Bulkhead Regulator Removal

[RogerL]

What are the legal and type approval implications of removing the new-style bulkhead LPG regulator and using an old-style cylinder regulator instead?
The work would be done when the caravan's 3-year warranty expires and carried out by a Gas Safe (Caravan LPG) engineer so no issues on those scores.
Although the number of reports of blocked bulkhead regulators has reduced somewhat there do still seem to be problems around - and Truma have seen fit to develop a filter, not cheap, to avoid the issue. Having used cylinder regulators for 3 decades in the past without any issues I'd rather go back to something that worked!

 

[otherclive]

Mine has been on since 2005 without any problem. After 4 years I changed the pigtail to stainless- polymer one but only on account of its longer life. Would it not be better to reposition the regulator in line with current advice if you are worried about fouling? Since that advice was issued and makers conformed there are rarely any complaints made about regulator fouling.

 

[JTQ]

I can't see any issues in changing, the more so if done professionally.
My 2008 UK market Hymer along with the earlier 2002 UK market Hymer both have 30 mB cylinder mounted regulators.
These are single stage GOK units and of adequate flow rate for the high demands of Alde heating/boiler units. They are threaded to suit UK 4.5 kg butane bottles [POL] and fitted with an adaptor that converts from UK propane to that butane [POL] thread. I believe both the regulators and definitely the adaptor can be purchased from Gaslow.
The discharge side to the van's solid pipe is done in orange reinforced hose; the 2002 van to push on nozzles.secured with Jubilee type clips; the 2008 with a made up orange hose with factory crimped on running nuts.

 

[Damian]

EN1949 2011 requires that caravans are fitted with bulkhead mounted regulators on UK built caravans.
However, a 30Mb cylinder mounted regulator can be used IF that is what was fitted originally.
It is NOT permitted to change from one type to another, and it is NOT permitted to use anything other than 30Mb operating pressure.

It is permissable to change regulator makers though, and Clesse is the preferred option.

Most of the UK available cylinder mounted Propane regaultora are rated at 37Mb.

The use of Gas Safe registered engineers is not required as caravans do NOT fall under Gas Safe regulation.
The operative MUST, however, be at least ACoPS qualified.

 

[ProfJohnL]

Damian has covered the Gas approval side.

No approved fitter would condone such a change yet allone cary it out.

From a safety perspective, it is never a good suggestion to try an operate any a gas appliance on a supply it is not designed or rated for.

Some of the possible consequences might include, the appliance operating unsafely, emitting a higher level of dangerous fumes, unsteady flames that are prone to blowing out, inadequate or over zealous heat output. to mention some.

Using an incorrect gas supply will take the caravan outside its NCC approval. It might also affect your insurance, as the caravan has an unapproved modification to a safety critical system.

You would also void any manufacturers guarantee or possible claim under the 6 year time limit for SoGA (if there is any left), again because the appliance has been operated on an unapproved gas supply.

 

[colin-yorkshire1]

hi all,
just a thought after reading Damians post, I notice he refers to EN1949 2011 I assume the last four digits refer to the year of introduction and as new legistlation supercedes some other legistlation it is not retrospective, the new rules would not apply (ie pre 2011) otherwise all of us with older vans (pre 2011) would all have to have bulkhead mounted regulator fitted.
if this is correct then Rogers (3 year old van) could be converted surely.

as an aside it is funny how things move on a few years ago I posted a comment that was supposed to be a joke stating that if legistlation carried on from the EU as it was in a couple of years we would have to have a gas engineer change the bottle, we are not there yet but one wonders.

 

[Damian]

EN1949 2011 is an updated version of the original and the original included the requirements as stated in my previous posting.
The updated version just makes minor changes to tightness testing and how it is done.

 

[RogerL]

From a safety perspective, it is never a good suggestion to try an operate any a gas appliance on a supply it is not designed or rated for.

For many decades, caravan appliances have been designed for butane/propane at 28/30/37 mbar pressure - cy;linder-mounted regulators being 28mbar butane or 37mbar propane but bulkhead-mounted regulators using an in-between 30mbar for both gases.

 

[RogerL]

EN1949 2011 requires that caravans are fitted with bulkhead mounted regulators on UK built caravans.
However, a 30Mb cylinder mounted regulator can be used IF that is what was fitted originally.
It is NOT permitted to change from one type to another, and it is NOT permitted to use anything other than 30Mb operating pressure.

