Reminder: request for concession to manufacturer’s instructions
Gas engineers often need to balance their customers’ requirements when fitting an appliance against those of the manufacturer’s installation instructions. These can be compounded by factors such as the constraints of the property and intended appliance location.
It’s important to remember that the primary requirement is to ensure that the appliance is safe and complies with the Gas Safety (Installation and Use) Regulations.
Gas engineers need to ensure that the specific installation requirements of the manufacturer are met, and they should undertake a survey of the intended location of the appliance and its instructions before starting work, to ensure that the installation will comply with the relevant regulations.
What if I cannot meet all the requirements as specified?
Gas Safe Register recognises that there are sometimes unique circumstances where the only available location for an appliance is one that will not comply fully with the manufacturer’s installation instructions.
As a Gas Safe engineer, you must seek the advice and approval of the appliance manufacturer to ensure that any intended deviation from its instructions will not reduce safety before undertaking any gas work.
A formal process is available to help you provide a consistent approach for dealing with these circumstances.
If your intended installation cannot fully meet the requirements of the manufacturer’s installation instructions, you must request a formal concession from the appliance or equipment manufacturer to deviate from the instructions.
To provide a consistent and robust method for this process, you can use the Request for Concession to Manufacturer’s Instructions template, which you’ll find by signing into your online account.
You can also find a helpful flow-chart in Technical Bulletin 158 by logging into your Gas Safe Register online account.
Important: This process must be used at the quotation stage, before work takes place.
Manufacturer’s view and advice
The manufacturer’s installation instructions will cater adequately for most installations. This process is to cater only for those rare occasions where there is genuine ambiguity and/or extenuating circumstances:
Any concession given by a manufacturer to its standard written instructions will relate only to the appliance, address and concession stated. It cannot be used to apply similar concessions to other work. A separate concession must be obtained for any additional site or appliance.
Approval will not be granted without valid reason and supporting evidence. It is not acceptable to circumvent the manufacturer’s instructions simply to make the job easier.
A request for concession to the manufacturer’s instructions does not detract from them; it is aimed at helping compliance with the regulations and making sure that unfounded defects are not raised and unsafe situations logged incorrectly.
Gas Safe Register will require you to show evidence of this approval process where an inspection identifies appliance or equipment installation defects.
Where approval of a requested concession has not been granted by the manufacturer, you will be required to correct the defect to meet the existing installation instructions, in accordance with the issued defect notice.
At a glance
All gas work should be carried out competently and safely, in accordance with the relevant geographical gas safety legislation, Building Regulations, manufacturer’s instructions and appropriate industry standards.
Deviations from the manufacturer’s instructions, normative industry standards or technical specifications or the use of ‘alternative methods’ to achieve compliance are not acceptable without documented and auditable approval from the equipment manufacturer or other relevant authority.
It is your responsibility to provide this evidence in these circumstances. Approval for any deviation should be sought from the manufacturer or other relevant authority before any gas work is carried out.
For more information see Technical Bulletin 158: Requesting a Concession to Manufacturer’s Instructions, by logging in to your online account at: www.GasSafeRegister.co.uk/sign-in
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