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Here is the relevant part of the BSS

Part 8

 

"There is a growing recognition of the risks associated with the use of non room-sealed gas appliances when used in confined spaces such as boats. These risks include poisoning and suffocation to individuals on board from improperly flued and ventilated appliances. So new LPG appliances must be room sealed, except where room-sealing is not physically possible, i.e. cooking appliances.

There is one specific exception to this rule and this is for LPG instantaneous water heaters. Based on the good previous safety record of these particular appliances, and until such a time as a room-sealed direct replacement becomes easily available, British Waterways and the Environment Agency accept the continued installation of instantaneous water heaters on private boats. If you are changing your non-room sealed instantaneous water heater it's strongly recommended that you consider room sealed alternatives.

So the BSS says

These heaters have a good safety record 

We accept the installation of these heaters 

It is strongly recommended to consider room sealed alternatives.  Note it is recommended to  consider room sealed alternatives it does not say it is recommended to install a room sealed alternative in which case this is not a BSS recommendation only a recommendation to consider, cue Elle Woods. 

So it's should be OK for the OP to have their heater installed? 

Whos ultimate decision is it down to the OP or the installer? 

I would interpret the above to say that if the OP wants the heater installed then he can if he can find a competent installer to agree. Basically the OP is responsible for making the decision to install and its the installers responsibility to install correctly. Is that a fair assessment? 

Edited by reg
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1 hour ago, reg said:

Here is the relevant part of the BSS

Part 8

 

"There is a growing recognition of the risks associated with the use of non room-sealed gas appliances when used in confined spaces such as boats. These risks include poisoning and suffocation to individuals on board from improperly flued and ventilated appliances. So new LPG appliances must be room sealed, except where room-sealing is not physically possible, i.e. cooking appliances.

There is one specific exception to this rule and this is for LPG instantaneous water heaters. Based on the good previous safety record of these particular appliances, and until such a time as a room-sealed direct replacement becomes easily available, British Waterways and the Environment Agency accept the continued installation of instantaneous water heaters on private boats. If you are changing your non-room sealed instantaneous water heater it's strongly recommended that you consider room sealed alternatives.

So the BSS says

These heaters have a good safety record 

We accept the installation of these heaters 

It is strongly recommended to consider room sealed alternatives.  Note it is recommended to  consider room sealed alternatives it does not say it is recommended to install a room sealed alternative in which case this is not a BSS recommendation only a recommendation to consider, cue Elle Woods. 

So it's should be OK for the OP to have their heater installed? 

Whos ultimate decision is it down to the OP or the installer? 

I would interpret the above to say that if the OP wants the heater installed then he can if he can find a competent installer to agree. Basically the OP is responsible for making the decision to install and its the installers responsibility to install correctly. Is that a fair assessment? 

Can you please provide a link to your source ? FOUND IT "2002 BSS, NON-PRIVATE BOATS

You forgot to include this part :

The production of carbon monoxide at low rates over a period of time can lead to dangerous accumulations of this noxious gas in enclosed spaces. For this reason appliances which operate for extended periods, and particularly during the night, must either be fitted with effective devices which automatically turn them off if carbon monoxide is detected or be of a room-sealed type. The risk from older appliances of carbon monoxide poisoning is so great that it's intended to prohibit the installation and use of non room-sealed refrigerators or central heating appliances on inland waterways boats after 1 January 2006. When buying an appliance it is a good idea to make sure that it's suitable for use in your boat. Manufacturers may provide an assurance of suitability by any of the following means:

  • installation instructions include a section specific to boats
  • brochures and other literature aimed at the boat-owner market
  • conformity with relevant published Standards.

https://www.boatsafetyscheme.org/boat-examination/non-private-boats/part-8-appliances,-flueing-ventilation/

I think that is probably an extract from an old (or maybe very new) BSS - the latest version I have is 2015 and I cannot seem to locate it.

I cannot seem to locate your 'section 8' in the 2005 issue either

All I can find in the 2002 issue is :

8:2 LPG Appliances shall be room sealed with the exception of cooking appliances.   (NOTE: see paragraph 11.25).