It is permissable to change regulator makers though, and Clesse is the preferred option.

Most of the UK available cylinder mounted Propane regaultora are rated at 37Mb.

The use of Gas Safe registered engineers is not required as caravans do NOT fall under Gas Safe regulation.
The operative MUST, however, be at least ACoPS qualified.

Neither EN standards nor Whole Vehicle Type Approval can ban subsequent modification, they only apply when built.
So is there UK legislation,applicable to touring caravans, which prevents this change being done ?

It may not be a legal requirement, as it's only covered by an ACoPS code of practice but Gas Safe do have a category of approval for LPG as opposed to natural gas and for caravans as opposed to domestic properties.

 

[RogerL]

hi all,
just a thought after reading Damians post, I notice he refers to EN1949 2011 I assume the last four digits refer to the year of introduction and as new legistlation supercedes some other legistlation it is not retrospective, the new rules would not apply (ie pre 2011) otherwise all of us with older vans (pre 2011) would all have to have bulkhead mounted regulator fitted.
if this is correct then Rogers (3 year old van) could be converted surely.

as an aside it is funny how things move on a few years ago I posted a comment that was supposed to be a joke stating that if legistlation carried on from the EU as it was in a couple of years we would have to have a gas engineer change the bottle, we are not there yet but one wonders.

The date on EN standards and EC Directives usually relates to the year it was enacted to distinguish it from earlier versions - but year of implementation may be several years different.
In the case of the caravan in question, it'll be a 2013 model - I'm just planning ahead !

 

[Surfer]

We had a regulator on the bottle in addition to the bulkhead regulator and never had any issues. Eventually the regulaor on the bottle was removed and within weeks the bulkhead regulator packed up and had to be replaced. Maybe coincidence, I don't know.

 

[JTQ]

“EN1949 2011 requires that caravans are fitted with bulkhead mounted regulators on UK built caravans.

It is NOT permitted to change from one type to another, and it is NOT permitted to use anything other than 30Mb operating pressure.

From a safety perspective, it is never a good suggestion to try an operate any a gas appliance on a supply it is not designed or rated for”.

Have we really in UK law got to this situation, or are these statements and inference on EN applicability, just a trade body’s own in house standards?

Here there was no suggestion of operating gas appliances on a supply it is not designed or rated for. Whilst that is of course true it is absurd to make the statement in this context where its changing from a bulkhead mounted to cylinder mounted 30mB regulator, both purpose designed for that function and at the appliances providing precisely the same “supply”.

If safety is the issue I can make an unarguable case that the direct close coupled cylinder mounted regulator is inherently safer than a high pressure hose fed remotely mounted regulator; so clearly the NCC decision to adopt a bulkhead regulator in the first place was not overly concerned with making the safer choice.

 

[Damian]

Quote " Have we really in UK law got to this situation, or are these statements and inference on EN applicability, just a trade body’s own in house standards?"

It is nothing to do with "trade bodies" in house standards, EN1949 was put in place by our ever loving European Parliament to harmonise the standard across Europe.
Initially a lot of European manufacturers opted for cylinder mounted 30Mb regulators, but most, if not all now use the bulkhead mounted versions, which is supposed to make life easier when changing from one gas to another with just the pigtail being replaced.

Quote" Here there was no suggestion of operating gas appliances on a supply it is not designed or rated for. Whilst that is of course true it is absurd to make the statement in this context where its changing from a bulkhead mounted to cylinder mounted 30mB regulator, both purpose designed for that function and at the appliances providing precisely the same “supply”."

No one has said the OP was changing pressure, I was only pointing out that it is very difficult to source a 30Mb cylinder mounted regulator in the UK, and that it is not permitted to change the installation from its original specification.

Quote "If safety is the issue I can make an unarguable case that the direct close coupled cylinder mounted regulator is inherently safer than a high pressure hose fed remotely mounted regulator; so clearly the NCC decision to adopt a bulkhead regulator in the first place was not overly concerned with making the safer choice."

It was not the NCC who decided on the bulkhead fixing, it was the caravan manufacturers.
II quite agree that a close coupled regulator is much safer by only allowing reduced pressure gas out of the cylinder, but in the E.U's decision it was decided that it was safer to have owners only needing to change pigtails as the bulkhead end of the pigtail contains a rubber gasket which provides a gas tight seal, whereas some owners were using the wrong type of Jubilee clips which cut into gas pipes and Jubilee clips are harder to get a good seal with .

