Gas safety in caravans, including leisure accommodation vehicles and residential park-homes
Formerly OC 440/34
This guidance replaces OC 440/34 v2 and provides information and advice to operational staff on the application of the Gas Safety (Installation and Use) Regulations 1998 (GSIUR) to leisure accommodation vehicles and residential park homes, and enforcement demarcation.
This guidance provides information on how and when GSIUR applies to caravans to assist with the decision on whether to investigate concerns, or incidents reported to HSE under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR); also advice on enforcement allocation.
GSIUR apply in many cases and enforcement responsibility may fall to HSE or Local Authorities, depending on the use and location of the caravan .
An incident (fatality or serious injury) reportable under RIDDOR does not necessarily attract duties under gas safety legislation e.g. where a dutyholder is not implicated.
For the purpose of this guidance, unless otherwise specified the term ‘caravan’ will be used throughout – definitions are set out below.
When making a decision whether to investigate a concern or incident involving a ‘caravan’, the following should be taken into account:
- Does the Health and Safety at Work etc Act (HSWA) apply?
- Does GSIUR apply? and
- Who is the Enforcing Authority?
In making this decision, it will be helpful to refer to The Approved Code of Practice and Guidance Safety in the installation and use of gas systems and gas appliances (L56, fourth edition)
Where the circumstances are unclear, there should be liaison with the relevant Local Authority (LA) and consideration of joint investigation if there are shared responsibilities e.g. on a residential site.
Inspectors coming across incidents which have not been reported under RIDDOR, may need to prompt the responsible person (whoever that might be in the circumstances) to submit an incident report.
Application of the Gas Safety (Installation & Use) Regulations 1998 (GSIUR)
GSIUR and L56 include the following specific references to caravans:
- Regulation 2(1) guidance relating to a ‘supplier' states that a caravan park operator who provides gas to caravans via a storage vessel (i.e. bulk tank) becomes the `supplier.' If the park operator supplies liquefied petroleum gas (LPG) in cylinders, they share suppliers' responsibilities with the gas company to which they are contracted;
- Regulation 2(5)(e) excludes privately owned tourers. However RIDDOR regulation 11(1) incidents occurring in them are still reportable
- The following are all subject to GSIUR:
- Touring/motor caravan hired out in the course of a business
- Permanently sited caravan (hired out or otherwise) on a holiday-home park, residential park-home or similar site, including a farm
- Caravan used as an annex to permanent accommodation e.g. as a granny flat
- Caravan/temporary accommodation unit used as temporary residential accommodation for workers on, for example, a building site or farm.
- Caravan used in the course of a commercial undertaking e.g. a roadside café or where serving food through the hatch at a sporting or entertainment venue
- Enforcing authority guidance section indicates the enforcing authority for these and other situations.
- Regulation 3(1) requires persons carrying out work on gas fittings/storage vessels to be competent. There are specific competencies under the Nationally Accredited Certification Scheme (ACS) for work on appliances in caravans, in addition to Core Domestic LPG Safety (CCLP1);
- Regulation 3(8) applies to installation and repair work carried out by caravan manufacturers where it is known that the end use of the caravan is covered by -+the Regulations e.g. will be hired out in the course of a business. This requires those carrying out such work to be competent, though not registered if that work is done at premises excluded from the regulations (i.e. factories);
- Regulation 7 covers the protection of gas fittings against damage. Fittings in touring caravans need to be securely fitted and supported to avoid damage from movement etc and fittings, service pipework (i.e. the pipework from a vessel/tank up to the emergency control valve (ECV)) and vessels in caravans sited near the sea may need protection against corrosion from salt spray;
- Regulation 36(6)(b) applies to holiday lets for less than 28 days, requiring the landlord to display the gas safety record prominently in the caravan -
- Regulation 37(1) covers the duties of a ‘supplier’ of LPG in the event of an escape of gas from a storage vessel, service pipework or a gas fitting;
- Regulations 37(2) & (3) cover the duties of the ‘responsible person’ if they become aware of an escape of gas into a caravan. The responsible person being the occupier or, where the caravan is empty, the caravan owner.
GSIUR does not cover the majority of portable appliances but, where mobile space or cabinet heaters are used in caravans, they are subject to the provisions of regulations 3, 35 and 36. However, as British Standards for the installation of space heating in leisure accommodation vehicles (LAVs) and residential park homes (RPHs) do not include portable appliances they should not normally be found.
In the event of a landlord or engineer supplying a portable heating appliance while, for example, the fixed heating system is being repaired, they may be in breach of HSWA Section 3 or consumer safety legislation if the appliance can be shown to be unsuitable for the purpose used. Trading Standards Officers should be consulted on consumer safety issues.