Exemption 11.25
Vessels manufactured prior to 3 January 2000 and having non-room sealed appliances are not required to comply with that part of Standard 8.2 which requires LPG appliances, with the exception of cooking appliances, to be room sealed provided the following requirements are complied with:
 
i) Replacements for existing non-room sealed appliances, with the exception of cooking appliances, shall be room sealed and installed in accordance with BS 5482-3 and Parts 7 and 8 of these Standards as appropriate.
 
ii) Modifications or additions to an existing installation shall be performed in accordance with the appliance manufacturer’s recommendations.

 

The BSS guidance to examiners then goes on to 'warn' about gas installation on live-aboard boats which come under GSIUR legislation.

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.

 

Edit to add a link to the 'section 8' for Non-Private boats.

Edited by Alan de Enfield
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2 hours ago, Mike the Boilerman said:

 

It might first appear to be this but on reflection I think not. 

I think it is more a case of retailers wishing not to appear to be giving advice on suitablility when the are not qualified to do so.

Imagine Mr Overconfident DIYer walks in and asks the bloke behind the counter if it is OK to fit in a boat. Blokes says 'yes' so Mr ODIYer beetle off back to his boat and fits it in a bedroom, bathroom or sleeping area. Or in his newbuild sailaway. Next, he tries to sell it and buyers surveyor flags it up as non-compliant. 

Mr DIYer beetles off back to the retailer and demands a solution, saying the retailer gave him legally binding advice it was OK and demands a solution (which doesn't exist).

Retailers caught out like this are gonna just start saying 'not suitable for boats', aren't they!

That seems sensible, but would also apply to almost any potential installation in various locations. 

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1 hour ago, Alan de Enfield said:

Can you please provide a link to your source

https://www.boatsafetyscheme.org/boat-examination/non-private-boats/part-8-appliances,-flueing-ventilation/

I believe this is the current version it does make reference to 2017 hire boats. 

1 hour ago, Alan de Enfield said:

For this reason appliances which operate for extended periods, and particularly during the night, must either be fitted with effective devices which automatically turn them off if carbon monoxide is detected or be of a room-sealed type.

I think this the effective part of your quote. Reading the rest of it I believe this is referring mainly to central heating and fridges which would likely be running long term and  overnight. LPG instant heaters on the other hand are run for short periods or relatively short periods of time and therefore are not covered in your quoted section. 

Just as an aside circa 2006 when my boat was being fitted out I was not allowed to install an instant heater. I think this was a short period when a ban was put into place only to be , pragmatically , amended after it was pointed out that they had a very good safety record. So BSS copies circa 2005/2006 or earlier may not represent the current position. 

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6 minutes ago, reg said:

That is the version that applies to "non private boats" - i.e. for example hire boats. ( can see that ecause it is embedded in the URL!).

The version for private boats, (i.e. the ones most of us on here own) is different.

For example you can still fit a non  room sealed LPG fridge in a private boat - I believe I am correct in saying that would not be allowed in a hire boat.

Unless things have changed since I last studied the two different guides there are lots of other detail differences.  For example cables with a solid copper conductor, (i.e. not stranded), were allowed, (but not recommended!) in private boats, but would be a fail in a hire boat.

You have to read the correct regulations for the type of boat being considered.

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11 minutes ago, reg said:

https://www.boatsafetyscheme.org/boat-examination/non-private-boats/part-8-appliances,-flueing-ventilation/

I believe this is the current version it does make reference to 2017 hire boats. 

 

Yet again you have linked to a section for NON-PRIVATE boats.

The OP is looking to install into a PRIVATE, LIVEABOARD boat which then comes under the GSIUR regulations.

A PRIVATE NON-LIVEABOARD boat would have different regulations and would not fall under the GSIUR regulations.

Edited by Alan de Enfield
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30 minutes ago, reg said:

https://www.boatsafetyscheme.org/boat-examination/non-private-boats/part-8-appliances,-flueing-ventilation/

I believe this is the current version it does make reference to 2017 hire boats. 

