Gas bottle size

[Alan de Enfield]

10 minutes ago, Sea Dog said:

There's no requirement for the guy using a manometer to test the integrity of a boat system be qualified in home gas installation, or any gas installation at all, is there?

Yes for boats which are the 'main or primary residence'.

No for 'leisure' boats.

 

So, if I use my boat for (say) 5 1/2 months I'm 'leisure' but 6 months and it becomes my 'main residence' and subject to GSIUR regulations.

[Chewbacka]

20 minutes ago, Alan de Enfield said:

Yes for boats which are the 'main or primary residence'.

No for 'leisure' boats.

 

So, if I use my boat for (say) 5 1/2 months I'm 'leisure' but 6 months and it becomes my 'main residence' and subject to GSIUR regulations.

Which is why the bss person will normally ask if you are leasure or live aboard if you don’t have a bubble tester.

[cuthound]

41 minutes ago, Sea Dog said:

 

The BSS test element seems like an easy issue to resolve. There's no requirement for the guy using a manometer to test the integrity of a boat system be qualified in home gas installation, or any gas installation at all, is there?  A short course and practical exam in how to do the test properly would seem to suffice.  It doesn't resolve the wider issue of the cost of training for those who wish to work only on boat or caravan gas, but that's a separate subject I guess.  I wonder what MtB thinks?

 

Indeed, it only involves unscrewing the test point covers, connecting the manometer, reading, waiting and re-reading the manometer, interpreting the results, removing the manometer and finally replacing the test point covers and checking for leaks.

 

When I was first shown how to do it over 40 years ago it took about 5 minutes for me to learn it.

 

Only if it fails does it require further knowledge to rectify.

Edited September 25, 2018 by cuthound
Spillung and clarity

[Alan de Enfield]

3 minutes ago, Chewbacka said:

Which is why the bss person will normally ask if you are leasure or live aboard if you don’t have a bubble tester.

Or, as a regular examiner in our marina says to customers "just go out for a few hours then I don't know if you are a liveaboard, so I can then do the BSS" (he is not gas safe registered)

[Chewbacka]

1 minute ago, Alan de Enfield said:

Or, as a regular examiner in our marina says to customers "just go out for a few hours then I don't know if you are a liveaboard, so I can then do the BSS" (he is not gas safe registered)

Very true, and if you are asked the question the responsibility is yours to declare your status, the inspector simply ticks the box

[Alan de Enfield]

10 minutes ago, Chewbacka said:

Very true, and if you are asked the question the responsibility is yours to declare your status, the inspector simply ticks the box

 

Are there any other alternatives to allow non Gas Safe registered BSS Examiners to check residential boat gas systems?

Unfortunately there are only two methods that can be used to check for gas leaks on boats (manometer leak check and bubble tester check). The only other alternative is for the non-Gas Safe registered BSS Examiner to observe a manometer leak check conducted by a LPG boat-competent Gas Safe registered engineer.

 

The BSS Examiner may ask you about your boat's use:

The examiners who are not on the Gas Safe register are advised as part of their initial dealings with owners to ask in advance of turning up at the mooring, about the status of the craft.

To avoid falling foul of UK law and avoiding criminal prosecution they need to find out whether the boat's use will mean they should not carry out a tightness-test using a manometer.  They may ask the following questions, just for their own personal record:

• Is the boat hired out in the course of a business?
• Is the boat used primarily by anyone for domestic or residential purposes (In this matter, it makes no difference to if the boat is owner-occupied or rented-out)?
• Are people invited on board the boat in the course of a business, e.g. is it a café or shop?

Even if the answer to all the questions above is 'no', the examiner is advised to make a brief record that he or she has asked the questions and received the negative answers. This information will not be shared with BSS Office or other parties unless there is an investigation linked to gas testing by the examiner.

*Note on the BSS Examination for non-private boats - If a vessel is a hire boat, third-party managed share-owned boat, trip boat, rented residential boat, floating business or some other form of commercial or public vessel, the boat will be examined to either the 2017 Hire Boat Requirements or 2002 BSS Standards as stipulated by the navigation authority registering your boat.

Edited September 25, 2018 by Alan de Enfield

[Sea Dog]

39 minutes ago, Alan de Enfield said:

Yes for boats which are the 'main or primary residence'.

No for 'leisure' boats.

 

So, if I use my boat for (say) 5 1/2 months I'm 'leisure' but 6 months and it becomes my 'main residence' and subject to GSIUR regulations.

Sorry, I perhaps should have not used the word requirement, because as you say, there is a legislative one.  I should have offered that there's no actual reason that the bloke doing a manometer test also needs to have the ability, and be qualified, to do the entire installation. Rather, he simply needs to be certified as able to do the check correctly. A failure in the test would bring a BSS fail and require gas work done - this is the area where you might require a fully fledged boat qualified gas safe engineer.  

