GAS SAFETY POLICY - Cobalt Housing€¦ · The Gas Safety (Installation and Use) ... point safety...

GAS SAFETY POLICY

of 10 Domestic Gas and Carbon Monoxide Safety Policy

Ref: Pol 15 – 21/01/19 – Revision 2 – Owner: Director of Operations

Lead Director Director of Operations

Reference Pol 15

Committee Review Homes & Neighbourhoods Committee Name – January 2019

Board Approval Jan 2019

Version Date Jan 2019

Review Date Jan 2021



1 Introduction & Aim The Gas Safety Policy details how Cobalt Housing meets the requirements of the Gas Safety (Installation and Use) Amendment Regulations 2018. In addition to this, the policy provides assurance to Cobalt that measures are in place to ensure compliance with the regulations and to identify, manage and/or mitigate risks associated with gas fittings, appliances and flues. The policy is relevant to all Cobalt employees, tenants, contractors and other persons who may work on, occupy, visit, or use its premises, or who may be affected by its activities or services. It should be used by all to ensure they understand the obligations placed upon cobalt to maintain a safe environment for tenants and employees within the home of each tenant and within all non-residential premises or areas of buildings. The policy is also relevant for maintaining a safe environment for all tenants and employees within all Cobalt non-domestic properties. Cobalt will follow a systematic approach to the management of gas safety to ensure it meets the requirements set out in the Gas Safety (Installation and Use) Amendment Regulations 2018 and other relevant legislation relating to gas safety. This is to ensure the safety of tenants, employees and members of the public.

2 Policy Statement The Group recognises its duty to comply with the Gas Safety (Installation and Use) Amendment Regulations 2018 and other relevant legislation and guidance. It is our objective to ensure that gas is managed effectively, and employees understand their duty to contribute to the robust management of gas safety. The key objectives of this policy are to establish:

• Landlord obligations • Gas Safety Principles • Inspection Testing Regime • Construction, Design and Management Regulations 2015 (CDM) Requirements • Compliance Follow up Work • Record Keeping • Component Person • Training • Audit • Non-compliance • Unsafe Situations and Reporting of Injuries, Diseases and Dangerous Occurrences

Regulations



3 Policy Principles Landlord Obligations The Gas Safety (Installation and Use) Amendment Regulations 2018 impose duties on landlords to protect tenants’ safety in their homes with respect to gas safety. The main duties as a landlord are set out in Regulation 36 requiring landlords to:

• Ensure gas fittings and flues are maintained in a safe condition. Gas appliances should be serviced in accordance with the manufacturer’s instructions. If these are not available, it is recommended that they are serviced annually unless advised otherwise by a Gas Safe registered engineer.

• Ensure the annual safety check is carried out on each gas appliance and flue within 12 months of the previous safety check.

• Have all installation, maintenance and safety checks carried out by a Gas Safe registered engineer.

• Keep a record of each safety check for at least two years. • Issue a copy of the latest safety check record to existing tenants within 28 days of the

check being completed, or to any new tenant before they move in. • Display a copy of the latest safety check record in a common area of a building where the

gas appliance serves a communal heating system to multiple homes. In addition, landlords’ must ensure that no gas fitting of a type that would contravene Regulation 30 (e.g. certain gas fires and instantaneous water heaters) is fitted in any room occupied or to be occupied as sleeping accommodation after the Regulations came into force. This includes any room converted into such accommodation after that time. Gas Safety Principles Cobalt will hold accurate records against each property it owns or manages setting out the requirements for gas safety checks and servicing of all gas fittings, appliances and flues. Cobalt will periodically (not more than intervals of 5 years) commission an external asset data review (known as a Fulcrum Report) with British Gas to ensure adequate assurance is provided that gas supply data held against its property assets is accurate and up to date. Cobalt will ensure that each tenanted property requiring a gas safety check and/or service will have a landlords’ gas safety record (LGSR) that has a completion date not more than 12 months following the completion date of the previous LGSR relating to the property or installation date of new installations. Cobalt will ensure that copies of all LGSRs are provided to tenants within 28 days of completion or displayed in a common area where necessary upon completion of the LGSR. Cobalt will cap off gas supplies to all properties when the property becomes void. Cobalt will cap off gas supplies to all new build properties at handover if the new tenancy is not commencing immediately at the point of handover. Cobalt will reinstate gas supplies to void properties and new build properties at commencement of the new tenancy and will undertake a gas safety check and issue a new LGSR.