I think this the effective part of your quote. Reading the rest of it I believe this is referring mainly to central heating and fridges which would likely be running long term and  overnight. LPG instant heaters on the other hand are run for short periods or relatively short periods of time and therefore are not covered in your quoted section. 

Just as an aside circa 2006 when my boat was being fitted out I was not allowed to install an instant heater. I think this was a short period when a ban was put into place only to be , pragmatically , amended after it was pointed out that they had a very good safety record. So BSS copies circa 2005/2006 or earlier may not represent the current position. 

Not strictly relevant to the discussion on water heaters, but the bss in that era had quite a few bits of legislation that were later dropped as unnecessary, for example, the fuel fillers and vents on historic craft had to be extended to the exterior of the boat, whereas for the previous few decades they had been inside the engine room with no issues. 

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4 minutes ago, reg said:

Good point my bad 

No problem. it is just that Non-private boats (hire boats, etc) fall under the 2002 regulations.

The regulations for Private boats have changed a number of time with the last issue being 2015, and all reference to the 'acceptability' of open-flued appliances has been removed.

But there is still the 'differences' between 'live-aboard' and 'non-live-aboard' private boats.

For some obscure reason spending (say) 6 months cruising your boat does not qualify as 'living on board'.

 

The whole BSS system is flawed even down to the extent of examiners telling live-aboards to 'disappear' for a couple of hours so he can do the non-live-aboard BSS checks. 

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On 18/01/2018 at 23:33, BBPIRATES said:

 

1. Is the Bosch W11 LPG heater suitable for a narrowboat? We were recommended it, bought one (from a chandlers), and have now been told that it won't pass the BSS and aren't sure why.

The following link says it is not suitable for mobile vehicles . 

https://www.caravanaccessoryshop.co.uk/product/bosch-w11-lpg-water-heater/4565

 

 

 

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18 hours ago, Alan de Enfield said:

Yet again you have linked to a section for NON-PRIVATE boats

Looking at it again and whilst accepting I linked to the non private boats BSS the actual statement specifically refers to private boats. 

 British Waterways and the Environment Agency accept the continued installation of instantaneous water heaters on private boats

I'm not sure if we are any nearer to a definitive answer for the OP but from the BSS point if view in broad general terms there should not be an issue with installing a non room sealed instant heater. 

I would be fairly confident if it was my boat it was being installed on that I had covered the BSS issue and that it was acceptable in general terms to install non room sealed instant heaters. 

The question now remains as to whether the specific model of heater referred to is a suitable candidate for boats. That question is outside my pay grade I'll leave that one to those with the relevant expertise. 

Eta 

I find it slightly strange that the statement referring to private boat installation is in the non private boats section. You have to deduce, if in fact my deduction is correct,  from the statement that it is not acceptable for non private boats. Could of been worded better Methinks. 

Edited by reg
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13 minutes ago, reg said:

Looking at it again and whilst accepting I linked to the non private boats BSS the actual statement specifically refers to private boats. 

 British Waterways and the Environment Agency accept the continued installation of instantaneous water heaters on private boats

I'm not sure if we are any nearer to a definitive answer for the OP but from the BSS point if view in broad general terms there should not be an issue with installing a non room sealed instant heater. 

I would be fairly confident if it was my boat it was being installed on that I had covered the BSS issue. 

The question now remains as to whether the specific model of heater referred to is a suitable candidate for boats. That question is outside my pay grade I'll leave that one to those with the relevant expertise. 

 

Agreed, but that is taken from the 2002 BSS regs, the 2005 and 2015 BSS regs make no such comment, however, as we are talking about a live aboard boat and not a leisure boat so the GSIUR regulations come into play - just to save going back dozens of posts the 2018 GSIUR regulation 30 :

Regulation 30 Room-sealed appliances 
 Summary of regulation 30  This regulation prohibits the installation of certain gas appliances in specified rooms, unless the appliance is room-sealed. In other specified locations, certain appliances must be room-sealed or fitted with a device to cause shutdown before a dangerous quantity of combustion products can build up in the room concerned. A general prohibition is placed on the installation of any instantaneous water heater, unless it is room-sealed or fitted with such a device.

