Neil Macdonald, technical manager at the Heating and Hotwater Council (HHIC), looks at the importance of using approved replacement parts when carrying out repairs to gas appliances – and the work that’s being done to ensure that gas engineers know whether parts are approved.
Gas engineers are all very aware of their duty to protect their customers, who rely on them to maintain the safety of their gas appliance if any replacement parts are needed.
In fact, this is a legal obligation under The Gas Safety (Installation & Use) Regulations 1998, but because the spare parts side of the industry remains largely unregulated, it is not always easy to uphold.
Technical Bulletin 116(1) states that registered businesses should only use manufacturer-approved replacement parts. Currently, using unapproved parts could result in the part appearing to function correctly, but being dangerous in practice because the safety and performance of the appliance cannot necessarily be ensured.
The HHIC is unequivocal in its stance that responsible registered businesses will wholeheartedly support the view that choosing spare parts should be based on ensuring safety, through correct specification.
What is the solution?
Opting for genuine manufacturer parts is one way for registered engineers to ensure their customers are safe, but a clearer, industry-led labelling system would provide another solution.
We already have the legally required CE mark for gas appliances and many of their component parts, even when sold as spares.
HHIC believes we could build on these principles, using a recognisable mark, such as Benchmark, to help registered business stay within the law and keep their customers safe, as well as helping market transparency. Spare parts carrying this mark would be proven to have met a defined industry test criteria, designed to help ensure that they perform safely within appliances with which the part manufacturer advises they are compatible for use.
At HHIC, we have already carried out a thorough review of the legislative requirements relating to the sale of gas appliance spare parts and we are now carrying out a programme of work to underpin a voluntary industry spare part certification scheme. This is aimed to be an extension of the Benchmark brand, initially focused on ‘safety-critical’ boiler components.
The intentions and objectives of the HHIC Benchmark spares working group are:
- For consumers to be safe
- For all manufacturers of either genuine or alternative parts to agree on part classification and definitions
- For manufacturers to understand their obligations when bringing a spare to market
- For a level playing field between OEMs and alternative part manufacturers when bringing a spare to market
- For registered businesses and consumers to understand their options with regard to spare parts
- For consumers not to be misled 7 To help registered gas engineers discharge their legal duties.
There is still a lot to do, but we are beginning to map various safety-critical boiler components to the appliance test standards EN 15502-1(2) and EN 15502-2-1(3) to inform an appropriate and bespoke test regime, all with validated appliance safety in mind.
In parallel, we are constructing the scheme requirements, which will place obligations on component manufacturers volunteering their parts for certification, and on the authorised bodies that undertake the testing of appliances and components in combination, for the purposes of the scheme.
The primary objective has to be safeguarding consumers but a key additional intent is to deliver a scheme that enables registered gas engineers to make better informed choices about the spare parts they use, and so help them to discharge their legal duties under GSIUR.
Does it matter?
The simple answer is yes.
Several HHIC manufacturing members have provided sobering examples about the differences in performance of part variants seemingly for the same application. Starting with basic visual indicators, and compared with the manufacturer’s genuine part, these range from uninsulated electrical connections and missing earth connections, to inadequate fixings for combustion fans. When performance is tested, then parameters such as temperature and electrical surge can greatly exceed those of the OEM design, and so raise potential safety concerns.
When it comes to replacing a part, although spare parts can look the same as manufacturer spares, they are not tested and their safety and functionality cannot and should not be assumed by the gas engineer or consumer.
(1) Technical Bulletin 116: Always use the appliance manufacturer’s specified spare parts when replacing gas controls
(2) BS EN 15502-1:2012+A1:2015 – Gas-fired heating boilers; General requirements and tests
(3) BS EN 15502-2-1:2012+A1:2016 – Gas-fired central heating boilers; Specific standard for type C appliances and type B2, B3 and B5 appliances of a nominal heat input not exceeding 1000kW