Cobalt will ensure that gas safety checks are carried out prior to, or immediately following the commencement of any new tenancy (void properties), mutual exchange and/or transfer and that the tenant receives a copy of the LGSR prior to, or immediately after moving in. Cobalt will carry out gas safety checks of any tenants’ own gas appliances and will carry out a six point safety check for gas cookers and gas fires. Where appliances are found to be faulty these will be disconnected, and a warning notice issued. Cobalt will test and replace (to BS EN 50292) as necessary smoke alarms as part of the annual gas safety check visit. Cobalt will install and subsequently test and replace carbon monoxide detectors in properties with open flued appliances as part of the annual gas safety check visit. Cobalt will carry out an annual gas safety check to all properties where the gas supply is inactive (capped). This is to ensure that gas supplies have not been reconnected by the tenant. Cobalt will carry out annual assessments of properties where tenants have chosen for personal reasons not to use the gas supply in the property. This is to check on the tenant’s wellbeing and also to assess that the lack of gas heating is not adversely affecting the condition of the property. Cobalt will ensure that only suitably competent Gas Safe accredited engineers undertake gas works for the Group. Cobalt will remove any open flue gas appliances found in any rooms that are being used as bedrooms. Cobalt will carry out a gas safety check and issue a new LGSR for the whole property following the installation of new gas appliances. Cobalt will ensure that robust processes and controls are in place to manage works to void and occupied properties that may affect existing gas installations. Cobalt will have a robust process in place to gain access to properties where tenant vulnerability issues are known or identified whilst ensuring timely access to any property in order to be compliant with this policy and safeguard the wellbeing of the tenant. Cobalt will ensure that all solid fuel, chimney stacks, oiled fire appliances and flues are inspected and maintained at least annually and that this work is completed by a suitably competent engineer. Inspection Testing Regime Cobalt will carry out a program of annual gas safety checks and services to all domestic properties. This check will include all gas fittings, appliances and flues in the property and will be completed 12 months from the date of the previous LGSR. This safety check is driven from the anniversary date of the most recent LGSR which may have been carried out at the start of a new tenancy or following installation of new gas appliances. Cobalt will carry out a program of annual gas safety checks and services to all non-domestic properties. These checks will include all gas fittings, appliances and flues in the property and will be completed no longer than 12 months from the date of the previous LGSR or as detailed within



manufacturer’s instructions. These safety checks and maintenance services will be carried out by a suitably competent engineer in accordance with the manufacturer’s instructions. These installations may include catering equipment, boilers serving communal heating systems, combined heat and power systems and water heating boilers. Cobalt will carry out a program of annual safety checks and services to all solid fuel systems. This check will include all fittings, appliances and flues in the property and will be completed no longer than 12 months from the date of the previous safety check and service or as detailed within manufacturer’s instructions or industry best practice. These safety checks and maintenance services will be carried out by a suitably competent engineer in accordance with the manufacturer’s instructions. Construction, Design and Management Regulations 2015 (CDM) Requirements To comply with the requirements of the Construction, Design and Management Regulations 2015 (CDM) a Construction Phase Plan will be completed for all void works, component replacement works and refurbishment projects. This plan will detail any gas installations that may be affected by the works and detail all necessary gas work required to make safe and reinstate gas installations including the requirement for a new gas safety check, maintenance service and LGSR. Cobalt will ensure robust management processes are in place should advantage be taken of changes to Part F, Regulation 36 (3) of the Gas Safety (Installation and Use) (Amendment) Regulations 2018. The regulation allows that should a new gas safety check be completed within 10 months and 1 day of the previous safety check then the new LGSR can be dated as the 12-month post the anniversary date of the previous LGSR. Compliance Follow up Work Cobalt will ensure there is a robust process in place for the management of any follow-up works required following the completion of a gas, oil or solid fuel safety check. Cobalt will ensure that there is a robust process in place to collate and store all warning notices and associated records of completed remedial works. Cobalt will replace any faulty smoke alarms in a property where faults are identified as part of the annual safety check. A safety check will be carried out on completion of any repair and/or refurbishment works to occupied or void properties where works may have affected any gas fittings, appliances or flues. Cobalt will ensure there is a robust process in place to investigate and manage all RIDDOR notices issued with regard to gas safety. Record Keeping Cobalt will establish and maintain a core asset register of all properties that have an active or inactive gas supply (Orchard). This register will also hold data against each property asset of gas and solid fuel inspection and servicing requirements for all domestic and non-domestic property assets.



