Competence and Gas Safety
Over the past two years we have been reviewing the safety of gas installations in new build and refurbishment projects. This was initiated in the light of some fatalities caused by CO poisoning as well as explosions. Of particular concern is the fact that there are some 50,000 gas fired boiler installations in new-build housing developments with concealed concentric push-fit flues that cannot be routinely inspected. The Health and Safety Executive have stated that the problems caused by the use of concealed flues arose as a result of "failures amongst designers, builders, boiler manufacturers and gas engineers". Over 1,200 installations that had been commissioned by Gas Safe Registered Engineers have been declared "immediately dangerous" on inspection.
Over 25 % of the at-risk gas fired boiler installations are in the rented sector and subject to annual inspection and the issue of a "landlord's gas safety certificate". Where the flue cannot be inspected because it is "boxed in" it should not be declared fit for purpose and given a certificate.
The Construction (Design and Management) Regulations 2007 are applicable for all construction work including the installation, commissioning, maintenance, repair or removal of gas services which are normally fixed within or to a structure. Regulation 4 - Competence states:
No person on whom these Regulations place a duty shall -
a. Appoint or engage a CDM co-ordinator, designer, principal contractor or contractor unless he has taken reasonable steps to ensure that the person to be appointed or engaged is competent;
b. Accept such an appointment or engagement unless he is competent;
c. Arrange for or instruct a worker to carry out or manage a design or construction work unless the worker is-
1 competent, or
2 under the supervision of a competent person.
It would appear that in a number of cases someone in the chain of duty holders has failed to adhere to this regulation as clearly some of the finished installations are defective and potentially exceedingly dangerous. The designer certainly should have determined the most suitable flue and specified how and where it would be installed. The designer would probably have been an architect, but he would have almost certainly relied on a mechanical services engineer who should only have taken on the design responsibility if he was competent. The mechanical services engineer could well have relied on the heating engineer carrying out the installation. The mechanical services engineer might have presumed the heating engineer was competent if he was Corgi registered or a Registered Gas Engineer on the Gas Safe Register.
The Gas Safe Register is kept and managed by Capita on behalf of the Health and Safety Executive but it is only a register. In order to obtain registration applicants are required to have passed an accreditation examination and have had practical experience. The knowledge required to become registered with the Gas Safe Register is not extensive and does not cover all of the tasks that need to be undertaken with gas fired boiler installations. Some people are being registered having completed a "fast track" course with very limited practical experience. The level of competence obtained by practical experience is not the subject of individual assessment by examiners.
We are of the opinion that no duty holder should accept Gas Safe Registration as proof of competence of any heating engineer carrying out the installation, commissioning or maintenance of a gas boiler unless considerable further steps and enquiries are made to ensure that the firm or person is competent.
We believe that registration with the Gas Safe Register is too easily obtainable without comprehensive verification of experience and competence. The annual subscription payable to remain on the Gas Safe Register should cover for random checks to be carried out on installations, maintenance work or commissioning of gas fired boilers, including the associated flues, by the registered person.
"Fast track" courses are a very poor substitute for comprehensive craft training.
Fellow of the Association for Project Safety