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Posted
47 minutes ago, MarineHeatingSolutions said:

Yes, most modern wall-mounted regulator assemblies now have them built in. As mentioned by someone earlier, the reason why a test point directly on one of the appliances only is not ideal is that if you want to turn the appliance shut off valve off, to test the rest of the rest of system, you then don't have a test point. Ideally, you would have a test point at the regulator and one at each appliance, so you can measure the pressure drop across the pipework. The system needs to be designed for proper testing by a gas engineer, not only for the tightness test carried out during a BSS exam. While I agree that unnecessary joints in a gas line are to be avoided, this isn't really an issue if joints are competently made. It certainly isn't a reason not to install the necessary fittings for proper testing.

The issue is that, to test with a manometer at a test point, the BSS examiner will have to open the gas line at the test point. This constitutes "work" under the Gas Safety (Installation and Use) Regulations 1998, and anyone carrying out "work" on a gas installation must be certified to be competent to do so.

 

In my opinion, this is overkill for a simple tightness test. But because the wording of the regulations is what it is, the BSS can not get around instructing their non-GasSafe registered examiners not to open up test points on liveaboard boats and only carry out tightness tests with bubble testers, if available, or hire a GasSafe registered engineer to do the tightness test while the BSS examiner observes them. 

So pay 2 people instead of one. Who is going to do that

Posted (edited)
18 minutes ago, Tonka said:

So pay 2 people instead of one. Who is going to do that

 

 

That's what the BSS say you must do if you use a non approved gas examiner to do your BSS

 

keeping on the right side of the law

Boats used for residential purposes as well as hire boats* and floating businesses* (such as cafés or shops) all fall within scope of the Gas Safety [Installation and Use] Regulations (GSIUR) and as such any LPG 'work' must be undertaken by Gas Safe registered installers.

As the definition of 'work' covers the removal and replacement of a screw nipple on a gas test point, the scope of the GSIUR includes carrying out BSS LPG tightness test.

So, on a boat in scope of GSIUR, examiners who are not Gas Safe registered can only complete check 7.12.2 by either:

  • undertaking a gas tightness test using a bubble tester where fitted and correctly located; or,
  • observing the tightness test conducted by a (LPG boats-competent) Gas Safe registered installer

It is important to be aware that people who are prosecuted and found guilty of contravening the GSIUR, can face fines of up to £5000 for each offence or even jail terms for very serious breaches. The HSE and local authorities are active in pursuing people not complying with the regulations, especially where hazards have arisen.

Check in advance

If you are not Gas Safe registered, as part of your initial dealings with owners when booking the examination, please try to protect yourself by tackling the issue in advance of turning up at the mooring.

Ask if the boat has a gas system, then find out whether the boat's use will put it in scope.  We suggest the following questions:

  1. Is the boat hired out in the course of a business (This may include timeshare/shared-ownership boats where there is letting involved in some of the timeslots)?
  2. Is the boat used primarily by anyone for domestic or residential purposes (In this matter, it makes no difference to you if it is owner-occupied or rented-out)?
  3. Do you invite people on board your boat in the course of a business, e.g. is it a café or shop?

If the answer to any of the above questions is yes, then in order to carry out the BSS gas tightness test you will either have to use a fitted bubble tester, or observe a Gas Safe registered installer carrying out the test with a manometer. 

Even if the answer to all the questions above is 'no', you are recommended to make a brief record that you have asked the questions and received the negative answers

*NB. Remember that in the event the boat is a hire boat, third-party managed share-owned boat, trip boat, rented residential boat or floating business, you must also have been trained and assessed to the 2002 BSS requirements.

If you are Gas Safe registered:

This concerns any differences between, i) the published Examiner instructions to take actions beyond recording a BSS fault as set out in the Examination Checking Procedures including Appendices A & B, and ii) the detailed provisions of the Gas Industry Unsafe Situations Procedure (GIUSP).

The following is agreed with HSE and is provided to help you make the right choices in the field.

The BSS recognises that a Gas Safe registered BSS Examiner when carrying out a BSS examination of a boat in scope of GSIUR, will be subject to the rules of his/her Gas Safe register rules of registration. Accordingly, it is a fact that Gas Safe registered BSS Examiners, whilst carrying out BSS examinations of boats in scope of GSIUR are subject to a duty not to overlook any circumstance that may be covered by GIUSP. The GIUSP is an industry document designed to assist Gas Safe registered gas engineers with identifying common unsafe situations and providing guidance on “classifying” them and taking action in dealing with any issues.