It cannot be fitted into :

a bathroom or shower room

a sleeping area unless (a) it is a room-sealed appliance; or (b) it incorporates a safety control designed to shut down the appliance before there is a build up of a dangerous quantity of the products of combustion in the room concerned. 
or 
(a) a cupboard or compartment within such a room; or (b) a cupboard, compartment or space adjacent to such a room if there is an air vent from the cupboard, compartment or space into such a room. 

I would suggest that there is 'not much' of a narrowboat that does not fall into either a bathroom, a sleeping area, or a 'space adjacent to such a room'

Edited by Alan de Enfield
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So to summarise

The BSS says it is acceptable with provisos 

Another set of regulations are down to interpretation by the installer and the BSS examiner. 

If it is installed then a BSS examiner at a later date may take a different viewpoint on the acceptability of the installation. 

I have sympathy for the OP who asked what on the face of it was a simple question. 

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11 minutes ago, reg said:

So to summarise

The BSS says it is acceptable with provisos 

Another set of regulations are down to interpretation by the installer and the BSS examiner. 

If it is installed then a BSS examiner at a later date may take a different viewpoint on the acceptability of the installation. 

I have sympathy for the OP who asked what on the face of it was a simple question. 

 

Ok let's review what the OP asked...

"1. Is the Bosch W11 LPG heater suitable for a narrowboat? We were recommended it, bought one (from a chandlers), and have now been told that it won't pass the BSS and aren't sure why"

The debate seems to conflate two different issues.
 

1) Is the appliance itself suitable for installation in a narrowboat? 

Quick answer: Yes.

Detailed answer: Lots of retailers are claiming it isn't suitable, but so far none has cited an arbiter with genuine authority saying the same (e.g. the manufacturer, BSS Office, CRT, EA etc).,

 

2) Is it legal to actually install this appliance in a narrowboat?

Quick answer: Yes.

Detailed answer: Yes, subject to compliance with whatever regulations happen to govern the proposed installation. These will vary and may include one or more of the following. BSS GSIUR, RCD. In each of these it isn't the appliance that might be wrong, it is the specific details of the proposed installation.

 

 

40 minutes ago, Alan de Enfield said:

I would suggest that there is 'not much' of a narrowboat that does not fall into either a bathroom, a sleeping area, or a 'space adjacent to such a room'

 

So therefore, this water heater may installed in the part of the boat you describe as 'not much'. :)

  • Greenie 1
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Plus the bosch manual states 

"With electronic ignition and triple safety system
consisting of ionisation detector, flue gas monitor
and heat exchanger temperature sensor" 

Page 6 of the manual goes into detail on how this shuts down the system 

https://www.manualslib.com/manual/19337/Bosch-W11b.html#manual

 

The regs quoted say

1 hour ago, Alan de Enfield said:

Regulation 30 Room-sealed appliances 
 Summary of regulation 30  This regulation prohibits the installation of certain gas appliances in specified rooms, unless the appliance is room-sealed. In other specified locations, certain appliances must be room-sealed or fitted with a device to cause shutdown before a dangerous quantity of combustion products can build up in the room concerned. A general prohibition is placed on the installation of any instantaneous water heater, unless it is room-sealed or fitted with such a device.

It would appear from the manual that it is fitted with such a device in which case for this set of regulations it does not need to be room sealed. So it looks like 

The BSS requirements are met, see previous posts

It meets the  quoted regulation 30 for other specified locations. 

So that only leaves an interpretation on whether the location is suitable. 

Based on the above I personally would be happy to install (have installed) this device in a kitchen area. 

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2 hours ago, Alan de Enfield said:

(a) a cupboard or compartment within such a room; or (b) a cupboard, compartment or space adjacent to such a room if there is an air vent from the cupboard, compartment or space into such a room. 

This part specifically states if there is an air vent Into to such a room.

I interpreted that as meaning if it is vented into such a room and not if it is adjacent to such a room. 

