Gas Safety Policy - Cobalt Housing

 
Gas Safety
                        Policy

Lead Director             Jason Cannon
                          Director of Operations
EMT Review                January 2019

                          Homes & Neighbourhoods Committee Name –
Committee Review          January 2019

                          January 2019
Board Approval

Review Date               January 2021

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                   Gas Safety Policy January 2019
1       Introduction & Aim

The Gas Safety Policy details how Cobalt Housing meets the requirements of the Gas Safety
(Installation and Use) Amendment Regulations 2018. In addition to this, the policy provides
assurance to Cobalt that measures are in place to ensure compliance with the regulations and to
identify, manage and/or mitigate risks associated with gas fittings, appliances and flues.

The policy is relevant to all Cobalt employees, tenants, contractors and other persons who may
work on, occupy, visit, or use its premises, or who may be affected by its activities or services. It
should be used by all to ensure they understand the obligations placed upon cobalt to maintain a
safe environment for tenants and employees within the home of each tenant and within all non-
residential premises or areas of buildings.

The policy is also relevant for maintaining a safe environment for all tenants and employees within
all Cobalt non-domestic properties.

Cobalt will follow a systematic approach to the management of gas safety to ensure it meets the
requirements set out in the Gas Safety (Installation and Use) Amendment Regulations 2018 and
other relevant legislation relating to gas safety. This is to ensure the safety of tenants, employees
and members of the public.

2       Policy Statement
The Group recognises its duty to comply with the Gas Safety (Installation and Use) Amendment
Regulations 2018 and other relevant legislation and guidance. It is our objective to ensure that
gas is managed effectively, and employees understand their duty to contribute to the robust
management of gas safety.

The key objectives of this policy are to establish:

    •   Landlord obligations
    •   Gas Safety Principles
    •   Inspection Testing Regime
    •   Construction, Design and Management Regulations 2015 (CDM) Requirements
    •   Compliance Follow up Work
    •   Record Keeping
    •   Component Person
    •   Training
    •   Audit
    •   Non-compliance
    •   Unsafe Situations and Reporting of Injuries, Diseases and Dangerous Occurrences
        Regulations

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                                 Gas Safety Policy January 2019
3       Policy Principles
Landlord Obligations

The Gas Safety (Installation and Use) Amendment Regulations 2018 impose duties on landlords
to protect tenants’ safety in their homes with respect to gas safety. The main duties as a landlord
are set out in Regulation 36 requiring landlords to:

    •   Ensure gas fittings and flues are maintained in a safe condition. Gas appliances should
        be serviced in accordance with the manufacturer’s instructions. If these are not available,
        it is recommended that they are serviced annually unless advised otherwise by a Gas Safe
        registered engineer.
    •   Ensure the annual safety check is carried out on each gas appliance and flue within 12
        months of the previous safety check.
    •   Have all installation, maintenance and safety checks carried out by a Gas Safe registered
        engineer.
    •   Keep a record of each safety check for at least two years.
    •   Issue a copy of the latest safety check record to existing tenants within 28 days of the
        check being completed, or to any new tenant before they move in.
    •   Display a copy of the latest safety check record in a common area of a building where the
        gas appliance serves a communal heating system to multiple homes.

In addition, landlords’ must ensure that no gas fitting of a type that would contravene Regulation
30 (e.g. certain gas fires and instantaneous water heaters) is fitted in any room occupied or to be
occupied as sleeping accommodation after the Regulations came into force. This includes any
room converted into such accommodation after that time.

Gas Safety Principles

Cobalt will hold accurate records against each property it owns or manages setting out the
requirements for gas safety checks and servicing of all gas fittings, appliances and flues.

Cobalt will periodically (not more than intervals of 5 years) commission an external asset data
review (known as a Fulcrum Report) with British Gas to ensure adequate assurance is provided
that gas supply data held against its property assets is accurate and up to date.

Cobalt will ensure that each tenanted property requiring a gas safety check and/or service will
have a landlords’ gas safety record (LGSR) that has a completion date not more than 12 months
following the completion date of the previous LGSR relating to the property or installation date of
new installations.

Cobalt will ensure that copies of all LGSRs are provided to tenants within 28 days of completion
or displayed in a common area where necessary upon completion of the LGSR.

Cobalt will cap off gas supplies to all properties when the property becomes void.

Cobalt will cap off gas supplies to all new build properties at handover if the new tenancy is not
commencing immediately at the point of handover.

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                                 Gas Safety Policy January 2019
Cobalt will reinstate gas supplies to void properties and new build properties at commencement
of the new tenancy and will undertake a gas safety check and issue a new LGSR.

Cobalt will ensure that gas safety checks are carried out prior to, or immediately following the
commencement of any new tenancy (void properties), mutual exchange and/or transfer and that
the tenant receives a copy of the LGSR prior to, or immediately after moving in.