[Alan de Enfield]

19 minutes ago, Sea Dog said:

Sorry, I perhaps should have not used the word requirement, because as you say, there is a legislative one.  I should have offered that there's no actual reason that the bloke doing a manometer test also needs to have the ability, and be qualified, to do the entire installation. Rather, he simply needs to be certified as able to do the check correctly. A failure in the test would bring a BSS fail and require gas work done - this is the area where you might require a fully fledged boat qualified gas safe engineer.  

Agreed but as the Examiner is being paid, the legislation states

 

Work in relation to a gas fitting  52 For the purposes of GSIUR, ‘work’ includes do-it-yourself activities, work undertaken as a favour for friends and relatives, and work for which there is no expectation of reward or gain, eg voluntary activity for charities. This means that anyone carrying out such work must have the necessary competence, as required by regulation 3(1). However, membership of an HSE-approved class of persons (under regulation 3(3)) is required only by businesses carrying out gas-fitting work. 

 

[Regulation 3(1)–(2)] 
(1) No person shall carry out any work in relation to a gas fitting or gas storage vessel unless he is competent to do so.  
(2) The employer of any person carrying out such work for that employer, every other employer and self-employed person who has control to any extent of such work and every employer and self-employed person who has required such work to be carried out at any place of work under his control shall ensure that paragraph (1) above is complied with in relation to such work.  
 
81 Gas work should only be undertaken:  (a) by a person who has successfully completed an industry-recognised training course followed by assessment of competence. Training that leads to assessment of competence in safe gas work should be recognised by the industry’s standards setting body; or  (b) in the case of a currently or previously registered person, where they have proved competence through a certification scheme; or  (c) for those working at premises that fall outside the scope of the Regulations (see regulation 2(4) and associated guidance), by a person who has successfully completed an appropriate full training course followed by assessment of competence. 

 

[Regulation 3(3)] 
 
(3) Without prejudice to the generality of paragraphs (1) and (2) above and subject to paragraph (4) below, no employer shall allow any of his employees to carry out any work in relation to a gas fitting or service pipework and no self-employed person shall carry out any such work, unless the employer or self-employed person, as the case may be, is a member of a class of persons approved for the time being by the Health and Safety Executive for the purposes of this paragraph.  
 
91 In addition to ensuring competence, all gas engineering businesses, including self-employed gas engineers, are (subject to the limited exceptions in regulation 3(4)) required to be in membership of a class of persons approved by HSE, whether they carry out such work as their main or part activity. Gas engineers who are employed by a member of an approved class of persons but who do separate work on their own behalf need to be in membership of such class of persons, eg Gas Safe registered, in their own right.  
 
92 The requirement to be in membership of such class of persons, eg Gas Safe registered does not apply to engineers carrying out gas work at premises that fall outside the scope of GSIUR (see regulation 2(4) and associated guidance).  
93 At the time of publication of this edition of the ACOP, the only body with such approval is the Gas Safe Register (www.gassaferegister.co.uk), although other organisations may apply to HSE for consideration to act as a registration body if they so wish.  
 

Edited September 25, 2018 by Alan de Enfield

[Sea Dog]

1 minute ago, Alan de Enfield said:

 Agreed but the legislation states...

 

And one can't argue with that.  Seems a bit of overkill for a manometer test though, and surely there'd be benefit to find a way to allow BSS testers to be able to do such a test?  Still, there currently isn't, and probably won't be either.  I'll continue to find a gas safe BSS tester so I can have the manometer test even though I don't need to under the present rules. 

[Chewbacka]

19 minutes ago, Sea Dog said:

 

And one can't argue with that.  Seems a bit of overkill for a manometer test though, and surely there'd be benefit to find a way to allow BSS testers to be able to do such a test?  Still, there currently isn't, and probably won't be either.  I'll continue to find a gas safe BSS tester so I can have the manometer test even though I don't need to under the present rules. 

You will never get a ‘manometer only’ ticket as all professions with restrictive practices guard them most strongly as it protects their income.  So whilst a manometer only qualification might not cost much work for a registered gas fitter it would be the thin end of the wedge.  

[Sea Dog]

4 hours ago, Chewbacka said:

You will never get a ‘manometer only’ ticket as all professions with restrictive practices guard them most strongly as it protects their income.  So whilst a manometer only qualification might not cost much work for a registered gas fitter it would be the thin end of the wedge.  

Fair enough, and I absolutely get the point - although here the alternative is to have someone who's not qualified to do a manometer test not do a manometer test at all!

 

[alan_fincher]

I wonder if there is any recorded  evidence anywhere of something bad happening on a boat because the gas integrity check in the BSS was done with a bubble tester, rather than a manometer?

 

I accept that a bubble tester may fail to reveal a very very slow leak, but the amount of gas escaping must surely be so small as to prevent no great hazard to the boat or its occupants.

 

Or can someone provide any evidence to the contrary, please?

[cuthound]

9 hours ago, alan_fincher said:

I wonder if there is any recorded  evidence anywhere of something bad happening on a boat because the gas integrity check in the BSS was done with a bubble tester, rather than a manometer?

 

I accept that a bubble tester may fail to reveal a very very slow leak, but the amount of gas escaping must surely be so small as to prevent no great hazard to the boat or its occupants.

