Hire boats*, (this may include timeshare/shared-ownership boats where there is letting involved in some of the timeslots) and floating businesses** (such as cafés or shops) fall within scope of the Gas Safety [Installation and Use] Regulations (GSIUR).
As such, the law demands that anyone contracted to 'work' on the LPG system of a boat in scope must be (LPG boats-competent) Gas Safe registered.
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.
Therefore, on a boat in scope of GSIUR, examiners who are not Gas Safe registered can only complete check 7.12.2 (confirming gas tightness) by either:
- undertaking a gas tightness test using a bubble leak detector where fitted and correctly located; or,
- observing the tightness test conducted by a (LPG boats-competent) Gas Safe registered installer
Where a BSS Examiner who is also Gas Safe registered is undertaking a BSS Examination of a boat in scope of GSIUR such as a hire boat, commercial or community boat, the Examiner could potentially identify safety-related LPG issues beyond the extent of the BSS Requirements. In doing so, they may feel duty-bound under their Gas Safe registration to report and discuss the additional issues.
If in discussions additional works are agreed as necessary and the Gas Safe registered Examiner is chosen to carry out works to remedy the safety-related LPG issues, this must be undertaken by way of a contract that is entirely separate to the contract for the BSS examination.
Does a Bubble Tester do away with the need for a Gas Safe registered engineer testing the gas system during a BSS Examination on hire or commercial boats?
Yes, because any BSS Examiner can check for leaks using a fully functioning and appropriately located bubble leak detector. It is the case however that there is no BSS requirement for a bubble leak detector and so fitting one is matter of boat owner choice.
Note that all other types of gas work, such as adding or replacing an appliance, needs to be conducted by a Gas Safe registered engineer with the LPG boat competence listed on his/her identity card.
Is it recommended that boat owners fit a bubble leak detector?
Yes, fitting a bubble leak detector in the LPG cylinder locker is strongly recommended on suitable systems because it allows owners to check for leaks themselves and so enjoy piece of mind in between BSS Examinations. However, it is very important that fitting bubble leak detector on residential boats (and private leisure boats) is done by a LPG boat-competent engineer listed on the Gas Safe Register.
This is because the bubble leak detector must be correctly located and oriented, and for large volume LPG systems, the engineer may need to install a bypass arrangement to allow gas to flow past the bubble tester when it is not being used.
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 leak detector 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.
Note on the BSS Examination for
*Hire boats - boats that are let or hired under an arrangement, whether or not on a pre-contract basis; or the subject of a bare boat charter arrangement; or the subject of any form of third-party managed shared-use arrangement (including timeshare or shared ownership), self-drive hire or non-moving self-service accomodation. These will be likely be examined by specifically authorised BSS Examiners to the Hire Boat Requirements (April 2017 onwards)
**non-private boats - If a vessel is a trip boat, hotel boat, floating business or some other form of commercial or public use vessel, a boat crewed by employees or volunteers, the boat will be likely be examined by specifically authorised BSS Examiners to the 2002 BSS Non-Private Boat Standards.
However, before making any decisions or contacting any examiners to make arrangements, you must discuss your BSS Certification requirements for any anyboats not in private use with the registering navigation or harbour authority so that your are clear what meets its terms and conditions.