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UNCORRECTED TRANSCRIPT OF ORAL EVIDENCE
To be published as HC1851-i
House of COMMONS
TAKEN BEFORE the
Communities and Local Government Committee
BUILDING REGULATIONS APPLYING TO ELECTRICAL AND GAS INSTALLATION AND REPAIRS IN DWELLINGS
MONDAY 20 february 2012
PAUL EVERALL, EMMA CLANCY, STEVE BRATT,
CHRIS TOWN, PHIL BUCKLE and DIANE MARSHALL
PAUL EVERALL, SIMON AYERS, CHRIS BIELBY and CHRIS YATES
Evidence heard in Public Questions 1 - 77
USE OF THE TRANSCRIPT
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Taken before the Communities and Local Government Committee
on Monday 20 February 2012
Mr Clive Betts (Chair)
Examination of Witnesses
Witnesses: Paul Everall, Chief Executive, Local Authority Building Control, and Trustee of Gas Safety Trust, Emma Clancy, Chief Executive Officer, NICEIC, Steve Bratt, Chief Executive Officer, ECA, Chris Town, Director, Residential Landlords Association, Phil Buckle, Director General, Electrical Safety Council, and Diane Marshall, Group Head of Building Control, NHBC, gave evidence.
Chair: Good afternoon and welcome to the first evidence session of our inquiry into building regulations applying to electrical and gas installation and repairs in dwellings. Before we start, I think Heidi Alexander has an interest to declare.
Heidi Alexander: I should declare as an interest that my father is an electrical contractor and is registered with NICEIC.
Q1 Chair: I am sorry to keeping you waiting for a little while, but thank you for your written evidence so far and for coming this afternoon. Quite a lot of you are giving evidence together. By all means disagree with one another, but if you agree fully with what someone else has said there is no need to repeat it. Just an indication that you are supportive of comments already made would be very helpful. To set off, the subject of this inquiry is electrical installation work and building regulations. Consultation is going on as to whether changes may or may not be made. We have Part P of the building regulations. Do you believe that, by and large, Part P has worked, and are our homes safer because of it?
Chris Town: There is no doubt that it has improved things. I represent landlords who are quite confused about the various different levels of electrical regulation. What landlords would like to see is more clarity in that regulation. They do not particularly grasp Part P, because clearly that is about new installations and additions, and become confused about testing and things like that. What landlords would like to see is more clarity from the industry.
Q2 Chair: At the beginning I should have asked all of you to say who you are and introduce yourselves. Perhaps you could do that.
Chris Town: I am Chris Town from the Residential Landlords Association.
Q3 Chair: It would be helpful if each of you could do that as you make your first comments.
Paul Everall: I am Paul Everall and currently I am chief executive of LABC, which is the representative body for building control officers working in local authorities. I was appointed to that post in 2005, but for the 14 years prior to that I was the senior civil servant in ODPM and the predecessor Departments responsible for building regulations. I was there at the time advising Ministers on whether or not we should introduce Part P to the building regulations. Seven years later I still strongly believe that it was the right thing to do.
Before Part P was introduced, an impact analysis had to be done. That demonstrated at the time that electrical safety was an important issue in the home that for some reason had never been covered by building regulations in England and Wales, but the case was made for it in terms of reducing deaths and injuries from electrocution and, just as importantly, fires in dwellings. I still believe that Part P should be retained.
Phil Buckle: I am Phil Buckle from the Electrical Safety Council. I support Paul’s comments in that regard. It is quite clear from the statistics that Part P has had a beneficial impact on electrical safety. If it was taken away, it would remove the only regulation that supports electrical safety in dwellings in England and Wales. If we look at the statistics in a little more detail, the most recent ones to hand show that fires attributable to mains wiring-that is, after the distribution system-have declined by 17.5% from 1,057 in 2004 to 872 in 2008. It has had a significant impact on safety.