 

Or can someone provide any evidence to the contrary, please?

 

Surely a slow leak into a gas tight bilge over a long time is just as dangerous as a big leak into a gas tight bilge over a short time.

 

Once the Lower Explosive Level is reached all it needs is a source of ignition and boom....

[alan_fincher]

6 minutes ago, cuthound said:

 

Surely a slow leak into a gas tight bilge over a long time is just as dangerous as a big leak into a gas tight bilge over a short time.

 

Once the Lower Explosive Level is reached all it needs is a source of ignition and boom....

Assuming we are talking ony about a leak that is so small you can't detect it with a bubble tester, I very much doubt it could accumulate in sufficient volumes over time to ever become a danger.

 

It may be denser than air, but I think it is unlikely that such small volumes will slowly fill the boat up without it getting dispersed by natural ventilation and draughts through the boat.

 

If that were not the case, why do the BSS authorities see it as a sufficient test?

 

Is there a shred of evidence that boats tested with a bubble tester suffer any greater number of gas leak related incidents than those without?

[MtB]

22 hours ago, Chewbacka said:

You will never get a ‘manometer only’ ticket as all professions with restrictive practices guard them most strongly as it protects their income.  So whilst a manometer only qualification might not cost much work for a registered gas fitter it would be the thin end of the wedge.  

 

Its nothing to do with restrictive practices and all to do with public demand. 

 

Until 21 floors were blown out of a tower block in London killing four people and injuring 17 caused by incompetent gas installers, there were no regulations at all. Public outrage led directly to the 'restrictive practices' you are moaning about.

 

https://en.wikipedia.org/wiki/File:Ronan_Point_-_Daily_Telegraph.jpg

[cuthound]

20 minutes ago, alan_fincher said:

Assuming we are talking ony about a leak that is so small you can't detect it with a bubble tester, I very much doubt it could accumulate in sufficient volumes over time to ever become a danger.

 

It may be denser than air, but I think it is unlikely that such small volumes will slowly fill the boat up without it getting dispersed by natural ventilation and draughts through the boat.

 

If that were not the case, why do the BSS authorities see it as a sufficient test?

 

Is there a shred of evidence that boats tested with a bubble tester suffer any greater number of gas leak related incidents than those without?

 

IIRC the Lower Explosive Level for propane is about 2% by volume, so not a lot is required to leak to reach that concentration in a bilge, especially if a lot of the bilge area is filled with ballast.

 

Not many bilges on narrowboats have much in the way of natural ventilation, let alone forced ventilation which is a requirement for boats with inboard petrol engines.

 

I am not aware of any evidence showing that boats with bubble testers suffer more gas leaks than those without, however as they introduce more joints the likelihood of leaks is probably greater.

 

Gas bubble testers are much harder to read than a manometer, mainly because they have to be located in the gas locker and observed for a relatively long time, so may not be used much after fitting. This can lead to a false sense of security.

Edited September 26, 2018 by cuthound
To remove a letter masquerading as a space.

[MtB]

25 minutes ago, cuthound said:

 

I am not aware of any evidence showing that boats with bubble testers suffer more gas leaks than those without, however as they introduce more joints the likelihood of leaks is probably greater.

 

There is my empirical evidence.

 

When bubble testers first appeared and before even BSS issued the requirement to fit them inside gas lockers, I bought one. 

 

I wanted to test it's effectiveness before installing it on my boat so I spent an afternoon rigging up an LPG system with the bubble tester installed and a very small leak (you will have NO IDEA how difficult it is to get a leak just the right size!) The leak was very small but just large enough to fail the proper soundness test as defined in the regs in force at the time.

 

Once I had established my test system failed the conventional tightness test I unleashed the bubble tester in accordance with the instructions. It failed to display the leak. I can't remember the details but I satisfied myself the bubble tester was not as sensitive as the PD5482-2005 Pt 3 soundness test. Holding the button in for 30 seconds I think was required, and in that time no bubble was formed. ISTR it took about a minute or so for the first bubble to visibly form and pass through the viewing window. 

 

I think the BSS recently raised the test period using a bubble tester to one minute too, so they perhaps performed a similar test and got a similar result. I'm not sure what the bubble tester instructions say the test period must be these days though. 

 

 

 

My point is that in the early days of bubble testers, it was possible for a boat to pass the bubble test and at the same time fail the PD5482-2005 Pt 3 tightness test.

[alan_fincher]

52 minutes ago, cuthound said:

I am not aware of any evidence showing that boats with bubble testers suffer more gas leaks than those without, however as they introduce more joints the likelihood of leaks is probably greater.

There should be no additional joints other than in the gas locker, which of course is vented to drain any escaped gas overboard.

Arguably within the confines of the boat there may be more joins if no bubble tester is fitted.  The boat I'm sat in now has no bubble tester fitted yet, so there is an additional fitment along the pipe in the boat for the test point that would not need to be there for BSS purposes if there was a bubble tester in the gas locker.