‘Gas Safe’ registration of service engineer

‘Gas Safe’ registration of service engineer

QUESTION:

To service a gas engine that is a Standby / Prime generator are you required to be GAS SAFE registered?
To service a gas engine that is in a Combined Heat and Power unit that is in a plant room are you required to be GAS SAFE registered?
We do not install or connect the gas, this is purely servicing the engine, oil, filters spark plugs etc. and checking the emissions once serviced.

RESPONSE

Firstly, if you do not have a copy, you should familiarise yourself with all relevant documentation, including HSE Publication “Safety in the installation and use of gas systems and appliances L56 – Gas Safety (Installation and Use) Regulations 1998. Approved Code of Practice and guidance”. This is available here.

Our view on the above question is that the gas engine (that being Natural Gas & LPG) is “gas using equipment” (appliance) and needs to be treated as such, however, the type of premises will dictate whether the unit will fall under Gas Safe or the HSE.

Those premises that are not covered by Gas Safe will be covered by the HSE and you must be able to demonstrate engineer competency, however, if the engineer is already on the Gas Safe register then he will already be deemed as competent to do the works. The definition of premises covered under Gas Safe can be found in the above HSE publication.

Where the engine is connected to a gas supply, it should comply with IGE/UP/2, 3, 10, 16, SR25, etc.

A list of appropriate standards, ACOPs, guidance and other relevant information sources can be found on the Gas Safe Register website in the Legislative, normative and informative document list at www.gassaferegister.co.uk or from AMPS.

HSE Approved Code of practice

A note taken from the HSE website concerning the status of their guidance and ACOP’s:

Legal status of HSE guidance and ACOPs

HSE publishes guidance (in the form of leaflets, books and on its webpages) and Approved Codes of Practice (ACOPs).

HSE guidance provides advice to help you understand how to comply with the law; explanations of specific requirements in law; specific technical information or references to further sources of information to help you comply with your legal duties.

ACOPs describe preferred or recommended methods that can be used (or standards to be met) to comply with regulations and the duties imposed by the Health and Safety at Work etc Act.

The legal status of guidance and ACOPs is given below and will appear in the relevant publications.

HSE guidance legal status

This guidance is issued by the Health and Safety Executive. Following the guidance is not compulsory, unless specifically stated, and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law. Health and safety inspectors seek to secure compliance with the law and may refer to this guidance.

Approved Codes of Practice (ACOPs) legal status

Each ACOP is approved by the Health and Safety Executive, with the consent of the Secretary of State. It gives practical advice on how to comply with the law. If you follow the advice you will be doing enough to comply with the law in respect of those specific matters on which the Code gives advice. You may use alternative methods to those set out in the Code in order to comply with the law.

However, the Code has a special legal status. If you are prosecuted for breach of health and safety law, and it is proved that you did not follow the relevant provisions of the Code, you will need to show that you have complied with the law in some other way or a Court will find you at fault.

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