Orson

    I doubt that any of this has dawned on the buffoons in suits, clueless as usual.

    Reply
  17. Orson

    Regarding the photograph at the heading of this article, you do realise that EICR’s apply to only fixed installations and whilst the extension lead in the photo with numerous dodgy appliances attached to it is obviously not desirable it would be outside the scope of any testing regime. This is extremely misleading, you should take it down.

    Reply
    • Giles Peaker

      Dear Orson. You will be shocked to learn that this post – https://nearlylegal.co.uk/2019/12/sibylla/ – does not contain any actual prophecy, despite the header image. What is more, this post – https://nearlylegal.co.uk/2020/01/tenancy-deposit-unserved-prescribed-information/ – is NOT ABOUT THE PROPERTY IN THE PHOTOGRAPH! Even worse, the picture in this post – https://nearlylegal.co.uk/2019/12/apres-nous-le-deluge-rents-and-water-resellers/ – does not show an actual employee of the Royal Borough of Kingston upon Thames selling water.

      We expect our readers to have some small degree of intelligence, imagination and humour, and not to be tediously literal-minded. I’m very sorry if you feel yourself unable to meet our modest expectations, and I’ll take steps accordingly.

    • Sparks

      “you do realise that EICR’s apply to only fixed installations”

      I doubt even the suits driving this realise that.
      Any knowledgeable debate is automatically closed down with ‘evidence’ pictures like the above and emotive wails about tenant safety.

    • Giles Peaker

      *Sighs* They not only realise that, they actively specified it. It is what the regulations actually say, carefully and deliberately.

      And the photo is not ‘evidence’. It is just a picture. Because sometimes we add pictures to our posts.

      If this is the standard of ‘knowledgeable debate’ you produce, I’m not entirely surprised you get ignored.

    • Michael Barnes

      Unfortunately that is the type of obviously-staged/irrelevant picture that landlords have become accustomed to being used for landlord-bashing by the likes of Shelter. The other pictures you mention do not have the same emotional connotations.

  18. richgreenhill

    HMSO have today issued a correction slip:

    “Page 1, in the italic coming into force cross-heading: ‘1st April 2020’ should read ‘1st June 2020’.”
    http://www.legislation.gov.uk/ukdsi/2020/9780111191934/resources

    (As the customary italic date headings are not strictly part of the regulations themselves so have no legal force, MHCLG can get away with a correction slip rather than having to withdraw the draft regulations and lay a revised draft before Parliament.)

    So that clears up one aspect of confusion. MHCLG’s Explanatory Memorandum still misleadingly states: “existing tenancies will come into scope after one year” (para 12.12), meaning 1 April 2021 not one year after the regulations come into force.

    It remains bad drafting for the regulations to have a commencement date (1 June) earlier than the earliest supposed date of application (1 July for tenancies granted on or after commencement). If a tenancy begins in June, is the reg 3(1)(c)(i) pre-tenancy inspection requirement meant to apply or not?

    And the definition of “qualified person” is vague if not circular as to who should conduct “inspection and testing” and any consequential “investigative or remedial work”: “a person competent to undertake the inspection and testing required under regulation 3(1) and any further investigative or remedial work in accordance with the electrical safety standards”.

    The Explanatory Memo alludes to the need for this to be clarified (para 12.10):

    “Carrying out an inspection of electrical installations is a complex task that requires an extra level of qualification and competence achieved beyond the standard 4-year vocational route commonly followed by qualified inspectors and testers. Therefore, Government will develop, with industry experts, new guidance for landlords stipulating who can carry out the mandatory electrical installation checks.”

    Which raises more questions than it answers. Even when the promised guidance emerges, it will be non-statutory so not binding either way when considering whether an electrician is legally competent.

    Finally(!), you say in the comments above, “a comprehensive analysis…will wait for the final approved regulations” and “keep a careful eye on the regulations when they are finalised”. Without wanting to overinterpret your asides, it is well for readers to recognise that draft statutory instruments (laid before Parliament for approval by a vote of each House) are unamendable and, despite the terminology, best thought of as the final text – it being rare for such drafts to be withdrawn other than for typos, and exceptionally rare for them not to get the necessary approval when put to the vote. That said, I do doubt that this draft is satisfactory – which is not to say that I doubt that it will be approved and made into law. :) Anyway, I look forward to your further analysis.

    Reply
  19. Bev Shields

    Reply to GERARD
    Gerard on 21/01/2020 at 8:37 am
    Hi Bev. Just to clarify. I’m an electrical contractor and also a small landlord. The consumer units, if plastic, don’t need to be changed as it is a recommendation (C3). This doesn’t affect the safety of the installation. If the cabling in the property is twin and earth, there is no need to rewire. The plastic, or non combustible issue is to protect against premature collapse in the event of a fire, so not typically relevant in a domestic situation. Hope this helps.