Having said all that, in actual fact, a caravan owner can do anything they want to as long as the caravan is for their own personal use alone (ie not lent out to friends or extended members of the family) providing any work complies with GSIUR's.

BUT,,,and its a big BUT,,,,,,if anything goes wrong, dont expect any insurance to cover you because it will not.

 

[Gafferbill]

.....to answer the OP's question with another question then I would ask .......what for?

My opinion and that of many others is that any problems encountered by using these regulators are caused by bad positioning of the regulator in respect of the gas cylinder.
The regulator should be mounted higher than the gas cylinder and the connecting pipework fitted in such a way as to allow any small amounts of heavy liquid products contained in the petroleum gas to freely drain back into the cylinder.
This is the case with a cylinder top mounted regulator and I maintain that is why they were mostly trouble free.

It would be useful if Damian could comment especially as to any cons of moving a bulkhead regulator that was not positioned correctly.

 

[ProfJohnL]

Neither EN standards nor Whole Vehicle Type Approval can ban subsequent modification, they only apply when built.
So is there UK legislation,applicable to touring caravans, which prevents this change being done ?

It may not be a legal requirement, as it's only covered by an ACoPS code of practice but Gas Safe do have a category of approval for LPG as opposed to natural gas and for caravans as opposed to domestic properties.

In the UK the Gas Safety (Installation and use) Regulations specifically exclude owners of motor homes and touring caravans from compliance with the need for work on private touring caravan by their owner. If a touring caravan is being worked on by anyone other than the owner (i.e. a contractor or dealer) or the caravan is being used for hire or reward the regulations apply. It is a crass dangerous piece of legislation in that regard.

However whoever works on a gas system (including owners) is required to ensure the codes of practise and safety regards design and installation are followed. That is the protocol that requires compliance with gas pressures.

For many decades, caravan appliances have been designed for butane/propane at 28/30/37 mbar pressure - cy;linder-mounted regulators being 28mbar butane or 37mbar propane but bulkhead-mounted regulators using an in-between 30mbar for both gases.

You asked what is the legal standing of your proposed change. I can only relate that a gas appliance should only be used on on the gas type and pressures for which it has been approved. If the manufacture does only includes 30mB on its data plate then it is illegal to connect it to a 28/37mB supply, and vice versa.

Having worked for a major gas appliance manufacture I can assure you that for some products there are more than just cosmetic changes to suit different gas supplies.

It is therefore wrong to assume that because 30mB sits nicely between 28 and 37mB that an older 28/37 appliance is legally satisfactory at 30mB and vice versa.

A registered gas fitter should issue a prohibition notice on your caravan if its gas supplies and appliances do not match.

Don't forget that there will be several different appliances in a caravan, and you must by guided by the appliance with the narrowest of approvals.

 

[RogerL]

You asked what is the legal standing of your proposed change. I can only relate that a gas appliance should only be used on on the gas type and pressures for which it has been approved. If the manufacture does only includes 30mB on its data plate then it is illegal to connect it to a 28/37mB supply, and vice versa.

I'm assuming nothing - the caravan gas appliances I have in my current caravan are stated as "28-30/37mbar" on their rating plates - specifically to allow use of different regulator pressures.
When caravan makers changed from supplying a hose nipple, to allow the attachment of hose to a 28mbar butane or 37mbar propane cylinder-mounted regulator, to a bulkhead 30mbar butane or propane regulator - they didn't need to make any changes to the gas appliances because they have been made and plated as "28-30/37mbar" for 3 decades to my knowledge and possibly will be for just as long in the future.

 

[Damian]

Many caravan gas appliances are indeed plated 28/30/37, but units destined for use in the UK and Europe are optimised for 30Mb use.

As the likes of Truma, Dometic and Thetford supply units to all parts of the world they have to make applinces to suit all applications.

Older caravans with cylinder mounted regulators cannot be altered to a bulkhead regulator as the appliances are jetted to take account of the differences between burn patterns of Propane and Butane.

The Truma, or GOK to be precise, regulator is prone to blocking because it is a double diaphragm unit, whereas cylinder mounted and the Clesse bulkhead regulators are single stage, only one diaphragm, and the oily deposit instead of being caught in the two stage GOK regulator is allowed through into the vans pipework, where some will be burnt off in normal use but eventually after several years will block pipework and gas valves.

