Hello Jim,
In many cases you have to move the Truma water heater to gain sufficient access to change the element, and in fact with some earlier models, you had to take the entire heater out, and work on a bench. In either case the gas and flue connections have to be disengaged, which definitely brings it into the realms of the Gas Safety Regulations.
I have not seen the latest design, so perhaps access to the element has been improved.
But from another aspect I still interpret the element as being within the realms of the Gas regs; Water containment is a required aspect for the safety of the appliance whether it is working on mains or gas. If the water containment fails due to incorrect fitting of the element, then the appliance as a whole is seen as unsafe, but more importantly it is an unsafe Gas appliance, with all that entails.
Others may take an alternative view on this but where companies need to manage work practices to comply with regulations care has to be taken to ensure the correctly trained persons are working on the appliance.
Jim I must also point out that Gassafe registration is not universally required. First of all it is UK only , and for some strange reason, persons working on their own touring caravan for personal use are exempt from registration BUT they are still required to be competent and conversant with the necessary safety regulations and ACoPS.
Fitters must be registered if working on Touring caravans used for hire.
Gassafe registration is required for all domestic and industrial installation, service, repair and removal work.
I also contend that gas fitters at caravan service depots should be fully trained Gassafe registered.