Advice for Social Landlords – Tenant and Resident Safety – Gas Safety Management Systems
Dear colleague
Background
Following a recent review, we and the HSE are keen to highlight the importance for social landlords of an effective management system for gas safety, and in particular, the critical role of the appropriate handling of initial reports of potential problems with gas appliances or flues.
Social landlords have a duty under Section 3 of Health & Safety at Work etc Act 1974 to ensure that they act in a way which does not put tenants or others at risk. They must ensure that they meet all of their duties on tenant and resident safety; obtain appropriate assurance about their compliance with all relevant safety requirements and ensure that they take prompt action to address any non-compliance.
This note provides advice on the actions social landlords are expected to take, with regard to gas safety management systems, in order to ensure the safety of their tenants and residents.
What is a gas safety management system?
Regulation 36 of The Gas Safety (Installation and Use) Regulations 1998 (GSIUR) requires landlords to ensure gas appliances and flues in their tenants’ homes are safe to use. Alongside the requirement for an annual check and any maintenance resulting from this check, landlords should also have an effective management system in place to deal with any emergency issues raised about this gas equipment by their tenants or others.
A gas safety management system describes the management arrangements which are in place to control the risks associated with gas appliances and flues in tenants’ homes.
Where issues are raised by tenants, these will mostly be communicated via the social landlord themselves or via a call centre operator in a contact centre appointed by the social landlord.
Failure to appropriately triage and correctly identify the nature of the problem reported by the tenant could result in a tenant being injured or killed in their home as well as putting neighbours and members of the public at risk. Front-line call handlers have a vital role to play in keeping tenants, and others, safe.
The management system should be robust and lead to appropriate action to ensure the gas appliances and flues in tenants homes continue to be safe to use and that persons are not put at risk.
The social landlord (or appointed organisation) should therefore have the necessary training, skills, experience and knowledge in place within the management system to recognise danger and take appropriate action to ensure safety when tenants contact them to raise issues.
Staff should be provided with suitable and sufficient information, instruction and training to enable them to understand the risks in regard to gas appliance faults, to make suitable and sufficient enquiries during call handling and to enable them to take the correct remedial action.
The social landlord also has a responsibility to assure themselves that staff, including those employed by a third party to handle initial contact from tenants, have appropriate understanding of these instructions, training and procedures.
HSE has provided some guidelines for social landlords (or their appointed organisation) to consider when designing an effective gas management system. The list, in the Annex, is illustrative rather than exhaustive, and should not be considered as a prescriptive document.
Using an appointed organisation to operate your gas safety management system
Social landlords cannot delegate their Regulation 36 GSIUR duties, even if they contract out the running of the management system to an appointed organisation.
This duty includes any further outsourcing or sub-contracting of this service to a third party by the appointed organisation running a management system on behalf of the social landlord.
Social landlords are therefore ultimately responsible for ensuring safe and appropriate call handling and must assure themselves of this.
If you have any questions on any of these matters please contact the lead regulator for your organisation or contact us.
Yours sincerely,
Ian Brennan
Director of Regulation
Annex - Guidelines when designing an effective gas management system
Social landlords should consider the need for the following:
- clear, robust procedures for a call handler to follow in order to triage calls correctly;
- clear emergency procedures for call handlers to follow;
- an escalation system in place where a call handler can escalate calls that are beyond their level of knowledge and training to suitably qualified persons who can make informed decisions about prioritisation and the appropriate course of action;
- training which includes familiarity with gas terminology for call handlers. This might include, for example, appliance types, flues, chimneys, pilot lights, flame picture, etc.;
- some practical training for call handlers on a range of domestic gas appliances to gain better understanding of their operation and safety issues. This might include the use of a training centre with appliances and mock-up faults; or shadowing an engineer for example; and
- an independent and suitably qualified third party to audit for competence and effectiveness of instructions, training and procedures.
Call handlers should be able to recognise and understand the risks associated with gas fittings (appliances, pipework and meters). They should know the appropriate response action to take when made aware of certain triggers. Such triggers might include:
- reports of a smell of gas or fumes. Call handlers should know that a report must be made to the gas transporter emergency service (SGN) immediately - before local engineers are notified;
- physical damage to fittings (this is not just appliances, but also pipework and meters). Any report of instability, sagging or movement should generate a priority response;
- gas warning notices and do not use labels; and
- staining above or near an appliance.
Please note: This appendix is illustrative, and is not intended as an exhaustive list of issues to consider in designing an effective gas management system.