The system needs to recognise the potential ramifications for everyone concerned. They should also practice what they preach in the regulations, if that principle really has merit.

We once invited comment on the subject of unregistered gas installers (UGI). Few answers were received for understandable reasons. No doubt we are now venturing into the world of ethics, possibly even philosophy. At the end of the day it is and always will be a personal decision. I’ve no strong views on the matter. I’m not sitting on the fence either. I do have some personal rules.

My rule of thumb throughout everything hinges on risk (to anyone). If I see something which presents an ongoing risk and I am unable to remedy the situation with diplomacy then I will act, doing whatever is necessary. I have the experience to back that up. Many will not and I am genuinely concerned about those people. The authorities lead people by the nose and clearly show no regard for their well-being.

Many rules and regulations are clumsily worded by people who will never have to put theory into practice. There is no provision for common sense. Some things are patently obvious but they choose to ignore the obvious because it is easier for them and they have the power to side-step practicalities.

I rarely issue unsafe situation notices though like most of us I regularly see prescribed unsafe situations. It is incumbent upon registered gas installers (RGI) to implement the Industry Unsafe Procedure (IUP). No one else. Many situations are prescribed as unsafe so there is no scope for doubt. The huge snag with all this is that RGI will almost certainly lose income when implementing IUP, seriously delayed payment or risk violence in some cases.

With Landlords there are more prescribed unsafe situations. Some unsafe situations are RIDDOR reportable. Those situations take no account of circumstances. You could check a Class I flue this year and next year the mid-feathers may have collapsed, blocking the flue. That is clearly an unsafe situation. It is also prescribed as RIDDOR reportable but is that reasonable ? In my opinion no. Why not apply the carrot v stick approach here ?

If a Landlord goes to the trouble of arranging gas safety checks I consider it reasonable to apply common sense and co-operate in such circumstances. Providing the Landlord agrees to repair the flue or permanently discontinue use of the flue, I would proceed accordingly and not even consider implementing IUP, let alone issue a RIDDOR.

Let me be clear. Steps to remedy the situation must be taken immediately and the whole situation must be fully recorded – as found - on the Landlord’s Gas Safety Record form. In my view it would be churlish or even childish to do any more. The regulations should take account of common sense and be seen to do that.

If anything at all prevented me from remedying the situation immediately (and thus being able to record it all on the LGSR) then I would implement full IUP without fear or favour.

I recognise the authorities like their statistics to show off in annual reports but there is a callous disregard for the people who are expected to generate such data. Putting safety first, I will not otherwise risk health, losing money or customers. The authorities get paid every month no matter what happens. Independent RGI do not necessarily. That is a fact.

Sadly, my past experience is that RGI are not backed up unequivocally by the authorities on those rare occasions when it is necessary to go the distance. We are now promised all this has changed and I will proceed, with caution, on that assumption in future. If I am ever let down again, heads will roll. That much I guarantee.

Happily I can cite an exception but not yet with gas. Wearing my WIAPS hat I get a few enquiries and on one such not so long ago found myself at a venerable institution which, unknown to me at the time, was the subject of a TV documentary series. The bottom line is that much of the plumbing was a dog’s breakfast and clearly a DIY job. There were serious health hazards as the local water undertaking discovered on one of their mandatory visits.

During the course of my inspection I also noted serious related gas safety issues and other Health and Safety issues. I followed up on those. They were not amused. Negotiations became laboured and I decided to pull out but first implement IUP. I prepared a meticulously researched report and submitted that to no avail. I announced my intention to visit and serve notice. I managed to obtain a signature ultimately but with some difficulty.

As expected I was ‘reported’ to the water undertaking but having out-guessed them I previously sent a copy of my report to the water undertaking. Unlike some they backed up my efforts fully. I did not get any money by the way but did not ask for any in that case. I can afford to do that but many cannot: The authorities should underwrite any losses and perhaps reclaim that from the offender.

Returning to UGI, let’s begin with scenarios. If I spot a UGI working nearby and probably working on gas, what do I do ? Nothing is my default choice. There is no legal or moral obligation in that regard. Besides, as I have said before, the home owner must invite Corgi in to investigate, regardless of what you or I may think.

Consider - As I recall, Corgi have claimed in the past that something in the order of 80+ percent of the population are aware of Corgi. If that is true then statistically it is more likely than not that anyone employing an UGI, has full knowledge of what they are doing. The authorities can’t have it both ways ?

Indeed we have evidence that some consumers are deliberately targeting UGI and on completion of work demanding ‘gas safety certificates’ which they know can’t be produced. The customers then negotiate a suitable reduction in fee and employ a RGI to check the work for a lesser fee.

If I received a call from someone who claimed genuinely to have been ripped-off by an UGI I would be circumspect. I would first insist they invite Corgi to investigate. If the customer refused then I would walk away. Not likely to happen to me as I do not accept gas enquiries from unknown sources. I agree those just starting up in business have no choice until they develop a recognised reputation.

I have only ever once been asked if I am Corgi registered by someone who is paying my bill. Curiously that was in the last month. I accept that those who know me may assume I am if I undertake that sort of work. There have been one or two ask when I been working on behalf of a third party who is paying. Most people do not give the matter a second though in my experience.

As a reminder, Corgi refer hundreds of UGI to the HSE each year. We can be sure in each case that Corgi have done their homework and as you may know, Corgi have no powers to prosecute. The HSE then take over and this is where the carrot and stick apply.

We could argue that anyone caught should be financially biffed and then offered the opportunity to comply. After all that is what happens if you are a road fund licence or TV licence dodger. So what does happen to the errant thousand ?

Actually we do not know. We do know they are not all prosecuted. I accept the knock on effect of prosecuting everyone would be substantial in administrative terms but the knock on effect of not prosecuting is substantial in terms of lack of confidence in the system by those who take the trouble to register.

Justice should be seen to be done but that is not happening in the fragmented RGI population. How many of the thousand remain unchallenged in any way, to continue their work ? It might offer comfort if we were given some honest figures on outcomes, which were seen to support the cause of those who are registered. We do know there is little confidence in the system at present, whatever the reason.

Some recommendations for new entrants:

Don’t knowingly work alongside unregistered installers at the same address.

Don’t agree to check or certify the work of others.

If a householder asks you to check work they claim was carried out by a cowboy, insist on Corgi being invited in. Refuse if they do not agree.

Don’t be tempted or persuaded to work out of scope. The person asking does not care about your future, only their own pocket.

Don’t agree to bend or break the rules. People will try to persuade you to save money if their own perception is that something is not that important. But equally they will sue if something goes wrong and they think they can make a butty out of it.

If you get caught out, walk away. You may lose money – we all have – but cut your losses which may be greater if you do not.

Read Feature on Landlord’s Gas Safety Checks.

If you’ve got any doubts about anything ask Corgi or email us in confidence.