The BSS has a similar process to the GIUSP including the ‘at risk’ and ‘immediately dangerous’ categories relevant to any circumstance warranting its application by BSS Examiners. Many of the circumstances listed within GIUSP are mirrored in BSS warning notice and hazardous boat procedures (i.e. leaking gas and evidence of escaping flue products, and significant accommodation space ventilation deficiencies) and most are captured by BSS LPG requirements. However, some of the GIUSP unsafe situations are not currently covered by BSS warning notice and hazardous boat procedures perhaps because:

  1. they would not be apparent to a BSS Examiner carrying out the set of visual and manual checks;
  2. the BSS adopts a presumption of good installation practice where items would not be apparent to the Examiner at the time of the BSS examination;
  • the measures are relevant to the domestic home environment and not to boats; and/or,
  1. because the BSS Risk Management Process has not identified or included them as a necessary BSS minimum safety requirement.

It is recognised that the consequence of this situation is that there is a potential for Gas Safe registered BSS Examiners, whilst carrying out a BSS examination of a boat in scope of GSIUR, to feel duty-bound under their Gas Safe registration to report to boat owners, and act on safety-related LPG items beyond those items covered by the BSS Requirements.

In these circumstances, two actions are incumbent on Gas Safe registered BSS Examiners, to avoid any potential breach of the BSS Examiner Conditions of Registration:

  1. any intended course of action in dealing with any GIUSP issues not covered by the BSS procedures must be undertaken by way of a separate contract with the customer and the customer must be in no doubt that the intended action is not associated with the contract for the BSS examination;
  2. a complete BSS examination, fully in-line with the BSS ECPs and guidance and instructions, must be undertaken before the customer is made aware of any GIUSP issues.

You are also strongly guided to advise your customers in advance that there could be circumstances, separate to the BSS requirements and BSS Examination contract, that they are dutybound not to overlook under their Gas Safe registration.

Edited by Alan de Enfield
Posted
2 minutes ago, Alan de Enfield said:

 

 

That's what the BSS say you must do if you use a non approved gas examiner to do your BSS

 

keeping on the right side of the law

Boats used for residential purposes as well as hire boats* and floating businesses* (such as cafés or shops) all fall within scope of the Gas Safety [Installation and Use] Regulations (GSIUR) and as such any LPG 'work' must be undertaken by Gas Safe registered installers.

As the definition of 'work' covers the removal and replacement of a screw nipple on a gas test point, the scope of the GSIUR includes carrying out BSS LPG tightness test.

So, on a boat in scope of GSIUR, examiners who are not Gas Safe registered can only complete check 7.12.2 by either:

  • undertaking a gas tightness test using a bubble tester where fitted and correctly located; or,
  • observing the tightness test conducted by a (LPG boats-competent) Gas Safe registered installer

It is important to be aware that people who are prosecuted and found guilty of contravening the GSIUR, can face fines of up to £5000 for each offence or even jail terms for very serious breaches. The HSE and local authorities are active in pursuing people not complying with the regulations, especially where hazards have arisen.

Check in advance

If you are not Gas Safe registered, as part of your initial dealings with owners when booking the examination, please try to protect yourself by tackling the issue in advance of turning up at the mooring.

Ask if the boat has a gas system, then find out whether the boat's use will put it in scope.  We suggest the following questions:

  1. Is the boat hired out in the course of a business (This may include timeshare/shared-ownership boats where there is letting involved in some of the timeslots)?
  2. Is the boat used primarily by anyone for domestic or residential purposes (In this matter, it makes no difference to you if it is owner-occupied or rented-out)?
  3. Do you invite people on board your boat in the course of a business, e.g. is it a café or shop?

If the answer to any of the above questions is yes, then in order to carry out the BSS gas tightness test you will either have to use a fitted bubble tester, or observe a Gas Safe registered installer carrying out the test with a manometer. 

Even if the answer to all the questions above is 'no', you are recommended to make a brief record that you have asked the questions and received the negative answers

*NB. Remember that in the event the boat is a hire boat, third-party managed share-owned boat, trip boat, rented residential boat or floating business, you must also have been trained and assessed to the 2002 BSS requirements.

If you are Gas Safe registered:

This concerns any differences between, i) the published Examiner instructions to take actions beyond recording a BSS fault as set out in the Examination Checking Procedures including Appendices A & B, and ii) the detailed provisions of the Gas Industry Unsafe Situations Procedure (GIUSP).

The following is agreed with HSE and is provided to help you make the right choices in the field.

The BSS recognises that a Gas Safe registered BSS Examiner when carrying out a BSS examination of a boat in scope of GSIUR, will be subject to the rules of his/her Gas Safe register rules of registration. Accordingly, it is a fact that Gas Safe registered BSS Examiners, whilst carrying out BSS examinations of boats in scope of GSIUR are subject to a duty not to overlook any circumstance that may be covered by GIUSP. The GIUSP is an industry document designed to assist Gas Safe registered gas engineers with identifying common unsafe situations and providing guidance on “classifying” them and taking action in dealing with any issues.

