Memorandum submitted by the Chartered Institute of Plumbing and Heating Engineering (FP 56)
The commercial nature and tight margins have created a system which has the potential to impact on both health and safety and the environment. The provision of a not for profit voluntary regulatory framework could if adopted remove pressure on the Warmfront process with regard to quality, resource and safety.
1. There is no doubt that the Warmfront scheme is theoretically a good idea, as it enables those within the community that would otherwise be without adequate central heating and hot water provision to receive a grant to fund (or in some cases to partly subsidise) the installation of a new system. This could be the provision of a new system, or the replacement of an inefficient and/or unsafe system which may include a central heating boiler with the potential to release carbon monoxide.
2. The CIPHE have been
alerted to fundamental flaws in the Warmfront system. For example, there are
members of the general public that are waiting for long periods of time for
work to be carried out; the reasons given by the provider to the public for
this vary from a shortage of competent professionals, to reasons associated
with funding not being released.
3. There are also instances where the installation work is being carried out to not only poor, but also outdated specifications. It has been suggested that this is due to pressures to drive down cost where margins are already tight.
4. If incorrectly installed and maintained, central heating and hot water systems can be extremely dangerous, and it is therefore vitally important that the procedures surrounding the allocation of grants to fund installations does not have an adverse effect on the quality and ultimately the safety of the system that is installed.
5. Members of the public that are seeking to have work undertaken will often either have no central heating and hot water or unsafe/inefficient systems, and it is therefore inappropriate for them to wait due to reasons associated with a 'shortage of workers' to undertake the work, when other evidence would suggest that there are Registered Heating Professionals who could competently undertake this work, but may have otherwise been distanced from the funding system.
6. We have also been made aware that there are incidences where private landlords are exploiting the system, using tenants which satisfy the grant allocation criteria to add value to their property portfolio, via the provision of a government funded central heating and hot water system. This funding should be used in a manner that is fair and equitable and such exploitation should be eradicated. Whilst we welcome the fact that grants are allocated to means tested individuals it is inappropriate for landlords to re-house tenants to lower standard accommodation in order to utilise this targeted funding and benefit from the improvement of their housing stock.
7. If incorrectly installed and maintained, central heating and hot water systems can be extremely dangerous, and it is therefore vitally important that the procedures surrounding the allocation of grants to fund their installation do not have an adverse effect on the quality and ultimately the safety of the system that is installed. This is particularly related to the ebid process which may attract prices which are bid to win business to keep a company solvent but which do not reflect a true price for the job. Lowest price does not always equal best value. Whilst the Institute has no desire to see prices which are not set at competitive market rates, we would not which to see a process which drives behaviours which may impact on public or employee safety or which have an impact on the environment. The CMD regulations in construction were established to address this issue but do not apply to the Warmfront process.
8. We are aware that the system works on a bidding process, and prices are agreed and subsequently set for standard works. Whilst this may be a standard practice, we have been made aware that in some cases this causes Registered Heating Professionals to decline work. The result is that the quality and standard of the work can be adversely affected. In the same light, health and safety issues associated with the number of workers that would be required to safely undertake the work (which cannot be accommodated in the allocated funding), alienates Registered Heating Professionals from the bidding process as this would contravene the code of professional standards..
9. Where heating and hot water installation work is being undertaken in new properties, for example a housing development containing 'identical' houses, it is reasonable to expect that each installation should have a similar duration. However, where existing housing stock is concerned, it is not possible to apply this same logic. The result is that where a set price (which often dictates a set time period), is concerned, quality and standard of work has been shown to be inconsistent; this is detrimental to not only energy efficiency, but also health and safety. Any funding that is associated with bidding should allow for a degree of flexibility, which allows for consistent standards and quality of work, and is therefore not detrimental to health and safety and standards of workmanship.
10. The Chartered Institute of Plumbing and Heating Engineering, a registered charity, operates and voluntarily regulates the Register of Heating Professionals for the benefit of the public, and it should be this register and the competency and professional standards that it represents that should be used as the benchmark for safe and competent central heating and hot water system installations which are funded under the Warmfront scheme. This would ensure that both the quality and standard of work are not undermined as a result of complications which arise where specifications and funding require work to be competed in unreasonable timescales. The removal from the Register through technical or unprofessional behaviour preserves the safety of the public by ensuring that those unable or unwilling to practice at the appropriate standards are removed from the market enhancing both the reputation of the scheme and the profession as a whole.