    Yes Gerard you are correct, but the elephant in the room is “Will this legislation have the effect of requiring ALL rented properties installations to be in conformity with the 18th edition”. It appears from the draft that there is no exception, C3 will not apply, older properties will need massive amount of work and pre 2019ish installations will require the metal CU,s and Arc protection devices at least, You will know more than I, I am sure, but I am not talking details here, it is the legal outcome of the new regs that is unclear. As I read them, and other legal posters have said, the 18th edition is going to be the standard which will need to be complied with regardless, unless amended before becoming law, and this does not seem likely unless some higher authority intervenes.

    Reply
  20. David Heal

    Thanks to richgreenhill for alerting me to the existence of the explanatory memorandum. Based on my reading of this and the Draft Regulations I have sent the following email to MCHLG (still awaiting their response) and should appreciate correction/criticism if there are flaws or weaknesses in my interpretation/reasoning.

    “The draft regulations stipulate that a private landlord must ensure that the standards for electrical installations in the eighteenth edition of the Wiring Regulations are met during any period when the residential premises are occupied under a specified tenancy.

    The Regulations have been drafted in such a way that they will potentially give rise to consequences that I assume are unintended. As a landlord I have the following concerns and should appreciate your comments and answers to my questions:

    1. Inspections carried out before 1st January 2019 do not confirm compliance with the 18th edition but are based on earlier editions so will need to be repeated before the date when the Regulations apply.
    2. The Regulations impose an on-going requirement to meet the standards in the 18th edition so if it is amended there will be an immediate need to incorporate the changes. When the 18th edition is superseded privately rented property will still have to comply with it, unless it is the intention to amend the Regulations to require compliance with the new standards. If that is the case we will have to upgrade each time the standards are amended or revised. If not, we will not be permitted to have any work done in compliance with the new standards but will have to insist on the electrician working to outdated standards. Does this make any sense at all?
    3. Wiring installed before 1st January 2019 (or possibly July 2018) will probably not meet the 18th edition standards so will need to be upgraded – there is no provision for Code C3 which under the current inspection regime is used when a particular feature of the installation does not meet current standards but is considered safe to be left as it is.
    4. Some features which do not “meet” the current standards, such as wiring using the old colours do not have to be mentioned at the moment. This will no longer be the case, so many properties will require a complete re-wire even though there is no safety issue. This will in many cases require the landlord to take possession of the property under ground 6 of Section 8 of the Housing Act as such work involves major disruption and periods when the electricity supply has to be disconnected, so more homelessness for no good reason.
    5. Plastic consumer units will need to be replaced with metal ones, even though I am led to believe that consideration is being given to reverting to plastic in the next issue of the Wiring Regulations. Why have the Draft Regulations not retained provision for code C3?
    6. Electrical Installation Condition Reports (EICRs) based on inspections carried out after 1st January 2019 will be similarly invalid as they will have been prepared based on the current guidance – they will not therefore confirm that the standards in the 18th edition have been met because there will be no record of aspects that in exercise of the tester’s discretion have not been mentioned. A code C3 will become a requirement to upgrade.
    7. All this makes a nonsense of Para 12.4 of the explanatory memorandum, which states that 78% of landlords already have electrical safety checks, so they will not be affected by this cost until they are due for a new Inspection, implying that this will be phased in over an extended period. In reality, all properties will require inspection before 1st April 2021, whether or not there is a current EICR.
    8. Para 12.7 of the explanatory memorandum “There are also likely to be remedial costs associated with fixing any hazards identified in the electrical safety checks. These are not a direct impact of the legislation because landlords are already legally required to ensure there are no serious electrical hazards in their properties” is also extremely misleading and inaccurate – under the Draft Regulations landlords will be required to carry out major work to upgrade features that present no hazard at all and have happily been ignored or given a code C3 in the past. The costs incurred will be a very definite direct impact of the legislation.
    9. Where are the electricians, qualified to as yet unspecified standards, to permit 4.6 million inspections (probably many more as this figure is several years out of date) and all the resulting remedial work to be carried out by April 2021? How are landlords expected to find them? Will there be a register that can be searched by location?
    10. The Regulations say “qualified person” means a person competent to undertake the inspection and testing required under regulation 3(1) and any further investigative or remedial work in accordance with the electrical safety standards”. There is no reference in the Regulations to the “guidance” or “checklist” mentioned in paras 12.10 and 12.11 of the explanatory memorandum so they will have no statutory authority and competence will be a matter of fact to be determined in each case, giving rise to yet more confusion and uncertainty.
    11. Why do the Regulations only apply to private landlords? Is the safety of tenants in Local Authority or Social Housing of less importance? The Fitness for Human Habitation Act applies to all tenures, why not these Regulations?”

    Reply

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