The BSS has a similar process to the GIUSP including the ‘at risk’ and ‘immediately dangerous’ categories relevant to any circumstance warranting its application by BSS Examiners. Many of the circumstances listed within GIUSP are mirrored in BSS warning notice and hazardous boat procedures (i.e. leaking gas and evidence of escaping flue products, and significant accommodation space ventilation deficiencies) and most are captured by BSS LPG requirements. However, some of the GIUSP unsafe situations are not currently covered by BSS warning notice and hazardous boat procedures perhaps because:

  1. they would not be apparent to a BSS Examiner carrying out the set of visual and manual checks;
  2. the BSS adopts a presumption of good installation practice where items would not be apparent to the Examiner at the time of the BSS examination;
  • the measures are relevant to the domestic home environment and not to boats; and/or,
  1. because the BSS Risk Management Process has not identified or included them as a necessary BSS minimum safety requirement.

It is recognised that the consequence of this situation is that there is a potential for Gas Safe registered BSS Examiners, whilst carrying out a BSS examination of a boat in scope of GSIUR, to feel duty-bound under their Gas Safe registration to report to boat owners, and act on safety-related LPG items beyond those items covered by the BSS Requirements.

In these circumstances, two actions are incumbent on Gas Safe registered BSS Examiners, to avoid any potential breach of the BSS Examiner Conditions of Registration:

  1. any intended course of action in dealing with any GIUSP issues not covered by the BSS procedures must be undertaken by way of a separate contract with the customer and the customer must be in no doubt that the intended action is not associated with the contract for the BSS examination;
  2. a complete BSS examination, fully in-line with the BSS ECPs and guidance and instructions, must be undertaken before the customer is made aware of any GIUSP issues.

You are also strongly guided to advise your customers in advance that there could be circumstances, separate to the BSS requirements and BSS Examination contract, that they are dutybound not to overlook under their Gas Safe registration.

Yes I know Alan but @Alan de Enfield and I had a discussion on here about Bss and carbon monoxide detectors. He categorically stated that detectors were bought in to protect 3rd party people. I.e a boat moored alongside a boat could get carbon monoxide poisoned.

 

But the gas regulations don't seem to care about a 3rd party boat as the rule changes depending on if you are tied alongside a leisure boat or live aboard. How utterly ridiculous.

How is that putting safety first

Posted
20 hours ago, nicknorman said:

The downside of that is that if there is a leak, it becomes very difficult to locate the source. With a central test point and shut off valves for the appliances you can shut them off in turn to find out which appliance is leaking or at least which section of pipe is leaking. I suggest that most leaks arise from appliances or the fittings in close proximity to them, rather than a long length of piping deciding to spring a leak.

I think you can achieve the same thing, but you have to go through the sequence a different way.

 

If you start by testing through an appliance with all appliance valves open and it passes then no leaks and all is good.

If you have a leak, you then re-pressurise the system, then close the valve to the appliance and re-test. If it leaks then you know the leak is downstream of the valve on the appliance under test; if it doesn't leak then that appliance is good.

Once you have no leaks on the appliance side, you close all the other appliance valves, open the valve to the 'good' appliance and re-test. A leak must then be on the upstream side of all the appliances, ie you are back to the procedure you would have for an independent test point, so can clear everything from the canister to the upstream plumbing fittings at the valves, and the valves themselves of course.

 

Having just gone through some of this myself, which eventually involved re-greasing a couple of valves and rebuilding the hob, it wasn't too difficult so long as I followed the valves as a series of binary gates (once upon a time I could code in BBC Basic and it followed the same logic train).

 

Alec

Posted (edited)
1 hour ago, Tonka said:

But the gas regulations don't seem to care about a 3rd party boat as the rule changes depending on if you are tied alongside a leisure boat or live aboard. How utterly ridiculous.

How is that putting safety first

 

But we should remember that this "gas rule" is nothing to do with the BSS, it is a Government regulation that gas-work on residential buildings / property is required to comply with.

 

The Gas Safety (Installation and Use) Regulations 1998

https://www.legislation.gov.uk/uksi/1998/2451/contents

 

(But - I agree with you, were we Liveaboards when we spent 6 months a year cruising, are you a Liveaboard if you spend the weekend on board ?

Maybe, if the BSS thinks the gas-regs are a good idea, then they should include the "surveyor/examiner must be gas registered rule" for any boat with gas fitted.

