Date issued: 21 April 2020
Note: This version of Technical Bulletin (TB) 044 replaces the version originally published on 26 July 2016, which is now withdrawn. This version has been reviewed and revised, where appropriate, to ensure that it remains both current and relevant.
This Technical Bulletin provides guidance to Gas Safe registered businesses/engineers when requested to upgrade catering equipment by retrofitting flame-failure devices (FFDs) where appropriate.
The revised BS 6173:2020 specifies that, when installing new or previously used catering appliances, all appliances shall have flame-failure devices fitted on all burners.
There will also be occasions when a Gas Safe registered business/engineer is called upon to provide advice to caterers when they encounter existing catering equipment during maintenance or service visits that do not incorporate any flame-failure protection, eg, flame-failure devices (FFDs).
An FFD is a device that detects the presence of a flame and, in the absence of a flame, prevents the uncontrolled release of gas to the burner.
HSE publishes Catering Information Sheet (CAIS) No 23(1), which advises catering equipment owners and operators on the need to ensure that gas catering equipment under their control is safe. Part of the information given in CAIS23 specifies the need to retrofit suitable flame-failure protection. This information sheet can be downloaded at: www.hse.gov.uk/pubns/cais23.pdf
Note 1: Although CAIS23 applies in GB, similar requirements apply in other geographical areas covered by Gas Safe Register. For details of current gas safety legislation, building legislation and industry standards for the geographical areas covered by Gas Safe Register, see the Legislative, Normative & Informative Document List (LNIDL)(2) by logging into your online account at: www.gassaferegister.co.uk/sign-in
Requirements of industry standards
BS 6173(3) in its Commentary to Clause 14 – Maintenance of gas-fired appliances – states: “Many older appliances are not fitted with safeguards that are currently required, eg, flame supervision devices, water failure systems, steam safety systems or mechanical protection systems. Alternative components can only be used if so specified by the appliance manufacturer.”
There remains a significant population of gas catering equipment with enclosed burners, eg, ovens, etc, that do not comply with current gas safety standards in the United Kingdom, the Gas Appliances Regulation (GAR) 2018 (eg, non-CE marked).
Note 2: Similar legislative requirements apply in other geographical areas covered by Gas Safe Register. For details of current gas safety legislation, building legislation and industry standards for the geographical areas covered by Gas Safe Register, see the Legislative, Normative & Informative Document List (LNIDL) by logging into your online account at: www.gassaferegister.co.uk/sign-in
Particular concerns have been identified in relation to Asian duck and tandoor ovens: however, other catering equipment such as hog roasters and other cooking appliances may be similarly in need of flame failure protection. The hazards that can arise from the use of non-compliant equipment include possible gas explosions and carbon monoxide (CO) poisoning.
Guidance to registered engineers
It is important to bear in mind the following:
- New appliances must comply with the requirements of the GAR, which states: “Appliances must be so constructed that gas release during ignition and re-ignition and after flame extinction is limited in order to avoid a dangerous accumulation of unburned gas in the appliance”. Therefore, a new appliance that does not feature such equipment shall not be installed.
- Second-hand appliances may not be equipped with FFD components: however, in order to be installed, all burners including ovens and similar enclosed burner equipment, such as steamers, shall be provided with flame supervision devices on all burners and appropriately upgraded gas controls. Upgrading of safety controls shall only be carried out using the appliance manufacturer’s instructions and parts.
- The ad hoc retrofitting of FFDs to CE-marked gas-fired appliances that is not done in accordance with the equipment manufacturer’s instructions may be regarded as a contravention of current gas safety legislation in GB – the Gas Safety (Installation and Use) Regulations (GSIUR) 1998 as amended, in particular, Regulation 26(7) of GSIUR.
Note 3: CE marking is a declaration by the manufacturer that the product meets all the appropriate provisions of the relevant legislation implementing certain European directives. CE marking gives companies easier access into the European market to sell their products without adaptation or rechecking. The initials ‘CE’ do not stand for any specific words but are a declaration by the manufacturer that the product meets the requirements of the applicable European Directive(s). For further guidance on the requirements of CE marking go to: www.gov.uk/guidance/ce-marking
- Registered engineers should not install new or secondhand appliances for which there are no manufacturer’s instructions as it will not be possible to comply with Regulations 29 and 33(1) of GSIUR in respect to the testing of appliances (see also Note 2).
- It is advised that engineers discuss with equipment owners/operators of existing catering facilities to plan for the replacement or upgrade of catering equipment where no flame-failure protection exists. Where it is not practicable to replace/ upgrade catering equipment or upgrade existing equipment with suitable flame failure protection, a risk assessment shall be carried out on the installation and, where necessary, classified in accordance with the current Gas Industry Unsafe Situations Procedure, IGEM/G/11(4).
- In the case of directly imported equipment that is already installed, such as Asian duck or tandoor ovens, there may not be any CE certification and therefore retrofitting FFDs may not constitute a contravention of Regulation 26(7) of GSIUR (see also Note 2). Competent Gas Safe registered businesses/ engineers may retrofit FFD components/kits that are CE marked and supplied with installation instructions, in order to improve the overall safety performance of existing equipment. Wherever possible, CE marked and approved kits from the kit manufacturer or appliance distributor should be used.
- The equipment owners/operators should also be advised that the requirements of the Provision and Use of Work Equipment Regulations 1998 (PUWER) may also apply. For further information visit: http://www.hse.gov.uk/pubns/indg291.pdf
Note 4: The GAR prohibit the supply of gas cooking appliances that do not comply either with the requirements specified in the regulations, or with the safety requirements required of industry standards such as European/British Standards (as appropriate) (see also Note 2).
Note 5: See TB 051 for guidance concerning the ventilation requirements of catering establishments. TB 051 can be viewed by logging into your online account at: www.gassaferegister.co.uk/sign-in
Note 6: For general information about the process behind the development of Gas Safe Register Technical Bulletins and the expectations for all stakeholders, see TB 1000(5) by logging into your online account at: www.gassaferegister.co.uk/sign-in
(1) Catering Information Sheet No 23 – Gas Safety in catering and hospitality (CAIS23)
(2) LNIDL – Gas Safe Register Legislative, Normative & Informative Document List
(3) BS 6173: 2020 Specification for installation and maintenance of gas-fired catering appliances for use in all types of catering establishments (2nd and 3rd family gases)
(4) IGEM/G/11 – Gas Industry Unsafe Situations Procedure
(5) TB 1000 – An introduction to Gas Safe Register Technical Bulletins