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RIDDOR: A gas engineer’s guide

The first Open Channel from Gas Safe Register event recently was on the topic of RIDDOR. Following the live Q&A with senior representatives from Gas Safe Register and HSE, here’s Registered Gas Engineer’s round-up of what you should know and do.

What is RIDDOR?
The Reporting of Injuries, Diseases and Dangerous Occurrences (RIDDOR) 2013 is a legal requirement that covers mandatory reporting to HSE of workplace injuries, diseases and dangerous occurrences.

The law requires employers, self-employed people, and other people in control of work premises to report and keep records of:

  • Work-related accidents that cause death
  • Work-related accidents that cause certain serious injuries (reportable injuries)
  • Dangerous occurrences with the potential to cause harm. There are special requirements for gas incidents.

What is RIDDOR 11(1)?
RIDDOR 11(1) is the duty on the gas conveyor, importer, supplier or filler of LPG refillable containers. If someone has died or lost consciousness, or has been taken to hospital, then the gas conveyor needs to report it too, under RIDDOR 11(1). The majority of situations that you will come across in terms of dangerous gas fittings are reportable under Regulation 11(2).

Why report?
It’s the law. The regulations spell out the dangerous gas fittings that gas engineers must report under RIDDOR Regulation 11(2). The report informs the enforcing authorities, via HSE, about potential and actual deaths, injuries, occupational diseases and dangerous occurrences, so they can identify where and how risks arise, and whether they need to be investigated.

This helps the enforcing authorities to target their work and provide advice about how to avoid work-related deaths, injuries, ill-health and accidental loss.

What is reportable?
Gas fittings are defined in the Gas Safety (Installation & Use) Regulations 1998 as amended, and include pipework, regulators, meters and appliances. Where a gas fitting, or a flue or ventilation used in connection with it could, in your opinion, be so dangerous that it could kill someone, make someone unconscious or cause them to be taken to hospital, it must be reported.

RIDDOR states: Registered gas engineers must provide details of any gas appliances or fittings that they consider to be dangerous, to such an extent that people could die, lose consciousness or require hospital treatment. The danger could be due to the design, construction, installation, modification or servicing of that appliance or fitting, which could cause:

  • An accidental leakage of gas
  • Incomplete combustion of gas, or
  • Inadequate removal of products of the combustion of gas.

In general, what this usually means is situations that would be deemed as being Immediately Dangerous (ID) under the Gas Industry Unsafe Situations Procedure (GIUSP) would be reportable.

The GIUSP (IGEM/G/11) gives a lot of guidance, including:

  • How to risk assess to classify a dangerous situation
  • How to deal with dangerous situations/installations correctly
  • The RIDDOR reporting process
  • A list of dangerous situations and how they would be classified.

If you repair a dangerous gas fitting, you must still report it under RIDDOR.

What if I need to fix the installation immediately on safety grounds?
Ideally, you should leave the installation intact as evidence. But if this is not possible or if the customer wants it back on, take as many photos and gather as much documentation as possible before you make safe. If required, HSE then can take a statement from you to support the photographs and any other evidence.

What if I’m not sure?
Use the GIUSP to risk assess the installation. Following the GIUSP should give you a clear indication of whether you should report under RIDDOR, but if you’re still unsure whether it meets the criteria, you can call Gas Safe’s Technical Helpline and talk the situation over in order to help you make your mind up.

Gas Safe Register confirmed during the Open Channel event, that you can call the Register to validate your assessment with its Technical Team or with your local Gas Safe inspector. However, Gas Safe Register will not classify the unsafe situation: this must be done by the engineer on site.

What must gas engineers report under RIDDOR 11(2)?
You must provide details of any gas fittings, including appliances and flues or ventilation used with the appliances, that you consider to be dangerous, by reason of their design, construction, installation, modification or incorrect servicing, which could result in:

  • An accidental leakage of gas
  • Incomplete combustion of gas, or
  • Inadequate removal of products of the combustion of gas.

It’s helpful to provide as much evidence as you can and clearly set out what is dangerous about the installation, construction or design, and the appliance itself.

Photographs are always helpful, so please take them if you can. Is there any paperwork that might provide information about who carried out the work? You must report via HSE’s website, and within 14 days of the incident.

What does HSE do with my report?
When you submit a report, it will be ‘triaged’ initially by HSE gas officers. It’s important to note that if you report work that has been carried out by a Gas Safe registered engineer, then the information will be passed to the Register to investigate; if not, HSE gas officers will check whether they need more information or whether there is enough to start investigating.

Reports of dangerous work involving commercial organisations and catering establishments will be passed to the appropriate local authority for investigation.

Why don’t I hear how my report is being followed up?
HSE has received more than 13,000 gas RIDDORs in the past five years*. When you report, you will receive an acknowledgement from HSE, but due to the number of reports it receives, and the time it can take to carry out a full investigation, it’s unlikely that you will be updated on progress. However, HSE gas officers may contact you if they need any more information.

* For the five-year period 2014/15-2018/19, 13,163 dangerous gas fittings were notified under Regulation 11(2)

What records should I keep?
You must keep a record of any reportable injury, over-three-day injury, disease or dangerous occurrence. You can print and/or save a copy of the online form. A copy of the form will be emailed to the email address you provide.

If you do not keep a copy of the online form, your records must include the date and method of reporting; the date, time and place of the event; personal details of those involved; and a brief description of occurrence.

What is NOT reportable?
Gas installations that are dangerous solely because they have not been maintained are NOT reportable under RIDDOR. Dangerous non-gas-safety defects are generally not reportable – such as damaged or inappropriate electrical connections and hot water cylinders without pressure relief.

You can report a concern about certain gas work that is not reportable under RIDDOR through HSE and Gas Safe Register.

Dangerous gas fittings in a rented property caused by a lack of maintenance are not reportable under RIDDOR. However, you can send the details to HSE as a concern and HSE will then decide whether to investigate further. If a landlords’ gas safety record check has not been carried out, this can be reported to HSE.

Reporting poor or illegal gas work
Work that is poor but is not RIDDOR reportable can be reported to Gas Safe Register or via HSE as a concern. Where the work has been carried out by a Gas Safe registered business, the Register will investigate and an inspection on competence grounds is likely to be triggered automatically for the registered business that carried out the work. Illegal gas work will be investigated by Gas Safe Register.

These photos, sent to us by Dean Pullman for the Good, the Bad and the Ugly in this month’s edition, are some good examples of situations that are reportable – as well as those that are not.

How to report

Report lack of landlord’s gas safety record check:

Further resources


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