Cobalt will ensure the Gas Safe registered engineer records the details of all appliances and other equipment which is served by the gas supply in every domestic and non-domestic property. Cobalt will establish and maintain accurate records of all completed safety records, warning notices and associated remedial works and keep these for a period of not less than two years. Cobalt will hold and maintain accurate records on the qualifications of all engineers undertaking gas works. Competent Persons Cobalt will ensure that the manager with lead responsibility for operational delivery is appropriately qualified; holding a recognised gas safety compliance management qualification. Cobalt will ensure that only suitably competent Gas Safe accredited contractors are procured and appointed to undertake works to gas fittings, appliances and flues. The compliance team with responsibility for delivery will check the relevant qualifications of employees working for these contractors to ensure that all persons are appropriately qualified and accredited for the work that they are carrying out. These checks will be undertaken on an annual basis. Cobalt will ensure that only suitably competent HETAS accredited contractors are procured and appointed to undertake solid fuel fittings, appliances and flues. HETAS is a not for profit organisation offering competent person scheme for installers of biomass and solid fuel heating, registration for retailers and chimney sweeps and approval of appliances and fuels. The operational team with responsibility for delivery will check the relevant qualifications of employees working for these contractors to ensure that all persons are appropriately qualified and accredited for the work that they are carrying out. These checks will be undertaken on an annual basis with chimney sweeps undertaken twice a year. Training This policy and the procedures that support it will be subject to a range of training across Cobalt. The training will be bespoke to the individuals and refresher training will be provided as appropriate. Training will include team briefings for those employees who need to have a basic understanding and awareness of gas safety but who may not be actively involved in the delivery of the gas safety policy. This will be basic gas safety awareness training. On the job training will be provided to those employees who will be responsible for managing the program of gas safety checks and repair works. The manager with lead responsibility for operational delivery will hold a relevant gas safety compliance management qualification. Audit Cobalt will carry out independent third-party quality assurance audits of gas safety checks, gas appliance services and gas appliance repair works. Best practice suggests this should be a 5% sample of the total gas safety works carried out.



Cobalt will carry out an independent audit of gas safety at least once every two years. This audit will specifically test for compliance with the regulation, legislation and codes of practice and identify any non-compliance issues for correction. Non-Compliance Any non-compliance issue identified at an operational level will be formally reported to the Director of Operations in the first instance. The Director of Operations will agree an appropriate course of corrective action with the compliance team in order to address the non-compliance issue and report details of the same to members of the Executive Management Team. The Executive Management Team will ensure Boards and the Audit & Risk Committee are made aware of any non-compliance issue so they can consider the implications and take action as appropriate. In cases of a serious non-compliance issue the Executive Management Team and the Board will consider whether it is necessary to disclose the issue to the Homes England in the spirit of co-regulation as part of the Regulatory Framework. Unsafe Situations and Reporting of Injuries, Diseases and Dangerous Occurrences Regulations Any smell of gas or suspected symptom of carbon monoxide poisoning detected by or reported to any employee will be treated as a gas emergency and immediately reported to the National Gas Emergency Service Provider. Any gas apparatus encountered by gas engineers/technicians or technical managers that is identified as not being able to be used without constituting a danger shall be made safe. Cobalt recognises its duty to report unsafe situations under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013. Any such cases will be reported immediately to the Compliance Team and relevant action will be taken.



4 Risk Management The key risk associated with non-delivery of this Policy is: Risk Register Ref: Risk:

COMP 02 - Health & safety breach - gas safety

Failure to comply with key landlord Health & Safety responsibilities for gas safety resulting in Health & Safety, compliance and regulatory breaches.

Risk Consequences: Management and Mitigation: • Health & Safety breaches – Staff &

Contractors • Health & Safety – landlord

compliance breaches • Breach of regulatory requirements

resulting in fines, penalties or criminal action

• Housing regulator adverse grading/intervention

• Insurance claims – customers/staff/contractors

• Negative Media/Reputation

• Approved Gas Safety Policy • Effective Procedure and Processes • Effective use of OHMS Attributes • Robust SQL Reports • Auto Generated Compliance Letters and Events • Effective Forced Access Process working with

LCC • Third Party Quality Audits Completed on 10% of

gas services • Robust procurement including competency of

the contractor and operatives • Knowledgeable and Experienced Staff • Monthly Performance Meetings Held with the

Contractor and Auditors • Contractors paid for works upon receipt of

certification • Monthly KPI reported to board and EMT to

demonstrate gas safety performance • 10 month servicing cycle on the gas safety

programme Key Risk Indicators and Control Limits Detailed below are the key performance indicators that are reported to board via the landlord compliance report.