Cobalt will carry out gas safety checks of any tenants’ own gas appliances and will carry out a six
point safety check for gas cookers and gas fires. Where appliances are found to be faulty these
will be disconnected, and a warning notice issued.

Cobalt will test and replace (to BS EN 50292) as necessary smoke alarms as part of the annual
gas safety check visit.

Cobalt will install and subsequently test and replace carbon monoxide detectors in properties with
open flued appliances as part of the annual gas safety check visit.

Cobalt will carry out an annual gas safety check to all properties where the gas supply is inactive
(capped). This is to ensure that gas supplies have not been reconnected by the tenant.

Cobalt will carry out annual assessments of properties where tenants have chosen for personal
reasons not to use the gas supply in the property. This is to check on the tenant’s wellbeing and
also to assess that the lack of gas heating is not adversely affecting the condition of the property.

Cobalt will ensure that only suitably competent Gas Safe accredited engineers undertake gas
works for the Group.

Cobalt will remove any open flue gas appliances found in any rooms that are being used as
bedrooms.

Cobalt will carry out a gas safety check and issue a new LGSR for the whole property following
the installation of new gas appliances.

Cobalt will ensure that robust processes and controls are in place to manage works to void and
occupied properties that may affect existing gas installations.

Cobalt will have a robust process in place to gain access to properties where tenant vulnerability
issues are known or identified whilst ensuring timely access to any property in order to be
compliant with this policy and safeguard the wellbeing of the tenant.

Cobalt will ensure that all solid fuel, chimney stacks, oiled fire appliances and flues are inspected
and maintained at least annually and that this work is completed by a suitably competent engineer.

Inspection Testing Regime

Cobalt will carry out a programme of annual gas safety checks and services to all domestic
properties. This check will include all gas fittings, appliances and flues in the property and will be
completed 12 months from the date of the previous LGSR. This safety check is driven from the
anniversary date of the most recent LGSR which may have been carried out at the start of a new
tenancy or following installation of new gas appliances.

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                                 Gas Safety Policy January 2019
Cobalt will carry out a programme of annual gas safety checks and services to all non-domestic
properties. These checks will include all gas fittings, appliances and flues in the property and will
be completed no longer than 12 months from the date of the previous LGSR or as detailed within
manufacturer’s instructions. These safety checks and maintenance services will be carried out by
a suitably competent engineer in accordance with the manufacturer’s instructions. These
installations may include catering equipment, boilers serving communal heating systems,
combined heat and power systems and water heating boilers.

Cobalt will carry out a programme of annual safety checks and services to all solid fuel systems.
This check will include all fittings, appliances and flues in the property and will be completed no
longer than 12 months from the date of the previous safety check and service or as detailed within
manufacturer’s instructions or industry best practice. These safety checks and maintenance
services will be carried out by a suitably competent engineer in accordance with the
manufacturer’s instructions.

Construction, Design and Management Regulations 2015 (CDM) Requirements

To comply with the requirements of the Construction, Design and Management Regulations 2015
(CDM) a Construction Phase Plan will be completed for all void works, component replacement
works and refurbishment projects. This plan will detail any gas installations that may be affected
by the works and detail all necessary gas work required to make safe and reinstate gas
installations including the requirement for a new gas safety check, maintenance service and
LGSR.

Cobalt will ensure robust management processes are in place should advantage be taken of
changes to Part F, Regulation 36 (3) of the Gas Safety (Installation and Use) (Amendment)
Regulations 2018. The regulation allows that should a new gas safety check be completed within
10 months and 1 day of the previous safety check then the new LGSR can be dated as the 12-
month post the anniversary date of the previous LGSR.

Compliance Follow up Work

Cobalt will ensure there is a robust process in place for the management of any follow-up works
required following the completion of a gas, oil or solid fuel safety check.

Cobalt will ensure that there is a robust process in place to collate and store all warning notices
and associated records of completed remedial works.

Cobalt will replace any faulty smoke alarms in a property where faults are identified as part of the
annual safety check.

A safety check will be carried out on completion of any repair and/or refurbishment works to
occupied or void properties where works may have affected any gas fittings, appliances or flues.

Cobalt will ensure there is a robust process in place to investigate and manage all RIDDOR
notices issued with regard to gas safety.

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                                 Gas Safety Policy January 2019
Record Keeping

Cobalt will establish and maintain a core asset register of all properties that have an active or
inactive gas supply (Orchard). This register will also hold data against each property asset of gas
and solid fuel inspection and servicing requirements for all domestic and non-domestic property
assets.

Cobalt will ensure the Gas Safe registered engineer records the details of all appliances and other
equipment which is served by the gas supply in every domestic and non-domestic property.

