LPG tightness testing on residential boats, houseboats, hire boats and business boats

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.