Siting the GOK high as possible is helpful and should be the norm (but it is not), with pigtails forming a continual downward attitude to the cylinder.
However, that in itself will not stop a blockage for ever.
One way of prolonging the eventuality of a failure is to burn off the gas in the system when not actually in use.
The use of the normal pigtails or the more expensive stainless steel pigtails has any effect on the problem , the problem is the gas, or what it contains.

 

[Dustydog]

What is the cost differential of replacing like for like the bulkhead regulator? Not a lot I suspect.

Damian touched on a very important insurance point.

Within the policy is a " due diligence" type clause that requires you keep your caravan in a good state of repair. Deviation from original specifications that subsequently causes a fire may result in a rejected claim. Arguably any such modification should be advised to your Insurer.

So is it really worth all the hassle??

 

[Damian]

Dustydog, you are quite right, every care must be taken especially with gas.
However, although EN1949 stipulates a bulkhead mounted regulator, it does not stipulate which make, and the Clesse is a 30Mb regulator whch is only different in diaphragm numbers, one instead of two , but it is perfectly acceptable and is a good unit.
Cost is less than the GOK regulator.

 

[ProfJohnL]

Hello Roger,
If as you state your appliances do actually state 28-30/73mb, then it is permissible to operate them om 28mB butane, 30mb Butane/Propane and 37mB Propane, but I have to stress only if all three pressure are specifically stated on the appliance's data and approvals plate.

However, the appliances are only part of the system, the caravan installation pipework is also part of the system. As with any system it is only as strong as its weakest link, In this case, the caravan manufacturer will have constructed and tested the gas system to the 30mB regulations, not 37 which is you intention. As the system is not approved to 37mB it would be seen as illegal to connect a 37mB regulator.

Whilst the actual pressure differences are relatively small, and unlikely to cause any mechanical problem, the gas laws and regulations are quite specific, and it is an offence to connect an appliance to a supply for which it not approved. It would also be a reason for an insurance company to refuse a claim to a related issue.

 

[ProfJohnL]

With regards the OP's choice of regulator and change in pressure, he states:-

Having used cylinder regulators for 3 decades in the past without any issues I'd rather go back to something that worked!

The standard UK pressures were 28mB Butane and 37mB Propane - not 30mB upuntil 2004. If he revertes to the pre 2004 type of regulator for his new 30mB caravan, that would involve a change of pressure and would be illegal.

 

[RogerL]

With regards the OP's choice of regulator and change in pressure, he states:-

Having used cylinder regulators for 3 decades in the past without any issues I'd rather go back to something that worked!

The standard UK pressures were 28mB Butane and 37mB Propane - not 30mB upuntil 2004. If he revertes to the pre 2004 type of regulator for his new 30mB caravan, that would involve a change of pressure and would be illegal.

It needs specific legislation to make something illegal - manufacturing standards and codes of practice don't make anything illegal directly.
Can you identify the specific legislation that makes a change of pressure illegal ? This would be entirely within the spirit of my raising the issue in the first place.

 

[Damian]

There is no "specific legislation" regarding the topic.
The guidelines which all the UK and European manufacturers work to are BS EN 1949 2011.(which is an upodated version of BSEN1949 2002)

If a British Standard is good enough for everyone else, its good enough for me.

As an owner you can do anything your heart desires, just dont ask a gas engineer to do it, because he cannot, legally, as he is bound by H&S, GSIUR and BSEN1949.

 

[RogerL]

Thanks for that clarification.
Over the decades, many changes relating to caravans have been beneficial to their owners - automatic over-run brakes from a long way back, fire-retardent foam and 13-pin plugs being examples but this issue seems an example of "change for change's sake" in replacing a perfectly good system with something different that is at best no better and at worst more unreliable.
As they say, "Change is inevitable, progress is optional".

As a cynical aside, why don't the faceless EU bureaucrats introduce a new EN standard for caravans to eliminate water ingress, once and for all - that would be a beneficial change !

 

[otherclive]

This has been an interesting thread, but the last post re EU- crats raised a question in my mind. What pressure did European vans operate at before the UK changed to 30 mb, did European vans have bottle or bulkhead regulators and did European vans have regulator fouling before UK changed to bulkhead mounting in 2004 or did they suffer regulator fouling after that time? Ie is this a UK problem or have European vans been similarly affected?