 

PS - our static caravans are required to have LPG registered (caravan ticket) Engineers to work on them)

Edited by Alan de Enfield
  • Greenie 1
Posted (edited)
1 hour ago, ditchcrawler said:

Just popped up on FB

image.png.3c380e62ddaf52befae11da9d8190a8c.png

My only question is why don't they make the hose to the manometer a bit longer so that it can dangle directly over the burner?

 

Alec

Edited by agg221
Posted
48 minutes ago, Alan de Enfield said:

Maybe, if the BSS thinks the gas-regs are a good idea, then they should include the "surveyor/examiner must be gas registered rule" for any boat with gas fitted.

I don't think the BSS necessarily"thinks the gas-regs are a good idea". They are stuck with them, whether they like it or not. They just have to deal with all the inconsistencies that crop up at the boundaries of the regs' scope.

But if they did insist all BSS examiners were gas safe registered I think they would struggle to get enough examiners to cope with the number of boats needing boat safety examinations.

Posted

 The BSS ran into the GSIUR fairly early on.  The BSS manager decided that he would ignore the CORGI definition of "work" as inconvenient and  that examiners would, once trained, be given an effective waiver of the CORGI registration requirement for boats used as dwellings.  CORGI,  backed by the HSE, flatly refused.  CORGI were not going to give up their monopoly to allow BSS into the registration game and neither  HSE nor the Government wanted either of  registration exemptions or another gas fitter registration schemes.  Nor would CORGI accept the BSS training package as adequate for CORGI registration  in any form. The correspondence got quite pointy!

 

  It was also clear that there was Buckley's chance of training enough examiners as CORGI fitters or vice versa.

 

Hence the bubble tester work round for liveaboards.

  • Greenie 2
Posted
8 minutes ago, BEngo said:

 The BSS ran into the GSIUR fairly early on.  The BSS manager decided that he would ignore the CORGI definition of "work" as inconvenient and  that examiners would, once trained, be given an effective waiver of the CORGI registration requirement for boats used as dwellings.  CORGI,  backed by the HSE, flatly refused.  CORGI were not going to give up their monopoly to allow BSS into the registration game and neither  HSE nor the Government wanted either of  registration exemptions or another gas fitter registration schemes.  Nor would CORGI accept the BSS training package as adequate for CORGI registration  in any form. The correspondence got quite pointy!

 

  It was also clear that there was Buckley's chance of training enough examiners as CORGI fitters or vice versa.

 

Hence the bubble tester work round for liveaboards.

But CORGI was a joke. If you paid your  subscription you were a member whether you were qualified or not

Posted
8 minutes ago, Technical Tony said:

If the fitting is used as a pass through at present, then why is it leaking, or have i missed something?

You have missed something.

 

The original fitting was a pass-through. This was removed and has been replaced with the present fitting that has connections both ends. The plan is to go back to a pass-through, but during the rebuild the original pass-through fitting has gone AWOL so the options are to buy a new one or drill out the present fitting to make it a pass-through again.

 

Personally, if the holes in the fitting are lined up and it is accessible enough, I wouldn't even remove the fitting to drill it. The drill bit will follow the guide hole and it's soft brass so I would go straight through with the drill. That will save having to access the awkward side again.

 

Alec

Posted

It’s worth bearing in mind what the law actually says, not slight misquotes of it as we have seen…

 

Nothing in these Regulations shall apply in relation to the supply of gas to, or anything done in respect of a gas fitting on—

c)a vessel not requiring a national or international load line certificate except when such vessel is

(iii)used primarily for domestic or residential purposes;

 

So if the vessel is used primarily for domestic or residential purposes then the GSIUR applies. We live in a house. When we are living in the house,  the boat is not used. When we visit the boat we are using it primarily for domestic and residential purposes, especially if we stay in the marina as we are clearly not using it for navigation. What else are we using it for?

 

What the law does NOT say is eg “used as someone’s primary residence”. There is an important difference between “primarily used for…” and “used for someone’s primary …”

 

And from the sheer logic of it, what is the difference in terms of safety between living in a house for 3 months over winter and then staying on the boat for 9 months, vs someone who doesn’t have a house and lives on the boat all year. It is pretty ridiculous and I suspect at some point some clever lawyer will challenge the dodgy interpretation that BSS has put on it.

 

On the other hand, if you are not doing gas work as a business, according to GSIUR you merely need to be competent to do whatever work you want to do on your own stuff. I think it would be hard to justify a prosecution on the grounds that you were not competent to unscrew a test point, screw it back in again and spray a bit of leak detection fluid on it. So what should happen for residential boats is that the owner could (if he feels competent to do so) undo and do up the test point screw whilst the non-Gas Safe BSS examiner does the tightness testing.

 

I can see lots of teeth sucking and looks of horror if that was suggested! Even though it is quite legal.