Recording and reporting
Make it clear in COIN reports that the issue concerns gas safety in a caravan, to include the type of gas and vehicle
OPSTD, MTU Sector, Utilities section
Enforcing authority guidance
|Domestic residence which is a caravan on a caravan/park home site, either privately owned or with a long-term tenant||HSE|
|Caravans on holiday park rented out short-term (may be individually owned or owned by the park operator)||LA|
|Caravans located on a work site and used as sleeping accommodation (eg for seasonal farm workers) or for domestic or residential purposes||HSE|
|Temporary caravans at construction sites||HSE|
|Accommodation provided for workers but located separately to the work site||LA|
|Domestic or holiday use is minor activity to main HSE enforced business e.g. a caravan site (not a separate business) on a farm.||HSE|
|Operator of residential caravan sites OR operator of holiday caravan park||LA|
|Hiring out touring caravans/motorhomes||LA|
|LA operated sites, whatever the circumstances||HSE|
|Mobile catering units (when pitched)||LA|
|At Local Authority assigned sites|
|Work carried out by a person who does not normally work on the site eg independent gas engineer||HSE|
|Gas work carried out by site owner who does not live on the site.||HSE|
|Gas work carried out by site owner who lives on the site.||LA|
|Gas work carried out by a person who normally works on the site.||LA|
|Landlord duties only e.g. annual safety checks, ensure current gas safety record held and gas fittings/appliances maintained.||LA|
What is a caravan?
The term caravan covers tourers, motor-caravans and caravan holiday-homes, collectively known as leisure accommodation vehicles, (LAV) and residential park-homes (RPH). They are described in more detail in the following paragraphs together with the current applicable standards for construction and gas safety. Note: as standards are regularly updated, always check with British Standards on-line for the standard in force at the time the caravan was built or upgraded.
Leisure accommodation vehicles
Tourers are those seen on the road being towed by cars. They are built to BS EN 1645 and must meet the requirements for the construction and use of road vehicles.
Motor-caravans incorporate the living accommodation similar to that of a touring caravan on to a motor base vehicle and are therefore designed specifically for touring. They are built to BS EN 1646 and must meet the requirements for the construction and use of road vehicles.
Caravan holiday-homes are designed specifically for holiday accommodation on licensed caravan holiday parks. Because of their size and weight they are delivered to the park by transporters. They are manufactured with wheels solely to manoeuvre them on site. They are built to BS EN 1647, LPG systems are covered by BS EN 1949 and safety ventilation requirements by BS EN 721.
Park-homes are designed for permanent residential accommodation. They are still caravans, even though they have pitched tiled roofs and may appear similar to a brick built bungalow. Because of their size and weight they can only be delivered by transporters, sometimes in two halves which are then bolted and secured together when in situ. They are built to BS 3632 which covers ventilation.
The LPG installation is covered by BS 5482-1 and BS 5440-1 and the flues and terminals by BS 715 (partially replaced by BS EN 1856-1:2003 & BS EN 1856-2: 2004).
Natural gas installations are covered by BS 6891 and BS 5440-1 and the flues and terminals by BS 715 (partially replaced by BS EN 1856-1:2003 & BS EN 1856-2:2004).
Types of gas used
Liquefied petroleum gas
The majority of appliances found in caravans will be fuelled by LPG; the generic name for commercial butane and commercial propane.
Butane is not suitable for installations subject to low external temperatures and is therefore mainly used for tourers and motor-caravans. There is no standardised colour for butane cylinders; blue, yellow/ochre, and white are common.
Propane is ideal for outside storage and therefore used to supply residential park-homes and caravan holiday-homes. Although often supplied in red cylinders it may also be supplied in cylinders of orange or other less common colours. Patio gas propane, an increasing market, is supplied in green cylinders. Bulk storage vessels at the customer's (e.g. caravan park operator) premises are normally coloured white or green.
In some caravan sites natural gas is supplied from a gas conveyor's local distribution network. Often there is a bulk supply meter at the site boundary from which the gas is then conveyed around the site in pipes to each caravan. The pipes on the site could be owned by the gas conveyor or by the park operator.
In certain circumstances, the pipes on the site may be part of a network as defined in the Gas Safety (Management) Regulations 1996 (GSMR) and subject to GSMR, including safety case requirements. Guidance on GSMR is contained in A guide to the Gas Safety (Management) Regulations 1996 - L80.
The end of the network is at the first emergency control valve (ECV) (as defined by GSIUR) and defines the cut-off point between GSMR and GSIUR. If the pipes are on the network and owned by the upstream gas conveyor, then they should be covered by their safety case. If the park operator owns the pipes then they may be required to produce a GSMR safety case.
OC 440/28 provides further guidance on the liaison between HID and FOD on gas safety matters. HID is responsible for GSMR safety case matters.