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James10  
#1 Posted : 10 June 2019 14:01:06(UTC)
Rank: New forum user
James10

Hi all, hoping for some input to help clarify an audit finding relating to gas safety.

We have industrial furnaces that utilise a flame “curtain” (metal ring with ignited gas jets) to help with various parts of the furnace process. This is not required all the time and the metal ring section is removed by disconnecting a bayonet fitting and fitting a closed cap (difficult to explain). During a recent audit we had the following finding

finding raised as a result of the H&S Legal Compliance Audit. Potential major Breach.

Within the manufacturing process it is noted that engineers in-house carry out some maintenance of equipment, including gas. Some gas related work is reviewed and signed off by a competent gas engineer (contractor). Regulation 3 of the ‘’The Gas Safety (Installation and Use) Regulations 1998 as amended require that ‘’No person shall carry out any work in relation to a gas fitting or gas storage vessel unless he is competent to do so’’. Therefore, I suggest enquiries are made to meet compliance with these regulations taking account of company activities in relation to competence.”

His suggestion being we Gas Safe train/cert our engineers. This is difficult to achieve due to the amount of training required. We utilise a contractor to commission and service our gas equipment (and install the discussed set up). On discussion with the gas engineer he said that the installation was designed to safely allow the changeover, although other than saying the auditor was wrong, he could not highlight why.

On reading the Gas safety reg I find this section, that would indicate (in my mind) that bayonet connections and movable appliance, considering the gas ring as such, would not be considered work as the auditor highlighted.

57 For the purpose of the definition of ‘work’, readily movable appliances include appliances such as laboratory Bunsen burners and mobile barbecues, which are readily portable. Other appliances, eg free-standing cookers connected by a flexible hose, are not considered to be ‘readily movable’, but can be moved temporarily, eg to clean the space they normally occupy; this type of activity is not regarded as ‘work’ within the meaning of GSIUR. (Where an appliance is connected by means of a bayonet fitting, this will need to be disconnected before moving the appliance – such a disconnection is also excluded from the definition of work, as is the connection or reconnection of this type of fitting.)

Just wondering if anyone has more experience with the gas safety reg to add any additional ponts, or has any thoughts on the above points of view?

johnc  
#2 Posted : 10 June 2019 16:59:51(UTC)
Rank: Forum user
johnc

Look at S2(4) of the regs and you might find out the reason re what your gas engineer is stating and your auditor is missing.
James10  
#3 Posted : 10 June 2019 18:05:19(UTC)
Rank: New forum user
James10

Thank you for taking the time to reply Johnc

I did read section 2(4) and thought that this might be where the auditor missed some information. However, in section 3(1)-(2) 81 (C) seems to hold the auditors belief that the engineers would need to be trained and competent to carry out gas work, even at premises that fall outside of the scope of the regulations as in 2(4).

This was why I considered it more from the task they were carrying out, looking at the task to see if it fits under the definition of work as set in the regs.

What do you think, would section 2(4) still apply and as a factory it is out with the scope of the regs? Or would section 3(1)-(2) apply for required training/competence, and then would it be down to the definition of work?

 

johnc  
#4 Posted : 10 June 2019 19:00:00(UTC)
Rank: Forum user
johnc

As the regs do not apply to a factory, except the few exceptions, the auditor cannot quote your organisation breaching them. He could ask under the general duties re training in HASAWA or the training requirements under PUWER and then you use S3 of the regs to state what would be required and this does not ask for HSE approval i.e. Gasafe standard and that bayonet fittings are exempt by definition. Thus if your people have been trained by an appropriate person e.g. your gas engineer or the manufacturer then that will be sufficient.
thanks 2 users thanked johnc for this useful post.
A Kurdziel on 11/06/2019(UTC), James10 on 11/06/2019(UTC)
fairlieg  
#5 Posted : 11 June 2019 09:12:04(UTC)
Rank: Forum user
fairlieg

S2(1) explicitly exempts bayonet fittings in terms of gas work.  Quote it and close the action.  For some reason auditors never read the definitions and interpretations

“work” in relation to a gas fitting includes any of the following activities carried out by any person, whether an employee or not, that is to say—

(a) installing or re-connecting the fitting;

(b) maintaining, servicing, permanently adjusting, disconnecting, repairing, altering or renewing the fitting or purging it of air or gas;

(c) where the fitting is not readily movable, changing its position; and

(d) removing the fitting;

but the expression does not include the connection or disconnection of a bayonet fitting or other self-sealing connector

thanks 1 user thanked fairlieg for this useful post.
James10 on 11/06/2019(UTC)
paul.skyrme  
#6 Posted : 11 June 2019 09:40:42(UTC)
Rank: Super forum user
paul.skyrme

@James10, Fit a suitable self sealing quick release connector, and it becomes exempt from GSIUR as your post illustrates. Just ensure that the connectors are initially fitted by a suitably qualified person.
thanks 1 user thanked paul.skyrme for this useful post.
James10 on 11/06/2019(UTC)
James10  
#7 Posted : 11 June 2019 10:49:44(UTC)
Rank: New forum user
James10

Hi all, thanks for your replies. It is appreciated, and it will help me close out the action.

Yes Paul, I have checked to ensure all the initial fitting of the connectors was carried out by a suitably qualified person.

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