• Total Number of properties with no gas supply • Total Number of properties with a gas supply • Percentage of properties with a valid gas safety certificate • Total Number of properties with Solid Fuel • Percentage of properties with a valid Solid Fuel certificate



5 Regulatory & Legislative Compliance Regulatory Standards The application of this policy will ensure compliance with the regulatory framework and consumer standards (Home Standard) for social housing in England, which was introduced by the Homes & Communities Agency (HCA) in April 2012. Legislation The principle legislation applicable to this policy is The Gas Safety (Installation and Use) Amendment Regulations 2018. Cobalt has a legal obligation under Part F, Regulation 36 of the legislation (Duties of Landlords) and is the ‘Landlord’ for the purposes of the legislation. Code of Practice The principle codes of practice applicable to this policy are: ACoP L56 - ‘Safety in the installation and use of gas systems and appliances’ (4th edition 2013). INDG285 - ‘A guide to landlords’ duties: Gas Safety (Installation and Use) Regulations 1998’.

Additional Legislation This policy also operates in the context of the following additional legislation: Health and Safety at Work Act 1974 The Management of Health and Safety at Work Regulations 1999 The Workplace (Health Safety & Welfare) Regulations 1992 Gas Safety (Management) Regulations 1996 (as amended) Dangerous Substances and Explosive Atmospheres Regulations 2002 Pressure Systems Safety Regulations 2000 Pipelines Safety Regulations 1996 Health and Safety (Safety Signs and Signals) Regulations 1996 Provision and Use of Work Equipment Regulations 1998 Construction, Design and Management Regulations 2015 Landlord and Tenant Act 1985 Data Protection Act 1998 RIDDOR 2013

6 Links to Other Key Documents Asset Management Strategy 2018 Health & Safety Policy - 2018 Asbestos Management Policy 2019 Repairs Policy 2019



7 Governance of this Policy

Equality and Diversity

Customers and vulnerabilities are taken into account in the development of any policies, procedures and plans and Cobalt will provide a tailored approach in respect of service delivery where possible. An equality statement will be developed by 31st March 2019 to ensure all asset and repairs service areas adapt to the requirements of customer vulnerabilities.

Financial and Links to VfM

Gas safety will require budget provision for the annual servicing requirements and to allow for recommendations from the gas safety inspection programme. Training for staff requires sufficient budget.

Privacy and Data Protection

Consideration in terms of GDPR needs to be factored in where access is required to undertake a gas safety inspection and tenant contact information is passed to the contractor.

Health and Safety

Failure to implement this policy carries significant risk in terms of health and safety for tenants, staff and contractors and embedding the policy will ensure landlord compliance for Cobalt.

Development and Consultation

The Gas Safety Policy details how Cobalt Housing meets the requirements of the Gas Safety (Installation and Use) Amendment Regulations 2018. In addition to this, the policy provides assurance to Cobalt that measures are in place to ensure compliance with the regulations and to identify, manage and/or mitigate risks associated with gas fittings, appliances and flues. The consultative panel have reviewed the policy prior to its approval and recommendations have been adopted in the final version.

Customer Profiles and Accessing Services Data

Relevant data will be used to determine if a tenant requires support where access to a property is to be obtained.

Monitoring and Review

Performance of the following in respect of gas safety will be reported to the relevant committee and to board as part of the Landlord Compliance Report:

• Total Number of properties with no gas supply • Total Number of properties with a gas supply • Percentage of properties with a valid gas safety certificate • Total Number of properties with Solid Fuel • Percentage of properties with a valid Solid Fuel certificate

Roles & Responsibility

The Director of Operations is responsible to the Chief Executive and the Board for ensuring the effective implementation of this policy. Implementation of and adherence to the policy will be monitored by the Board.

8 Definitions LGSR - Landlords’ Gas Safety Record CDM - Construction, Design and Management Regulations 2015 HETAS - Heating Equipment Testing and Approval Scheme RIDDOR - Reporting of Injuries, Diseases and Dangerous Occurrences Regulations

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