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MCS and the use of subcontractors: how it all works

Posted by John Martin on 9 November 2010 at 10:46 am

Who needs to be MCS approved (Microgeneration Certification Scheme) and how do subcontractors fit in? These questions are often asked by participants on QMSA's national seminar programme.

Under MCS it is the business that is approved and not the individual engineers. MCS allows a business to become approved even though it may employ no staff other than say a sales team.

The reason for this is that MCS requires the business to demonstrate that it has adequate management systems in place to control the whole process: from initial customer enquiry, through design and installation to commissioning and handover, ensuring a fully compliant installation and delivering a satisfied customer.

Therefore, it is perfectly acceptable to use subcontractors (or approved suppliers as they are described in the MCS001 document). However, in order to do so, the MCS approved business must have a written agreement with each supplier. This agreement will ensure that the necessary obligations under MCS and MIS (management information system) documents are communicated to, understood and implemented by the ‘supplier’.

Agreements include clauses relating to items such as:

  • Qualification and experience requirements (these should be as described in the applicable management information system documents)
  • The standards to be applied (for example, a supplier of solar PV will have to install in accordance with MIS3002 and the DTI Guide to Photovoltaics in Buildings 2nd edition)
  • Maintenance and calibration of tools and equipment used
  • Insurance requirements
  • Health & Safety
  • Building Regulation notification requirements

The business will need to demonstrate that it meets the inspection requirements to ensure compliance with the standards.

The responsibility for the job, regardless of the level of direct involvement that the MCS approved business has, rests with them and not their suppliers.

Under recent changes to Building Regulations the installation of the actual renewable technology is now notifiable, as well as any related works such as Part P electrics etc.  As such, businesses need to be registered for MCS and CPS (competent person scheme). This would typically be done through a single certification body as all MCS providers also provide CPS.

Gemserv requires an installation to be notified to them within 14 days of ‘setting to work’ and Building Regulations require notification through the CPS within 30 days.

Depending on the technology, planning consent may have to be obtained and for generation technologies the Distribution Network Operator (DNO) will also need to be notified of connection to the supply within 30 days (or prior to commencement of the installation depending on the system output).

About the author: John Martin is proprietor of QMSA and managing director of Benchmark Certification.

If you have a question about anything in the above blog, please ask it in the comments section below.

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7 comments - read them below or add one


phildComment left on: 26 October 2011 at 7:00 pm


I am just getting involved in PV solar systems. I am in the throes of applying for Real and MCS. I will be using a subcontractor installer but I need a workable pv installer subcontractor agreement to protect my MCS status and responsibilities. Are you able to recommend such an agreement which I could use

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sypherComment left on: 10 April 2011 at 8:29 am

Hi John, as being a PV sub contractor I find more and more company’s (4 in total) that employ in house electrical installers with no part P or 17th edition! They do not submit their installs to building control (as they have told me.) The customers are unaware they need a Part P certificate so this goes on unchecked. On the annual MCS inspection our installs and paperwork are inspected by MCS. The companies pass their annual inspection with flying colours.

It should be the other way around the engineer should be MCS approved with the engineer vetting the "Sales" company.

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GlenfenderComment left on: 29 December 2010 at 10:59 am

I would like to raise the question of the REAL Code here. We are an MCS accredited business - passed both our initial inspection and our first renewal inspection with flying colours (only a handful of minor non conformances each time and complements from our assessor) - however we are also labouring through the fall out from an inspection by the REAL Code - another body you have to be a member of in order to be MCS approved.  Having spent ages going through all our documentation again to satisfy the requirements they requested following an inspection by them, they are now raising questions regarding our use of subcontractors and our documentation on that - this is despite our being assessed by the MCS after our visit from the REAL code, and passed by the MCS.  We have been unimpressed by the way that the REAL code appears to operate - emails left unanswered, delays of months before result of inspection communicated....  I would be interested to hear of anyone else's experience of the REAL code and also any advice re subcontractors and the REAL Code.

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john burgess

john burgessComment left on: 15 December 2010 at 8:16 pm

I would wholeheartedly recommend Solinvictus Ltd. to anybody who is considering a Solar Powered system.

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John E Martin

John E Martin from QMSAComment left on: 12 November 2010 at 2:15 pm

visit the CLG website, this link takes you to the latest building regulations and specifically schedule 3 notifiable works and those approved as CPS providers for the particular work activity

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Stirling Consulting Limited

Stirling Consulting LimitedComment left on: 11 November 2010 at 12:40 pm

John, prior to compiling our last posts we spent some considerable time reviewing the MCS site. For those of us accredited with ISO is quite noticable the similarities which exist yet we do not consider a couple of lines relating to mandatory compliance sufficient to address refrigerant/recycling and selection issues - however if the client, who could find themselves prosecuted for non-compliance issue(s), is fully informed at the tender stage it could be argued that they have been provided with enough information to make an informed choice. In direct opposition to this, I note, the MCS website requires the inclusion of a performance statement to qualify the output of heat pump technology in various ambient conditions, but does not stipulate the refrigerant/recycling requirements.

I would have hoped that an organisation such as MCS could have considered the aforementioned concerns and implemented an immediate policy to clarify the position?

As I'm sure you are aware F-Gas Regulations are under review and its quite possible that the current exemption, for hermetic systems, could be modified at which point a directive would pressumably be forthcoming?


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Current Energy Solutions Ltd

Current Energy Solutions LtdComment left on: 9 November 2010 at 8:38 pm

Hello John "Under recent changes to Building Regulations the installation of the actual renewable technology is now notifiable" can you point me to a web site than can give me further information on this ?

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