 

 

  • Greenie 1
Posted
58 minutes ago, nicknorman said:

It’s worth bearing in mind what the law actually says, not slight misquotes of it as we have seen…

 

Nothing in these Regulations shall apply in relation to the supply of gas to, or anything done in respect of a gas fitting on—

 

(iii)used primarily for domestic or residential purposes;

 

 

 

 So what should happen for residential boats is that the owner could (if he feels competent to do so) undo and do up the test point screw whilst the non-Gas Safe BSS examiner does the tightness testing.

 

I can see lots of teeth sucking and looks of horror if that was suggested! Even though it is quite legal.

 

 

Or simply decide to stop using it for domestic purposes  before the test .....maybe changing mind and reverting to domestic shortly after (or maybe not who knows). I think someone suggested something similar earlier.

Posted

The only evidence an examiner has that it's a livaboard is what you tell him and they do ask.

 

Just be economical with the truth🫣

 

Posted
15 minutes ago, Phoenix_V said:

Or simply decide to stop using it for domestic purposes  before the test .....maybe changing mind and reverting to domestic shortly after (or maybe not who knows). I think someone suggested something similar earlier.

That is another good point - you get the BSS test done by a non-gas safe bod because you live in a house, then you sell the boat the next week to someone who is going to live on it. So the "work" that didn't fall under GSIUR (according to conventional wisdom) is still there on the boat that now falls under the GSIUR (according to conventional wisdom. It is all a load of BS!

  • Greenie 1
Posted
1 hour ago, agg221 said:

The original fitting was a pass-through. This was removed and has been replaced with the present fitting that has connections both ends. The plan is to go back to a pass-through, but during the rebuild the original pass-through fitting has gone AWOL so the options are to buy a new one or drill out the present fitting to make it a pass-through again.

But presumably the original pipe, which passed through, has been cut to install the fitting with connections both ends. So to reinstall a pass through will require the entire pipe length to be replaced up to the next fittings either side. That will mean undoing and remaking two joints which are currently not leaking. Wouldn't it be easier to just sort out the leaking connection(s) to the current fitting?

Posted
1 minute ago, GUMPY said:

The only evidence an examiner has that it's a livaboard is what you tell him and they do ask.

 

Just be economical with the truth🫣

 

 

To be fair, I think it is pretty obvious whether a boat is a live aboard or just used for leisure. If the former, there will be piles of junk on the roof, piles of junk on the towpath, green slime on the paint and tarps draped all over everything. If it is leisure boat, there will be dirty gin and tonic glasses in the sink of an otherwise immaculate boat.


Did someone just shout "INCOMING"? I'm a bit deaf.

 

But on a serious note, an examiner I had a chat with on this subject said it was usually pretty obvious whether a boat was used as a liveaboard or not.

  • Greenie 1
Posted
4 hours ago, agg221 said:

I think you can achieve the same thing, but you have to go through the sequence a different way.

 

If you start by testing through an appliance with all appliance valves open and it passes then no leaks and all is good.

If you have a leak, you then re-pressurise the system, then close the valve to the appliance and re-test. If it leaks then you know the leak is downstream of the valve on the appliance under test; if it doesn't leak then that appliance is good.

Once you have no leaks on the appliance side, you close all the other appliance valves, open the valve to the 'good' appliance and re-test. A leak must then be on the upstream side of all the appliances, ie you are back to the procedure you would have for an independent test point, so can clear everything from the canister to the upstream plumbing fittings at the valves, and the valves themselves of course.

 

Having just gone through some of this myself, which eventually involved re-greasing a couple of valves and rebuilding the hob, it wasn't too difficult so long as I followed the valves as a series of binary gates (once upon a time I could code in BBC Basic and it followed the same logic train).

 

Alec

Leaving aside that this wouldn't work because there is a prescribed way to do a tightness test, which wouldn't allow this, I recently had a boiler that was leaking gas, where I could have capped the boiler line off and kept the cooker connected, but that wasn't possible because the only test point was on the boiler.

2 hours ago, nicknorman said:

It’s worth bearing in mind what the law actually says, not slight misquotes of it as we have seen…

 

Nothing in these Regulations shall apply in relation to the supply of gas to, or anything done in respect of a gas fitting on—

c)a vessel not requiring a national or international load line certificate except when such vessel is

(iii)used primarily for domestic or residential purposes;

 

So if the vessel is used primarily for domestic or residential purposes then the GSIUR applies. We live in a house. When we are living in the house,  the boat is not used. When we visit the boat we are using it primarily for domestic and residential purposes, especially if we stay in the marina as we are clearly not using it for navigation. What else are we using it for?

