Energy and Climate Change CommitteeWritten evidence submitted by the All-Party Parliamentary Carbon Monoxide Group
About the All-Party Parliamentary Carbon Monoxide Group
The All-Party Parliamentary Carbon Monoxide Group (APPCOG) provides a forum for Parliamentarians, gas industry representatives and other key stakeholders to discuss carbon monoxide poisoning in relation to all fuels. It is chaired by Barry Sheerman MP, Jason McCartney MP, and Baroness Finlay of Llandaff.
In 2011, it launched an inquiry, “Preventing Carbon Monoxide Poisoning,”1 chaired by Baroness Finlay. This inquiry estimated that as many as 4,000 people each year2 are diagnosed with low-level carbon monoxide exposure, with a further 200 admittances to hospital with serious injuries, and 50 fatalities every year,3 but it is thought that the true numbers are significantly higher,4 as the vast majority of instances of carbon monoxide poisoning are undiagnosed, and thus, unreported in official statistics.
The inquiry calculated the approximate cost to society, and found that preventing carbon monoxide poisoning could save the UK £178 million a year, as well as avoid immeasurable human tragedy and suffering.5
The report put forward seventeen key recommendations to tackle carbon monoxide poisoning through improved detection, increased awareness, and better regulation of safety standards. The APPCOG works to achieve these recommendations, and related aims which have emerged from working with its key stakeholders.
Introduction
The Energy and Climate Change Committee has asked for submissions commenting on energy prices, profits and poverty. Given the focus of the APPCOG on preventing carbon monoxide poisoning, this response focuses on only those terms of reference which have the scope to increase carbon monoxide safety. Therefore, this document will respond to following issue:
Are there any particular groups that are currently not getting the necessary support from current fuel poverty policies?
Summary of APPCOG Recommendations
Households suffering from fuel poverty are less likely to make the regular checking and servicing of heating and cooking appliances a priority. Similarly, households will be less likely to purchase a carbon monoxide alarm.
Therefore, the definition of fuel poverty must also take into account a consumer’s ability to maintain a safe home. Policies intended to address fuel poverty must ensure that consumers are safe, as well as warm.
Ofgem should re-evaluate gas and electricity supply licenses in light of its new risk-based approach to consumer vulnerability. It recommends that the conditions of licenses move beyond targeting at-risk groups, but rather, target consumers who are in at-risk circumstances in terms of energy safety.
Any information supplied to people receiving the Winter Fuel Payment, or a Cold Weather Payment, should state the importance of getting appliances regularly checked and serviced, and of purchasing a carbon monoxide alarm.
Consumers in fuel poverty living in rented accommodation should be made aware of their landlords’ legal responsibilities under The Gas Safety (Installation and Use) Regulations 1998 to ensure that gas appliances, fittings and flues provided for tenants are safe.
Measures intended to address fuel poverty by improving the energy efficiency of a home through insulation measures may lead to an unintended increase in levels of indoor pollutants, such as carbon monoxide.6
Given the relatively low cost of fitting a carbon monoxide alarm in comparison to the total cost of energy efficiency improvements, the Government should make the installation of a carbon monoxide alarm, where one is not already present, a requirement under the Green Deal installer standard.
Government should encourage energy suppliers to provide a carbon monoxide alarm to consumers receiving assistance under the ECO scheme.
Are there any particular groups that are currently not getting the necessary support from current fuel poverty policies?
1. The APPCOG supports Ofgem’s risk-based approach to consumer vulnerability, as “a dynamic state that can affect anyone at any time and for many different reasons.” It states that vulnerability is “not all about the individual” and “may also be affected by the nature of the market concerned. Its approach focuses on “the risk factors, long- and short-term, which could lead to disadvantage and aims to encourage suppliers and distributors to embed this into how they operate.”7
2. The APPCOG therefore recommends that a similar approach be taken when defining fuel poverty, and that it must include the consumer’s ability to maintain a safe home. It stresses that policies intended to address fuel poverty, from both government and the energy industry, must ensure that consumers are safe, as well as warm.
3. The standard licence conditions of the gas and electricity supply licences require suppliers to establish a list (the Priority Services Register) of domestic customers that are of pensionable age, disabled or chronically sick. Eligible customers can ask to be added to their suppliers list; these customers are then eligible for certain free services specified in the supply licences.8
4. The APPCOG recommends that Ofgem re-evaluate gas and electricity supply licenses in light of its new risk-based approach to consumer vulnerability. It recommends that the conditions of licenses move beyond targeting at-risk groups, but rather, target consumers who are in at-risk circumstances in terms of energy safety, such as consumers who have recently moved house.
