Hello Dougie,
I'm not disputing what you are telling us, but if the inference is that by April all CC sites and others will be asking for the PIR certificate then I think the organisations have shot themselves in both feet.
You point out; if it is supposed to be enacted by April, then the vast majority of caravanners will have no time to get the PIR's carried out simply because they take so long (4 hours?) and the workshops who are accredited to do them will be swamped not only with PIR work but the normal seasonal services and repairs.
It does not help that the organisations involved have failed to make the caravanning public aware of the situation or of what is involved and the cost.
It is also clear from this thread, that even within the industry there are some who find the problem has not been quantified, the general knowledge of the caravanners who post here (and on other sites) seems to suggest the level of incidence involving contravening the electrical regulation the PIR is supposed to detect is both very low and the consequences have been minimal. How many caravans have had systems that would not be approved to connect to a mains supply, and how many of those have caused injury or loss? So where is the risk assessment? Is the proposal a disproportionate response to a problem that has not been defined? Sledge hammer to crack a nut seems to be a very apt analogy.
The risk assessment needs to be defined and published otherwise its going to be another committee derived matter like the 85% towing ratio, the 7% nose load, which are misleading, often impractical and out dated.
Then of course there is the issue that if an installation is failed at its first PIR (after three years) due to a manufacturing design fault, who is responsible? And who pays to have it corrected? I suspect that the manufacturers are concerned with probability that they will be facing repair bills for their incorrect installations - and the possibility that consumers may be considering suing manufactures for placing them in danger as a result of the work that they sign off, on their production lines electrical completion certificates.
If the requirement for a PIR type test and certificate is to be rolled out, then the whole process needs to be re-planned with proper timely information supplied and consultation with the caravanning public, not the 'fait accompli' approach that seems to have been used.
Personally I agree with the principal that all trailers should be reviewed regularly for safety issues, (running gear, gas, electrics etc) and be issued with an insurance certificate of some kind - rather like an MOT.