 

What the law does NOT say is eg “used as someone’s primary residence”. There is an important difference between “primarily used for…” and “used for someone’s primary …”

 

And from the sheer logic of it, what is the difference in terms of safety between living in a house for 3 months over winter and then staying on the boat for 9 months, vs someone who doesn’t have a house and lives on the boat all year. It is pretty ridiculous and I suspect at some point some clever lawyer will challenge the dodgy interpretation that BSS has put on it.

 

On the other hand, if you are not doing gas work as a business, according to GSIUR you merely need to be competent to do whatever work you want to do on your own stuff. I think it would be hard to justify a prosecution on the grounds that you were not competent to unscrew a test point, screw it back in again and spray a bit of leak detection fluid on it. So what should happen for residential boats is that the owner could (if he feels competent to do so) undo and do up the test point screw whilst the non-Gas Safe BSS examiner does the tightness testing.

 

I can see lots of teeth sucking and looks of horror if that was suggested! Even though it is quite legal.

 

 

While the Gas Safety (Installation and Use) Regulations 1998 (GSIUR) do not contain a literal dictionary definition of "competent" within the legal text, the HSE provides a clear definition via the Approved Code of Practice (ACOP L56), which has special legal status. Competence means: "A combination of practical skill, training, knowledge and experience to carry out the job in hand safely, and ensuring the installation is left in a safe condition for use." The training and knowledge part is important, because you would have to prove that through an officially recognised certificate from a Nationally Accredited Certification Scheme. A boat owner or BSS examiner can not assess their own competence. 

55 minutes ago, nicknorman said:

 

To be fair, I think it is pretty obvious whether a boat is a live aboard or just used for leisure. If the former, there will be piles of junk on the roof, piles of junk on the towpath, green slime on the paint and tarps draped all over everything. If it is leisure boat, there will be dirty gin and tonic glasses in the sink of an otherwise immaculate boat.


Did someone just shout "INCOMING"? I'm a bit deaf.

 

But on a serious note, an examiner I had a chat with on this subject said it was usually pretty obvious whether a boat was used as a liveaboard or not.

Exactly. Just like with everything else in life, it's up to the individual if they want to take the risk. The rules are clear, but people always bend them. It's only when something goes wrong that this whole discussion becomes relevant. I personally wouldn't want to try to explain to the Magistrate why I declared a clearly lived-in boat as a leisure boat. 

Posted (edited)
2 hours ago, MarineHeatingSolutions said:

 

While the Gas Safety (Installation and Use) Regulations 1998 (GSIUR) do not contain a literal dictionary definition of "competent" within the legal text, the HSE provides a clear definition via the Approved Code of Practice (ACOP L56), which has special legal status. Competence means: "A combination of practical skill, training, knowledge and experience to carry out the job in hand safely, and ensuring the installation is left in a safe condition for use." The training and knowledge part is important, because you would have to prove that through an officially recognised certificate from a Nationally Accredited Certification Scheme. A boat owner or BSS examiner can not assess their own competence. 

 

 

Yes this is what the HSE say, but it is not law. I think the point is that if you did as I say and nothing happened, you would not be prosecuted. If doing what I proposed caused the boat to blow up then pretty much by definition you were not competent and you could and should be prosecuted. But in fact more or less the same applies to a gas safe registered person. If they do some work badly, and eg a gas explosion results which can be put down to the faulty workmanship, then the gas safe person can and should be prosecuted despite having the appropriate paperwork. And in fact the penalties should be greater than for the amateur because you could be expected to carry out a job to the highest standard.

 

Having bits of paper and some training means you could be competent and perhaps demonstrated on a particular day that you were competent to carry out a specific task, but there is absolutely no guarantee that on a subsequent job you are in fact doing it competently. I have seen some pretty shoddy work from gas safe "professionals". Present company excepted of course!

 

And since MtB isn't here to point it out, I will say that actually the biggest hazard with working with gas appliances is not gas leaks, it is CO poisoning.

 

And anyway what the GSIUR is quite clear on is that to do gas work on your own non-residential narrowboat you do not even have to be competent. Which is interesting!

Edited by nicknorman
Posted
8 hours ago, nicknorman said:

That is another good point - you get the BSS test done by a non-gas safe bod because you live in a house, then you sell the boat the next week to someone who is going to live on it. So the "work" that didn't fall under GSIUR (according to conventional wisdom) is still there on the boat that now falls under the GSIUR (according to conventional wisdom. It is all a load of BS!

computer say no syndrome

 

5 hours ago, nicknorman said:

 

Yes this is what the HSE say, but it is not law. I think the point is that if you did as I say and nothing happened, you would not be prosecuted. If doing what I proposed caused the boat to blow up then pretty much by definition you were not competent and you could and should be prosecuted. But in fact more or less the same applies to a gas safe registered person. If they do some work badly, and eg a gas explosion results which can be put down to the faulty workmanship, then the gas safe person can and should be prosecuted despite having the appropriate paperwork. And in fact the penalties should be greater than for the amateur because you could be expected to carry out a job to the highest standard.