In which case the 

2 hours ago, Alan de Enfield said:

I would suggest that there is 'not much' of a narrowboat that does not fall into either a bathroom, a sleeping area, or a 'space adjacent to such a room'

In which case this would negate your suggestion as it does not say in a 'space adjacent to such a room'  but "if there is an air vent from the cupboard, compartment or space into such a room"  which is a different thing. 

Bearing everything in mind I would still be happy to have this installed. 

Edited by reg
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11 minutes ago, reg said:

Plus the bosch manual states 

"With electronic ignition and triple safety system
consisting of ionisation detector, flue gas monitor
and heat exchanger temperature sensor" 

Page 6 of the manual goes into detail on how this shuts down the system 

https://www.manualslib.com/manual/19337/Bosch-W11b.html#manual

 

 

Not questioning any likely variations by region but did you note that this is the manual for the South African Bosch water heater ?

It reads as if it may meet the requirements

The flue gas safety device checks the effectiveness of flue

gas extraction by the flue. If it is inadequate, the appliance

switches off automatically so that the combustion fumes do

not escape into the room in which the appliance has been

installed. The flue gas safety device resets after a cooling-

down period.

But I have no idea if a device that measures if the flue gases are being extracted, is the same as one that shuts down before the combustion gases can build up in the room.

Maybe it is ?

 

4 minutes ago, reg said:

I interpreted that as meaning if it is vented into such a room and not if it is adjacent to such a room. 

An air vent is supplying 'fresh air' to the boiler as it is not a sealed unit and getting its air supply from outside. This depletes the air/oxygen in the adjacent 'space', and, with there not being much of barrier between 'rooms' on a NB  it will draw air/oxygen from the adjacent room(s)

'Vented' would normally mean to 'pass air OUT' (ie a tumble drier 'vent' pipe) It would certainly be a fail if it was vented anywhere inside the boat. 

 

I have 'no dog in this fight' as I am quite happy with my Eberspacher heater, however, at the end of the day I still suggest that a live aboard considering fitting one should get written 'authority' from the manufacturer and the BSS just to cover themselves in the event of an incident.

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19 minutes ago, Alan de Enfield said:

I have 'no dog in this fight

Likewise

Just trying to understand the whole shebang. 

After removing my Alde  system may be looking at an instant heater and don't want to fall into any of the traps. 

Options go cheaper, which appeals

Or go fully roomed sealed with the added expenses. 

My main criteria are 

Would I be safe

Would I meet all of the regulations. 

If I can ascertain that the Bosch meets both of those criteria then it would be an option. So far I am happy that it would however it does seem to come down to whether my installer would agree and the bss examiner would agree. 

All a bit of a mess and I'm still not sure where this leaves the Op as there does not appear to be a definitive answer. 

I think I'm done with this. 

 

 

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1 minute ago, reg said:

Likewise

Just trying to understand the whole shebang. 

After removing my Alde  system may be looking at an instant heater and don't want to fall into any of the traps. 

 

Apologies for my confusion but assumed you had one fitted when you posted this :

 

1 hour ago, reg said:

Based on the above I personally would be happy to install (have installed) this device in a kitchen area. 

 

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4 hours ago, Alan de Enfield said:

Not questioning any likely variations by region but did you note that this is the manual for the South African Bosch water heater ?

It reads as if it may meet the requirements

The flue gas safety device checks the effectiveness of flue

gas extraction by the flue. If it is inadequate, the appliance

switches off automatically so that the combustion fumes do

not escape into the room in which the appliance has been

installed. The flue gas safety device resets after a cooling-

down period.

But I have no idea if a device that measures if the flue gases are being extracted, is the same as one that shuts down before the combustion gases can build up in the room.

Maybe it is ?

Could well be a thermal switch at the bottom of the draught diverter, if the flue is blocked or there's too much backdraft it will trip and open the thermocouple circuit, shutting the heater off.

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4 hours ago, smileypete said:

Could well be a thermal switch at the bottom of the draught diverter, if the flue is blocked or there's too much backdraft it will trip and open the thermocouple circuit, shutting the heater off.

 

What thermocouple circuit is that then? 

;)

(This appliance has electronic ignition!) 

 

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