Instantaneous water heater

[WotEver]

5 minutes ago, Sapphal said:

After a bit of reading around, the ruling seems to be that any new installation of instant water heaters have to be 'room-sealed'. But there seems to be confusion regarding the approval for use in boats.  As such it appears that only the Morco ones are approved.  Surely though if the unit is room sealed and fitted by a gas registered installer then it should pass the BSS.

Mmmmm - perhaps there are soldered internal connections which might be a fail on the BSS. 

My stance is that if it isn’t specifically mentioned in the BSS checklist then it doesn’t form part of the BSS examination. 

The whole point of the checklist is to confirm that your boat complies. You can’t have examiners turn up with ‘secret rules’ that aren’t listed. 

[alan_fincher]

20 minutes ago, Sapphal said:

After a bit of reading around, the ruling seems to be that any new installation of instant water heaters have to be 'room-sealed'.

 

Not so - ore at least not for BSS puposes.

For BSS on a private boat6, at least, an open flued heater is OK.

[Alan de Enfield]

23 minutes ago, WotEver said:

You can’t have examiners turn up with ‘secret rules’ that aren’t listed. 

Its a shame that the BSS & the examiners don't know that.

Although, even the correct application of the existing rules would be a major step forward.

[WotEver]

6 minutes ago, Alan de Enfield said:

Its a shame that the BSS & the examiners don't know that.

Although, even the correct application of the existing rules would be a major step forward.

Yes, your RCD debacle springs to mind. I did ask @Rob@BSSOffice about that but he never responded to me. 

[MtB]

10 hours ago, MoominPapa said:

I couldn't find anything that said that during a quick scan. That's why I aksed you.

 

MP.

 

 

This debate was last had over gas fridges being fitted in boats. ISTR a BSS bod taking part and saying as far as his inspections were concerned there is an overarching requirement for appliances to be installed in compliance with MI and if the MI doesn't specifically state suitable for use in boats, then the appliance isn't suitable. I think no conclusion was being reached. 

As no-one here has ever raised a appeal against BSS failure under such circumstances or can cite one, the outcome of such an appeal remains a matter for conjecture. 

10 hours ago, MoominPapa said:

I couldn't find anything that said that during a quick scan. That's why I aksed you.

 

MP.

 

 

This debate was last had over gas fridges being fitted in boats. ISTR a BSS bod taking part and saying as far as his inspections were concerned there is an overarching requirement for appliances to be installed in compliance with MI and if the MI doesn't specifically state suitable for use in boats, then the appliance isn't suitable. I think no conclusion was being reached. 

As no-one here has ever raised a appeal against BSS failure under such circumstances or can cite one, the outcome of such an appeal remains a matter for conjecture. 

10 hours ago, MoominPapa said:

I couldn't find anything that said that during a quick scan. That's why I aksed you.

 

MP.

 

 

This debate was last had over gas fridges being fitted in boats. ISTR a BSS bod taking part and saying as far as his inspections were concerned there is an overarching requirement for appliances to be installed in compliance with MI and if the MI doesn't specifically state suitable for use in boats, then the appliance isn't suitable. I think no conclusion was being reached. 

As no-one here has ever raised a appeal against BSS failure under such circumstances or can cite one, the outcome of such an appeal remains a matter for conjecture. 

10 hours ago, MoominPapa said:

I couldn't find anything that said that during a quick scan. That's why I aksed you.

 

MP.

 

 

This debate was last had over gas fridges being fitted in boats. ISTR a BSS bod taking part and saying as far as his inspections were concerned there is an overarching requirement for appliances to be installed in compliance with MI and if the MI doesn't specifically state suitable for use in boats, then the appliance isn't suitable. I think no conclusion was being reached. 

As no-one here has ever raised a appeal against BSS failure under such circumstances or can cite one, the outcome of such an appeal remains a matter for conjecture. 

[WotEver]

1 minute ago, Mike the Boilerman said:

ISTR a BSS bod taking part and saying as far as his inspections were concerned there is an overarching requirement for appliances to be installed in compliance with MI and if the MI doesn't specifically state suitable for use in boats, then the appliance isn't suitable. I think no conclusion was being reached. 