Cobalt will establish and maintain accurate records of all completed safety records, warning
notices and associated remedial works and keep these for a period of not less than two years.

Cobalt will hold and maintain accurate records on the qualifications of all engineers undertaking
gas works.

Competent Persons

Cobalt will ensure that the manager with lead responsibility for operational delivery is
appropriately qualified; holding a recognised gas safety compliance management qualification.

Cobalt will ensure that only suitably competent Gas Safe accredited contractors are procured and
appointed to undertake works to gas fittings, appliances and flues. The compliance team with
responsibility for delivery will check the relevant qualifications of employees working for these
contractors to ensure that all persons are appropriately qualified and accredited for the work that
they are carrying out. These checks will be undertaken on an annual basis.

Cobalt will ensure that only suitably competent HETAS accredited contractors are procured and
appointed to undertake solid fuel fittings, appliances and flues. HETAS is a not for profit
organisation offering competent person scheme for installers of biomass and solid fuel heating,
registration for retailers and chimney sweeps and approval of appliances and fuels. The
operational team with responsibility for delivery will check the relevant qualifications of employees
working for these contractors to ensure that all persons are appropriately qualified and accredited
for the work that they are carrying out. These checks will be undertaken on an annual basis with
chimney sweeps undertaken twice a year.

Training

This policy and the procedures that support it will be subject to a range of training across Cobalt.
The training will be bespoke to the individuals and refresher training will be provided as
appropriate.

Training will include team briefings for those employees who need to have a basic understanding
and awareness of gas safety but who may not be actively involved in the delivery of the gas safety
policy. This will be basic gas safety awareness training.

On the job training will be provided to those employees who will be responsible for managing the
programme of gas safety checks and repair works. The manager with lead responsibility for
operational delivery will hold a relevant gas safety compliance management qualification.

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                                 Gas Safety Policy January 2019
Audit

Cobalt will carry out independent third-party quality assurance audits of gas safety checks, gas
appliance services and gas appliance repair works. Best practice suggests this should be a 5%
sample of the total gas safety works carried out.

Cobalt will carry out an independent audit of gas safety at least once every two years. This audit
will specifically test for compliance with the regulation, legislation and codes of practice and
identify any non-compliance issues for correction.

Non-Compliance

Any non-compliance issue identified at an operational level will be formally reported to the Director
of Operations in the first instance.

The Director of Operations will agree an appropriate course of corrective action with the
compliance team in order to address the non-compliance issue and report details of the same to
members of the Executive Management Team.

The Executive Management Team will ensure Boards and the Audit & Risk Committee are made
aware of any non-compliance issue so they can consider the implications and take action as
appropriate.

In cases of a serious non-compliance issue the Executive Management Team and the Board will
consider whether it is necessary to disclose the issue to the Homes England in the spirit of co-
regulation as part of the Regulatory Framework.

Unsafe Situations and Reporting of Injuries, Diseases and Dangerous Occurrences
Regulations

Any smell of gas or suspected symptom of carbon monoxide poisoning detected by or reported
to any employee will be treated as a gas emergency and immediately reported to the National
Gas Emergency Service Provider.

Any gas apparatus encountered by gas engineers/technicians or technical managers that is
identified as not being able to be used without constituting a danger shall be made safe.

Cobalt recognises its duty to report unsafe situations under the Reporting of Injuries, Diseases
and Dangerous Occurrences Regulations 2013. Any such cases will be reported immediately to
the Compliance Team and relevant action will be taken.

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                                 Gas Safety Policy January 2019
4           Risk Management

The key risk associated with non-delivery of this Policy is:

 Risk Register Ref:                                 Risk:

                                                    Failure to comply with key landlord Health &
 COMP 02 - Health & safety breach - gas             Safety responsibilities for gas safety resulting
 safety                                             in Health & Safety, compliance and
                                                    regulatory breaches.

 Risk Consequences:                                 Management and Mitigation:
                                                      • Approved Gas Safety Policy
        •    Health & Safety breaches – Staff &       • Effective Procedure and Processes
             Contractors                              • Effective use of OHMS Attributes
        •    Health & Safety – landlord               • Robust SQL Reports
             compliance breaches                      • Auto Generated Compliance Letters
        •    Breach of regulatory requirements           and Events
             resulting in fines, penalties or         • Effective Forced Access Process
             criminal action                             working with LCC
        •    Housing regulator adverse                • Third Party Quality Audits Completed
             grading/intervention                        on 10% of gas services
        •    Insurance claims –                       • Robust procurement including
             customers/staff/contractors                 competency of the contractor and
        •    Negative Media/Reputation                   operatives
                                                      • Knowledgeable and Experienced Staff
                                                      • Monthly Performance Meetings Held
                                                         with the Contractor and Auditors
                                                      • Contractors paid for works upon
                                                         receipt of certification
                                                      • Monthly KPI reported to board and
                                                         EMT to demonstrate gas safety
                                                         performance
                                                      • 10 month servicing cycle on the gas
                                                         safety programme

Key Risk Indicators and Control Limits

Detailed below are the key performance indicators that are reported to board via the landlord
compliance report.

