CTE HE3: daily traceability for lighting control on site
How to capture daily HE3 lighting control evidence in the site report and reach handover without rebuilding documentation in the office.
The problem
Friday, 18:30. Lighting scope close-out, level 2.
The technical supervisor asks for the functional test of the presence detectors installed on Tuesday. The daily report says "sensors installed in office area". Nothing else. No model, no commissioning check, no response under daylight conditions.
The electrician is on another site. The site manager is travelling on Monday. The client wants to certify the scope on Wednesday.
That is two hours of admin reconstruction, an awkward call to the installer, and — at best — partial certification. At worst, retention until handover and a written dispute.
The report did not fail because work was missing. It failed because it left no evidence that HE3 could be read backwards from.
Why it happens
The Spanish Building Code, CTE DB-HE Section HE3 ("Conditions for lighting installations"), sets three requirements that are easy to comply with on paper and hard to prove on site:
1. VEEI within the limits of section 2.2 (W/m² per 100 lux, by use of the space). 2. Control and regulation systems under section 2.3 — presence detection, daylight regulation, centralised management systems. 3. Functional verification under section 3, which requires checking that each system behaves as the project specifies.
Following the transposition of Directive (EU) 2024/1275 (EPBD recast, adopted 24 April 2024), monitoring and verification requirements tighten further for new and renovated non-residential buildings.
The standard is not the issue. Three site patterns are:
- Generic daily reports. "Lighting progressed on level 2." Useful for production tracking, useless for HE3.
- Photos without technical context. The photo proves the fixture is mounted. It does not prove the presence sensor disables when daylight exceeds 500 lux.
- Documentation deferred to handover. When the engineer tries to rebuild three weeks later, the installer is gone, the sensor is hidden above the false ceiling, and the functional test becomes word-against-word.
Rebuilding one poorly documented milestone costs between 2 and 4 hours of admin time. Across an entire floor, that is full afternoons in the office that never appear in the budget but always appear in the margin.
How to fix it
Treat HE3 as an operational routine, not a paperwork task. Four moves.
1) Standardise the daily report with HE3 fields
Every lighting intervention should capture, in the same report:
- Zone and drawing reference (level 2, office 2.04).
- Device installed or commissioned: brand, model, control type (presence, daylight regulation, time-based, centralised management).
- Functional test performed: what was checked (lux threshold, delay, programmed scene).
- Applied criterion: project VEEI vs. measured value where relevant.
- Result: pass / fail, with linked issue if there is a deviation.
- Responsible person and exact timestamp.
This turns the report into evidence the technical supervisor can read without phone calls.
2) Tie every photo to a technical point
A photo of a fixture does not prove HE3. The photo + the technical statement + the functional test + the responsible person does.
Simple rule: each photo in the report should answer "what does this image prove and which HE3 point does it validate?". If it cannot, drop it.
3) Close issues with full chain
When a functional test fails, document the full cycle:
- issue detected (sensor delay set to 15 min when project requires 5),
- corrective action (reparameterised by installer, date and time),
- follow-up verification (new test, pass),
- signed closure by responsible person.
Without that cycle, the client or developer can challenge the scope later, and the site manager has no defensible position.
4) Build the report continuously, not at the end
If the daily log is already structured, the weekly report writes itself. The final HE3 closeout dossier is assembled from the daily logs — not drafted from scratch. That is the difference between arriving at handover with everything in order and spending the last month "rebuilding history" from the office.
Close HE3 the day it happens, not the day it is requested.>
With OBRATEC, the engineer dictates the functional test while walking the floor, photographs the fixture, and the daily report closes the same day — with zone, device, test, result, responsible person, and timestamp. By the time final certification arrives, the HE3 dossier is already built.>
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Mistakes that cost margin
Mistake 1 — Treating a fixture photo as HE3 evidence. The photo is the start, not the end. Without the linked functional test, it proves installation, not compliance.
Mistake 2 — Closing a scope without documented functional verification. If a consumption discrepancy appears in the operating phase, liability falls on whoever did not capture the evidence.
Mistake 3 — Waiting for final certification to "tidy up HE3". Three weeks late, the installer is gone, the sensor is hidden, the test is reconstructed from memory. That is not traceability.
Conclusion
HE3 is not won in the design office. It is won on site, in the daily report.
Capturing each intervention properly takes three minutes per milestone. Rebuilding it badly takes whole afternoons and, sometimes, a retained certificate.
Teams that arrive at certification with HE3 already documented do not improvise. They just hand over.