5. A report published by the Institute for Fiscal Studies in March 2011 found that the income of the median UK household has fallen by 1.6% since 2008.9 A recent news article from Northern Ireland revealed the measures taken by residents in fuel-poor households to keep warm, which included the use of unsafe appliances and unmaintained appliances.10
6. A recent survey by the Gas Safe Register revealed that 9 million out of 21 million homes using gas do not have annual gas safety checks on their appliances, with 1.6 million admitting to never having had appliances checked. When asked why they did not have their appliances checked, 37% cited cost as the main reason.11 Therefore, it is reasonable to assume that households suffering from fuel poverty will make the regular checking and servicing of heating and cooking appliances even less of a priority. Similarly, households will be less likely to purchase a carbon monoxide alarm.
7. The APPCOG recommends that any information supplied to people receiving the Winter Fuel Payment, or a Cold Weather Payment, should state the importance of getting appliances regularly checked and serviced, and of purchasing a carbon monoxide alarm.
8. In particular, vulnerable homeowners should be made aware of their eligibility to receive free gas safety checks. A recent survey by the Gas Safe Register revealed that 88% of elderly homeowners have never claimed a free gas safety check, and that £134 million worth of gas safety checks go unclaimed.12
9. Consumers living in fuel poverty in rented or Local Authority/Housing Association accommodation should be made aware of their rights as a tenant. Such tenants must be made aware of the need for their landlord’s legal responsibilities under The Gas Safety (Installation and Use) Regulations 1998 to ensure that gas appliances, fittings and flues provided for tenants are safe.
10. Measures intended to address fuel poverty by improving the energy efficiency of a home through insulation measures may lead to an unintended increase in levels of indoor pollutants, such as carbon monoxide.13 Furthermore, there is potentially an increased risk of death and illness from carbon monoxide poisoning if ventilation is reduced while continuing to use old gas heating systems.
11. Given the relatively low cost of fitting a carbon monoxide alarm in comparison to the total cost of energy efficiency improvements, the Government should make the installation of a carbon monoxide alarm, where one is not already present, a requirement under the Green Deal installer standard.
12. Similarly, Government should encourage energy suppliers to provide a carbon monoxide alarm to consumers receiving assistance under the ECO scheme.
February 2013
1 http://www.policyconnect.org.uk/appcog/inquiry-2011. Accessed 31/01/2013.
2 Preventing Carbon Monoxide Poisoning, p. 15
3 Since the publication of the inquiry, this figure has now been revised to 40 deaths per year. http://www.hse.gov.uk/gas/domestic/cross-government-group-1112.pdf
4 A recent study conducted by Liverpool John Moores University in 2011 measured CO levels in 109 homes over a number of weeks: it found that 24 homes had CO levels greater than 50 ppm (parts per million) – a level in which symptoms of poisoning, such as headaches, tiredness, and drowsiness can be experienced. A further 53 homes contained CO levels between 10 and 50 ppm. Similarly, a study conducted at UCL showed that 2% of 597 homes visited were assessed to have a “very high” risk of carbon monoxide exposure, and a further 4% were estimated as having a “high” risk of exposure to concentrations of CO above WHO guideline levels. http://www.hse.gov.uk/gas/domestic/uclgasfinal.pdf
5 Preventing Carbon Monoxide Poisoning, p. 17
6 The Health Impacts of Cold Homes and Fuel Poverty, the Marmot Review Team. http://www.instituteofhealthequity.org/projects/the-health-impacts-of-cold-homes-and-fuel-poverty. Accessed 08/02/2013.
7 Proposals for a new consumer vulnerability strategy, Ofgem, p.6. http://www.ofgem.gov.uk/Sustainability/SocAction/Documents1/Proposals%20for%20a%20new%20Consumer%20Vulnerability%20Strategy.pdf. Accessed 08/02/2013.
8 Energy Affordability: helping develop Ofgem’s Vulnerable Consumers’ Strategy http://www.ofgem.gov.uk/Sustainability/SocAction/Documents1/Energy%20Affordability_helping%20develop%20Ofgem%E2%80%99s%20Vulnerable%20Consumers%E2%80%99%20Strategy.pdf. Accessed 08/02/2013.
9 http://www.ifs.org.uk/pr/pr_210311.pdf. Accessed 08/02/2013.
10 http://strabanechronicle.com/2013/01/17096/. Accessed 08/02/2013.
11 http://www.gassaferegister.co.uk/news/gas_safe_register_news/9_million_british_families_at.aspx?year=2011. Accessed 08/02/2013.
12 http://www.gassaferegister.co.uk/news/gas_safe_register_news/elderly_ignore_free_checks.aspx?year=2011. Accessed 08/03/2013.
13 The Health Impacts of Cold Homes and Fuel Poverty, the Marmot Review Team. http://www.instituteofhealthequity.org/projects/the-health-impacts-of-cold-homes-and-fuel-poverty. Accessed 08/02/2013.