 

Having bits of paper and some training means you could be competent and perhaps demonstrated on a particular day that you were competent to carry out a specific task, but there is absolutely no guarantee that on a subsequent job you are in fact doing it competently. I have seen some pretty shoddy work from gas safe "professionals". Present company excepted of course!

 

 

Feeling particularly bitter about this as apparently I am not able to commission fire extinguishers in our club as i do not have the right piece of paper despite the process being as far as I can tell 1 weigh them 2 check for dents 3 check pressure gauge with magnet, modern life in Uk all over

Posted (edited)
15 hours ago, nicknorman said:

 

Yes this is what the HSE say, but it is not law. I think the point is that if you did as I say and nothing happened, you would not be prosecuted. If doing what I proposed caused the boat to blow up then pretty much by definition you were not competent and you could and should be prosecuted. But in fact more or less the same applies to a gas safe registered person. If they do some work badly, and eg a gas explosion results which can be put down to the faulty workmanship, then the gas safe person can and should be prosecuted despite having the appropriate paperwork. And in fact the penalties should be greater than for the amateur because you could be expected to carry out a job to the highest standard.

 

Having bits of paper and some training means you could be competent and perhaps demonstrated on a particular day that you were competent to carry out a specific task, but there is absolutely no guarantee that on a subsequent job you are in fact doing it competently. I have seen some pretty shoddy work from gas safe "professionals". Present company excepted of course!

 

And since MtB isn't here to point it out, I will say that actually the biggest hazard with working with gas appliances is not gas leaks, it is CO poisoning.

 

And anyway what the GSIUR is quite clear on is that to do gas work on your own non-residential narrowboat you do not even have to be competent. Which is interesting!

The argument that 'if it doesn't blow up, it's legal' is like saying 'it's legal to drive 100mph as long as I don't crash.' It’s a fundamental misunderstanding of how safety law works.

 

Under Section 17 of the Health and Safety at Work etc. Act 1974, the ACOP L56 has 'special legal status'—which means failure to follow it is itself admissible as evidence of a criminal breach unless you can prove you complied with the law in another way. If you ignore it and something goes wrong (or the HSE catches you), the burden of proof is on you to prove you were competent. Since the HSE defines competence through accredited certification, an amateur has zero legal leg to stand on in court.

 

Encouraging people to bypass the Gas Safe Register on a forum isn't 'independent thinking'—it's potentially encouraging criminal activity and, more importantly, endangering lives. If you think the court or the HSE will accept anything less than an officially recognised certificate as proof of competence after even only a minor incident, you’re dreaming.

 

Just because a private leisure craft isn't a "residential" dwelling doesn't mean you're in a legal wild west where safety standards are optional. You might be legally allowed to work on your own boat, but you remain fully liable for the outcome—if your DIY "competence" leads to a death, the boat's status won't protect you from a manslaughter charge.

 

Gas work isn't just 'DIY plumbing'; it involves critical tightness, let-by, spillage, pressure, safety device, and controls testing that carry zero legal weight in a court without an official professional record to prove they were actually done following the correct procedures.

10 hours ago, Phoenix_V said:

computer say no syndrome

 

Feeling particularly bitter about this as apparently I am not able to commission fire extinguishers in our club as i do not have the right piece of paper despite the process being as far as I can tell 1 weigh them 2 check for dents 3 check pressure gauge with magnet, modern life in Uk all over

That is indeed ridiculous. Though I can imagine it's more about independently verifying that the work was done than about the technical skill to carry the work out. Isn't there a quick course you can take to become certified? It's got to be cheaper in the long run than calling somebody out to do it.

Edited by MarineHeatingSolutions
Posted
20 hours ago, agg221 said:

You have missed something.

 

The original fitting was a pass-through. This was removed and has been replaced with the present fitting that has connections both ends. The plan is to go back to a pass-through, but during the rebuild the original pass-through fitting has gone AWOL so the options are to buy a new one or drill out the present fitting to make it a pass-through again.

 

Personally, if the holes in the fitting are lined up and it is accessible enough, I wouldn't even remove the fitting to drill it. The drill bit will follow the guide hole and it's soft brass so I would go straight through with the drill. That will save having to access the awkward side again.

 

Alec

 

I have probably missed something too. Although a "pass through" gas locker bulkhead fitting will be gas tight in terms of the pipework itself, doesn't it compromise the gas tightness of the locker, or would the olives in the through fitting effectively seal the bulkhead? 