    •       Total Number of properties with no gas supply
    •       Total Number of properties with a gas supply

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                                   Gas Safety Policy January 2019
•   Percentage of properties with a valid gas safety certificate
    •   Total Number of properties with Solid Fuel
    •   Percentage of properties with a valid Solid Fuel certificate

5       Regulatory & Legislative Compliance

Regulatory Standards

The application of this policy will ensure compliance with the regulatory framework and consumer
standards (Home Standard) for social housing in England, which was introduced by the Homes
& Communities Agency (HCA) in April 2012.

Legislation

The principle legislation applicable to this policy is The Gas Safety (Installation and Use)
Amendment Regulations 2018. Cobalt has a legal obligation under Part F, Regulation 36 of the
legislation (Duties of Landlords) and is the ‘Landlord’ for the purposes of the legislation.

Code of Practice

The principle codes of practice applicable to this policy are:

ACoP L56 - ‘Safety in the installation and use of gas systems and appliances’ (4th edition 2013).
INDG285 - ‘A guide to landlords’ duties: Gas Safety (Installation and Use) Regulations 1998’.

Additional Legislation

This policy also operates in the context of the following additional legislation:
Health and Safety at Work Act 1974
The Management of Health and Safety at Work Regulations 1999
The Workplace (Health Safety & Welfare) Regulations 1992
Gas Safety (Management) Regulations 1996 (as amended)
Dangerous Substances and Explosive Atmospheres Regulations 2002
Pressure Systems Safety Regulations 2000
Pipelines Safety Regulations 1996
Health and Safety (Safety Signs and Signals) Regulations 1996
Provision and Use of Work Equipment Regulations 1998
Construction, Design and Management Regulations 2015
Landlord and Tenant Act 1985
Data Protection Act 1998
RIDDOR 2013

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                                 Gas Safety Policy January 2019
6     Links to Other Key Documents

Asset Management Strategy 2018
Health & Safety Policy - 2018
Asbestos Management Policy 2019
Repairs Policy 2019

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                           Gas Safety Policy January 2019
7    Governance of this Policy
Equality and      Customers and vulnerabilities are taken into account in the development of
Diversity         any policies, procedures and plans and Cobalt will provide a tailored
                  approach in respect of service delivery where possible.

                  An equality statement will be developed by 31st March 2019 to ensure all
                  asset and repairs service areas adapt to the requirements of customer
                  vulnerabilities.
Financial and     Gas safety will require budget provision for the annual servicing
Links to VfM      requirements and to allow for recommendations from the gas safety
                  inspection programme. Training for staff requires sufficient budget.
Privacy and       Consideration in terms of GDPR needs to be factored in where access is
Data Protection   required to undertake a gas safety inspection and tenant contact
                  information is passed to the contractor.
Health and        Failure to implement this policy carries significant risk in terms of health
Safety            and safety for tenants, staff and contractors and embedding the policy will
                  ensure landlord compliance for Cobalt.
Development       The Gas Safety Policy details how Cobalt Housing meets the requirements
and               of the Gas Safety (Installation and Use) Amendment Regulations 2018. In
Consultation      addition to this, the policy provides assurance to Cobalt that measures are
                  in place to ensure compliance with the regulations and to identify, manage
                  and/or mitigate risks associated with gas fittings, appliances and flues.

                  The consultative panel have reviewed the policy prior to its approval and
                  recommendations have been adopted in the final version.
Customer          Relevant data will be used to determine if a tenant requires support where
Profiles and      access to a property is to be obtained.
Accessing
Services Data
Monitoring and    Performance of the following in respect of gas safety will be reported to the
Review            relevant committee and to board as part of the Landlord Compliance
                  Report:

                     • Total Number of properties with no gas supply
                     • Total Number of properties with a gas supply
                     • Percentage of properties with a valid gas safety certificate
                     • Total Number of properties with Solid Fuel
                     • Percentage of properties with a valid Solid Fuel certificate
Roles &           The Director of Operations is responsible to the Chief Executive and the
Responsibility    Board for ensuring the effective implementation of this policy.
                  Implementation of and adherence to the policy will be monitored by the
                  Board.

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                             Gas Safety Policy January 2019
8     Definitions
LGSR - Landlords’ Gas Safety Record
CDM - Construction, Design and Management Regulations 2015
HETAS - Heating Equipment Testing and Approval Scheme
RIDDOR - Reporting of Injuries, Diseases and Dangerous Occurrences Regulations

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                             Gas Safety Policy January 2019
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