John, I have read your post and can only agree with you.
I have not been able to find out how many, if any, fires or deaths have happened in a touring caravan (there have been deaths in Statics but due to CO poisioning)or motorhome at any time in the past.
I have no idea who would have such information.
I also disagree with testing just for the sake of it, especially when it involves extra costs for owners, of which I am one as well.
I am also very uncomfortable about the requirement for me to start pulling items out of their housings, such as a fridge to disconnect the mains, to carry out testing.
There is no intention, as far as I know, to dismantle fixed furniture and the like, I am informed that just enough access to disconect electronic items is all that is needed, in many cases that just means access to underbed lockers to separate a plug.
At the end of the day, as it stands at the moment, an owner does not HAVE to agree to the test, it is his or her choice, but I have a feeling that once all parks have been made aware of the situation, and received their training, that it will become a standard question when booking "Have you got a current PIR for your van/motorhome"
Owners of vans 3 years and less in age will already have the original certificate so wil not be affected.
On a personal note, I do not know where I am supposed to find the time to carry out these tests and inspections without causing attendance delays to users with much more pressing problems when they arrive on sites and find something does not work, and it is affecting their holiday or use of the van.