I can understand why no conclusion was reached because the above ‘requirement’ doesn’t form any part of the BSS checklist. What’s the point of publishing a checklist that doesn’t include all the items to be checked?

[MtB]

(Ok the multiple reply problem raises its head again. I pressed "Submit Reply" and it displayed the word "Saving" for about one second them changed back to "Submit Reply". So I pressed it again thinking it hadn't posted my reply. Three more times before giving up and re-loading the thread to see if my reply was lost or posted four times.) 

[Alan de Enfield]

2 minutes ago, WotEver said:

Yes, your RCD debacle springs to mind. I did ask @Rob@BSSOffice about that but he never responded to me. 

Nor me when I reported it.

Nor when I questioned about an examiner asking the 'owners' to not be in attendance so he could then not ask them if it was a liveaboard (he was not qualified to undertake Liveaboard BSS exams)

[MtB]

40 minutes ago, WotEver said:

My stance is that if it isn’t specifically mentioned in the BSS checklist then it doesn’t form part of the BSS examination. 

The whole point of the checklist is to confirm that your boat complies. You can’t have examiners turn up with ‘secret rules’ that aren’t listed. 

 

Well that seems to be exactly what can and does happen. 

48 minutes ago, Sapphal said:

After a bit of reading around, the ruling seems to be that any new installation of instant water heaters have to be 'room-sealed'.

 

Can you cite the the details of this ruling that say this please?

I think you will turn out to be conflating 'new installation' of a water heater in an old boat, with 'new installation' of a water heater in a brand new boat subject to the requirements of the RCD.  

[MtB]

A new installation in an old boat can be open flue as I understand it, but would like to know if my understanding is wrong.

12 minutes ago, WotEver said:

I can understand why no conclusion was reached because the above ‘requirement’ doesn’t form any part of the BSS checklist. What’s the point of publishing a checklist that doesn’t include all the items to be checked?

 

Totally agree. An appeal would sort things out. 

An appeal won would probably also result in the next issue of BSS checks including a question like "Are all fuel-burning appliances installed in compliance with Manufacturers Instructions?"

[WotEver]

5 minutes ago, Mike the Boilerman said:

Totally agree. An appeal would sort things out. 

An appeal won would probably also result in the next issue of BSS checks including a question like "Are all fuel-burning appliances installed in compliance with Manufacturers Instructions?"

Which would be fair enough. Ambiguity removed  

As it stands, that isn’t in the current checklist and logic would therefore suggest that any appeal would succeed. Not that logic is always relevant. 

[MtB]

6 minutes ago, WotEver said:

Which would be fair enough. Ambiguity removed  

As it stands, that isn’t in the current checklist and logic would therefore suggest that any appeal would succeed. Not that logic is always relevant. 

 

Be careful what you wish for.

Think about the consequences of introducing such a rule. There are thousands of appliances out there in boats not installed in accordance with MI. Every alternate boat would fail its next BSS examination and the owners would all scream it was fine last time!

I suspect this it the reason the rule is not already present, and never will be.

[WotEver]

1 minute ago, Mike the Boilerman said:

 

Be careful what you wish for.

Think about the consequences of introducing such a rule. There are thousands of appliances out there in boats not installed in accordance with MI. Every alternate boat would fail its next BSS examination and the owners would all scream it was fine last time!

I suspect this it the reason the rule is not already present, and never will be.

A bit like my boiler installation at home you mean?

Getting back to boats... the checklist is gospel and they can’t wander in with arbitrary rules...

There’s a hole in my bucket...

[David Mack]

4 hours ago, Mike the Boilerman said:

A new installation in an old boat can be open flue as I understand it, but would like to know if my understanding is wrong.

 

Totally agree. An appeal would sort things out. 

An appeal won would probably also result in the next issue of BSS checks including a question like "Are all fuel-burning appliances installed in compliance with Manufacturers Instructions?"

That would be draconian, and far in excess of what is required for house, cars etc. The most that could reasonably be asked is "Were all fuel-burning appliances originally installed in compliance with the Manufacturers Instructions applicable at the time of installation?"

