Re: Its a uniquely American weakness -- or is it?
You have similar situations in the UK. I gather that any electrical work, no matter how trivial, has to be signed off by a licensed electrician.
Not correct - though the rules vary by country these days.
In England, the rules are fairly simple - anyone who is competent is allowed to do electrical work and produce a certificate for it. There is no legal definition of constitutes competent in terms of training or membership and any trade body*. in England, there are just 3 specific things that require notification (though they can still be done by someone without any formal qualifications or memberships) : replacing a consumer unit, adding a new circuit, or work within the zones of a bathroom (basically close to a bath or shower).
Wales still has the notification rules that came in in 2005, they didn't relax them as happened in England. Scotland has it's own rules.
Note that the notification requirements are notification of the work to the local Building Control department - who may insist on having the work inspected by what they consider to be a "real" electrician if the work is done by (for example) a DIYer.
* Members of certain membership schemes are able to "self notify" notified work via their scheme for hardly any cost. That gives them an advantage as notifying via the local Building Control dept typically costs between around £200 and £400 !
These bodies are seen by most as protectionist "unions" who would love to see the law strengthened so that only their members were allowed to do electrical work - thus blocking out non-members and guaranteeing themselves more membership fees (which are not inconsiderable !) The sort of messages they put out are very carefully worded to mislead the general public into thinking that membership of their bodies is a requirement for an electrician to be competent. As with many areas, membership is no guarantee whatsoever - there's no shortage of examples of "dodgy" work done by scheme members. The chances of a dodgy sparky getting caught is low, and the penalties really come down to having their membership of a non-mandatory body revoked (and they could then join another).
That's all for domestic work. In a commercial environment the law is less restrictive in that there are no notification requirements. However, in a work environment there are other laws that come into play - so a business needs to apply more due diligence so they can demonstrate (if needed) that they've complied with things like the Electricity at Work Regulations. But there are still no formal qualification or registration requirements.