Thank you Damian for the details you have provided.
Hello Highlander,
The actual regulations are very long winded, and written in typical Whitehall gobbledgook and would bore the majority of readers beyond reason.
It would serve no practical purpose to post them in full, besides which it would actually be in breach of a Crown Copyright. If you want to see a copy they like everyone else you would need to purchase a set or perhaps pay a visit to your reference library.
It is far easier to allow an experienced fitter to interpret the regulations as they apply to a given set of circumstances.
From my own experience of working in the manufacturing industry for a number of companies, and having to provide guidance on the application of the regulations (admittedly not the most recent versions) the companies involved decided to err on the side of caution, and arranged for all their fitters to be appropriately trained and assessed and registered (at the time with CORGI).
As in any profession there may be disagreement on some aspects of the interpretation. It is my interpretation that in relation to caravans the full force of the regulations are applicable except that the person undertaking any work on a private caravan gas system does not need to be registered with Gas safe, but they must still be competent in all aspects of the work they work they undertake.
For many years it was commonly assumed that because private touring caravans have their own section in the regulations that states were exempt from the need to use a registered fitter for gas work, that it meant that anybody could undertake work on a the caravans gas system, but in fact all the regulations allowed was that the person undertaking work did not have to be part of a registered scheme of accreditation.
This is why many caravan workshops do not have all their fitters registered with Gas Safe. Interestingly, as Damian points out work on caravans for hire or as part of a commercial business must use registered fitters. Caravan workshops are commercial businesses, so it is a debatable point whether it is in fact legal for a caravan workshop not to have or use registered fitters.
However the remainder of the regulations remain fully in force, in so far that any person working on a gas system must be competent to do so. The duty on the fitter to test the installation still remains and they must work in accordance with the codes of practice and ACOPS.
The practical upshot of this is, it is highly unlikely that anyone other than trained gas fitter would have the necessary knowledge to undertake the job correctly or have access to the required equipment to perform the required testing.
A competent person would not have need to refer a gas related question to a public forum. Posting a question is tantamount to admitting incompetency.
The person who is responsible for a gas installation is legally liable for the safety of that installation. They must ensure that only persons fit to work on the system actually do so. It is often not appreciated that if an installation fails in some way that causes an H&S investigation, and resulting prosecution is pursued through the criminal and not civil courts, and sentences can and do involve fines and prison terms and a criminal record. Action can be taken against the responsible person, and the person who actually worked on the system.
The strange anomaly in the regulations for private caravans are in my view circumvented by the overall impact of the regulations as a whole, and by the increasing complexity of the code of practice and the duties that all fitters have to complete. But as the regulations stand I can only reiterate that a person must be competent to work on any gas installation in a caravan.