[WotEver]

15 minutes ago, David Mack said:

That would be draconian, and far in excess of what is required for house, cars etc. The most that could reasonably be asked is "Were all fuel-burning appliances originally installed in compliance with the Manufacturers Instructions applicable at the time of installation?"

And how could one possibly know that?  “Yes, once upon a time it was installed in compliance with MI. It isn’t now of course...”

And if the original manufacturer no longer exists, who’s to say what their installation instructions were?

And if the manufacturer doesn’t specifically state “Not to be fitted in a boat” but neither does he say “Suitable for boats”, what then?

[MoominPapa]

1 minute ago, WotEver said:

And how could one possibly know that?  “Yes, once upon a time it was installed in compliance with MI. It isn’t now of course...”

And if the original manufacturer no longer exists, who’s to say what their installation instructions were?

I don't believe that there's actually a requirement for appliances to have type approval, and therefore an appliance may not even HAVE a manufacturer, in a legal sense.

 

MP.

 

[WotEver]

Just now, MoominPapa said:

I don't believe that there's actually a requirement for appliances to have type approval, and therefore an appliance may not even HAVE a manufacturer, in a legal sense.

Good point. 

[Alan de Enfield]

This requirement is still in the BSS for non-private boats (ie syndicate boats, commercial boats, hire boats etc)

For Non-Private boats the applicable BSS is the issue dated 2002

"Some appliances are just not suitable for use on boats, e.g. where they generate too much heat in a confined space or where they are heavy and unstable. If surfaces next to an appliance get overheated there is a danger that they could catch fire. To reduce the risk of this happening you must make sure that all appliances are suitable for use on your boat, situated in sufficient space and are properly installed in line with the manufacturer's instructions for installation on boats".

And, just as a matter of interest (as it is oft discussed) this also applies to non-private boats

There have been numerous explosions resulting from the use of gas refrigerators with naked flames on petrol-powered boats. The low level permanent flame of a pilot light or burner could be the prime source of ignition for any stray petrol fuel or vapour. To prevent this happening the pilot lights and burners on LPG or paraffin refrigerators installed in boats with a petrol engine must be completely enclosed by a suitable flame trap.

And this :

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.

Edited March 22, 2018 by Alan de Enfield

[WotEver]

6 minutes ago, Alan de Enfield said:

This requirement is still in the BSS for non-private boats (ie syndicate boats, commercial boats, hire boats etc)

"Some appliances are just not suitable for use on boats, e.g. where they generate too much heat in a confined space or where they are heavy and unstable. If surfaces next to an appliance get overheated there is a danger that they could catch fire. To reduce the risk of this happening you must make sure that all appliances are suitable for use on your boat, situated in sufficient space and are properly installed in line with the manufacturer's instructions for installation on boats".

 

 

But what if the manufacturer doesn’t issue specific installation instructions for a boat?

[Alan de Enfield]

2 minutes ago, WotEver said:

But what if the manufacturer doesn’t issue specific installation instructions for a boat?

As with any other 'failure' to meet the requirements, I would guess you cannot comply with the requirements of the BSS and will not be issued with a certificate.

A question for Rob@BSS ?

[David Mack]

4 hours ago, Alan de Enfield said:

As with any other 'failure' to meet the requirements, I would guess you cannot comply with the requirements of the BSS and will not be issued with a certificate.

A question for Rob@BSS ?

The requirement could equally well be read as saying you must comply with manufacturer's instructions for installation on boats where these exist. So if there are no such instructions, then "non compliance" cannot be a failure point. Only if the manufacturer specifically states that the appliance must not be installed on boats could the manufacturer's instructions be contravened.

[Alan de Enfield]

1 minute ago, David Mack said:

The requirement could equally well be read as saying you must comply with manufacturer's instructions for installation on boats where these exist. So if there are no such instructions, then "non compliance" cannot be a failure point. Only if the manufacturer specifically states that the appliance must not be installed on boats could the manufacturer's instructions be contravened.

That could lead to no end of silliness.

Remember the story coming out of the USA ?

A woman had washed her dog and put it into the microwave to dry off - the dog died and she took the manufacturers to court claiming that their safety labels made no mention of not microwaving pets.