 

I fitted a normal bulkhead gas fitting from my locker with separate pipes on each side. Where the pipe comes through the cabin bulkhead I have a pass through fitting.

Posted
Just now, blackrose said:

 

I have probably missed something too. Although a "pass through" gas locker bulkhead fitting will be gas tight in terms of the pipework itself, doesn't it compromise the gas tightness of the locker, or would the olives in the through fitting effectively seal the bulkhead? 

 

 

Yes, the olives seal it. The acceptable alternative (which I established recently for the BSS) is simply to pass the pipe through the hole and fill around it with sealant. If I had originally installed it then I would have gone for the pass through fitting, but I didn't and it is too awkward to take apart and replace now, plus it was remedial work for the BSS so somewhat under time pressure, so some CT1 was the solution.


Alec

Posted (edited)
28 minutes ago, MarineHeatingSolutions said:

The argument that 'if it doesn't blow up, it's legal' is like saying 'it's legal to drive 100mph as long as I don't crash.' It’s a fundamental misunderstanding of how safety law works.

 

Under Section 17 of the Health and Safety at Work etc. Act 1974, the ACOP L56 has 'special legal status'—which means failure to follow it is itself admissible as evidence of a criminal breach unless you can prove you complied with the law in another way. If you ignore it and something goes wrong (or the HSE catches you), the burden of proof is on you to prove you were competent. Since the HSE defines competence through accredited certification, an amateur has zero legal leg to stand on in court.

 

Encouraging people to bypass the Gas Safe Register on a forum isn't 'independent thinking'—it's potentially encouraging criminal activity and, more importantly, endangering lives. If you think the court or the HSE will accept anything less than an officially recognised certificate as proof of competence after even only a minor incident, you’re dreaming.

 

Just because a private leisure craft isn't a "residential" dwelling doesn't mean you're in a legal wild west where safety standards are optional. You might be legally allowed to work on your own boat, but you remain fully liable for the outcome—if your DIY "competence" leads to a death, the boat's status won't protect you from a manslaughter charge.

 

Gas work isn't just 'DIY plumbing'; it involves critical tightness, let-by, spillage, pressure, safety device, and controls testing that carry zero legal weight in a court without an official professional record to prove they were actually done following the correct procedures.


There is a lot of protectionism in the gas safe industry. I recall being in the queue at the local plumbers merchant buying a part for our boiler, another person in the queue was berating the staff for serving me. I can’t remember the part in question but it was nothing to do with the gas side of the boiler, might have been a diaphragm for an old fashioned hydraulic changeover valve in an ancient Combi boiler. Fortunately the staff ignored him and of course these days I would have got the part by mail order. So obviously I can see why you are riling at me pointing out what the law actually says, rather than what the gas safe industry wishes it did say. And I am not encouraging anything, I am merely pointing out what the law says, along with its logic-defying idiosyncracities.

 

Going back to your point about speeding, exceeding the speed limit is illegal, it is black and white. If you don’t get caught, you get away with it. But your speed is routinely checked by speed cameras and the police, you don’t have to be crash to be prosecuted.

 

However in the world of gas, the gas police don’t come round to your house or boat checking on every aspect of a gas installation and looking for amateur intervention. And if your activities did come to their attention, they would have to prove you were in breach of the law which would not be as easy as pointing a speed cameras and at you and reading the numbers. It seems unfeasible that you would be prosecuted for competently carrying out some work on a residential boat, and even less likely ditto on a leisure boat because for the latter, under what law could you be prosecuted and how would anyone know unless you did it incompetently and it blew up?

 

You don’t know me very well but I am known for holding the view that there are a lot of incompetent “professionals” out there - along with some great ones of course. It is a problem in boating world that anyone can (and do) set themselves up  on the canals as a “marine engineer”, “marine electrician” and even “marine heating engineer” with absolutely zero training, qualifications or competence. I am of the view that “if you want a job done properly, do it yourself” as I have seen so much incompetence in canal world.

 

Back in the 1980s I bought my first house, I got gas central heating installed but a reputable local company. The boiler was in an outhouse. After a year or two, when I went into the outhouse which was a bit cramped, I must have leant on the gas supply pipe which came adrift at a soldered joint and gas started pouring out. So the gas supply pipe was badly soldered (signs of a “dry joint”), badly supported and in a location where one came into contact with it when passing through the door. At that point I wished I had installed it myself, I would have done a better job. They had also routed the CH pipework via a shortcut OUTSIDE the house. Not ideal in North Scotland! So in summary, just because someone has a qualification on a bit of paper doesn’t mean I would trust them to do something safety critical.

Edited by nicknorman
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