Building Regulations

Written evidence submitted by the Heating and Hotwater Industry Council

Overview of HHIC

The Heating & Hotwater Industry Council (HHIC) is a trade association that represents the UK domestic heating industry. Members include all sectors of supply chain including manufactures, merchants, installers and service providers. HHIC membership covers most types of domestic heating products and systems including traditional central heating systems and most low carbon and renewable heating technologies.

The industry which HHIC represents is committed to working with Government to transform the domestic market for energy and heat. This will require a range of products and technologies, including renewable, and also other low carbon technologies which can make the most effective use of existing energy supplies and infrastructures.

Summary of response

· This response considers the issues surrounding gas installations and repairs.

· HHIC believe that significant improvements have been made in the installation of gas appliances as a result of the development of the Building Regulations.

· Government has continued to involve industry in the development of the Regulations and the associated documents and is easier to access by installers due to them being on line

· Better recording of information relating to the installation would be beneficial and we are currently investigating options to go towards and electronic Benchmark form which is used by installers as a means on complying with the Building Regulations.

· HHIC would strongly oppose and reduction in the scope of Building Regulations as great strides have been taken in recent years to improve the safety of installations.

· HHIC would like to see a joining up of schemes e.g. Competent Persons, MCS, Green Deal and in particular the need for common or mutually accepta ble installation standards. We w ould also suggest a single registration scheme for installers to make life easier for them and householders, reduce costs and improve compliance.

Response

Question:-

· Are the Building Regulations adequate in safeguarding health and safety in domestic dwellings?

Response:-

· Significant steps have been taken since the introduction of the Competent Persons Schemes and in our opinion has led to a significant improvement in the safety of installations.

· Levels of efficiency for appliances has increased which is leading to benefits in terms of safety appliances as well as the impact on Climate Change.

· The Domestic Building Services Compliance Guide acts as the ‘bible’ for installers on installation giving guidance to the minimum requirements as well as best practice in some cases and provides a level of consistency to the interpretation of the Regulations.

Question:-

· What are the costs of complying with the Regulations?

Response:-

· The costs of compliance can be significant if there are differences between the England, Wales, Scotland and Northern Ireland regulations and should, wherever possible, be the same. Cost is incurred in terms of product range and stocking, installer training.

Question:-

· How could the Regulations be revised to be streamlined and made more effective?

Response:-

· To give it real value, HHIC believe that Government should look at the effectiveness of implementing the regulations. Gas Safe Register data suggests that 250,000 gas installations are carried out ever year by individuals who are not part of a Competent Persons Scheme.

· Our view is that compliance with the regulations needs to be more closely monitored to start overcoming this problem on non competent engineers being involved with installations.

· HHIC would like to see a joining up of schemes e.g. Competent Persons, MCS, Green Deal and in particular the need for common or mutually acceptable installation standards. We would also suggest a single registration scheme for installers to make life easier for them and householders, reduce costs and improve compliance.

Question:-

· What would be the consequence of the removal or significant reduction of the scope of the Building Regulations so far as they apply to electrical and gas installation and repairs in dwellings?

Response:-

· For gas installation and repair, HHIC would be extremely concerned if there was to be reduction in the scope of Building Regulations. Whilst in is not a perfect model, it does, by and large, work.

· Our understanding is that the Regulations have been based upon the evidence of risk and on this basis any removal or reduction of the scope would have to be evidenced based.

· There is also another important aspect of consumer behaviour. HHIC’s opinion is that regulations are needed to drive change. A good example of this was the move to condensing boilers. Prior to the change, only about 10% of boilers installed were condensing. This moved to nearly 90% 3 months after the implementation of the Regulation.

Heating and Hotwater Industry Council

January 2012

Prepared 14th February 2012