Steve Bratt: I am Steve Bratt, chief executive of the Electrical Contractors Association. We monitor contractors and have an inspection every year, and we keep statistics on that work. The number of contractors has been increasing and the number of faults identified has been decreasing, and the same principle applies to complaints. That would suggest the standards are significantly increasing. The number of training courses provided to operatives is also significant. Undoubtedly, standards in the industry are being raised.
Diane Marshall: I am Diane Marshall, group head of building control at NHBC. We have taken a fairly neutral position on the evidence base in relation to Part P, predominantly because of the clients with whom we work. We tend to work in the new homes sector, where an approved inspector carries out building control. We work with new home builders, who are required to conform to NHBC standards for warranty. Our warranty requires electrical installations to be to the latest British standard. With our customer base there is no hard evidence that Part P has made a difference, but it is predominantly because of the quality of the customers with whom we deal through registered builders.
Emma Clancy: I am Emma Clancy, chief executive of the Ascertiva Group, which includes the NICEIC. Along with our colleagues at ECA and ESC, we believe that Part P is crucial to maintaining high standards of electrical safety. For consumers, it is, first, a badge of confidence and trust, because as competent person scheme operators we guarantee the work undertaken in people’s homes. It is of value to a householder to know that they have that warranty and guarantee if something goes wrong.
Secondly, it is a badge to work in the industry. We recently helped a constituent of Simon Hughes to gain NICEIC membership. That constituent felt it was important to have NICEIC endorsement as well as his qualifications and training to enable him to differentiate himself in getting work. Therefore, it is a benefit both to consumers and to industry.
Q4 George Hollingbery: Mr Buckle, I want to press you a little harder on the 17.5% to get a proper feel for it. I think your evidence is that it contributed to a 17.5% reduction. To explore that a little further, plainly there are lots of buildings out there that have never been touched since Part P came into being. It may well be that lots of the fires occurred in buildings that had never been subject to the regulations in Part P. Do you have a more solid number? Can you give us hard evidence about the actual reduction under Part P itself?
Phil Buckle: These statistics are attributable to mains wiring and are in a category that we have drawn down from the CLG statistics that are most relevant to domestic wiring. That is the figure we are working on in regard to the 17.5% reduction. In respect to housing stock across England and Wales where Part P is in force, about 50% of homes in England and Wales-we can provide you with a more exact figure following this session-have not benefited from an upgrade to the current edition of the wiring regulations, which means there is not RCD protection within those dwellings. The Electrical Safety Council is campaigning to address that issue. That means that for users of those installations there is a greater risk of both fire and electrical hazards.
There is a whole range of issues that Part P underpins and supports in terms of improvement. Without that regulatory framework there would be no incentive for some who own or rent out homes potentially to make those improvements. We are particularly concerned about the accidental landlords. Responsible landlords take due diligence and make sure their housing stock is maintained appropriately, but accidental landlords can fall foul of not having regular checks undertaken. We have case study examples where in the past that has caused tragedies.
Q5 George Hollingbery: Is it possible to produce any figures in a more granular form?
Phil Buckle: We can certainly provide more granularity for you following this session.
Q6 Chair: That is an issue not about the standard of installation at first instance but follow-ups to make sure it is still safe?
Phil Buckle: Indeed. The new housing stock is wired up to the current standard and you can have some confidence that it complies and is safe. The older housing stock needs regular checks. Many houses in England and Wales do not enjoy the benefit of a regular check because people are not aware that is necessary. The whole debate is about having Part P to create or maintain a framework of electrical safety for new and upgraded work, but also to campaign to make sure people are aware that they need to check regularly the maintenance of their electrical installation.
Q7 George Hollingbery: I think most of us are much more aware of gas regulation than electrical regulation and would not employ a gas fitter who was not qualified. We know that that should not happen. Should not everyone just be a competent person?
Phil Buckle: If I may start-I am sure my industry colleagues will want to add to it-the Electrical Safety Council feels that it would be better if anybody doing paid-for work was registered with a competent persons scheme. That makes life so much more straightforward for members of the public who look to procure electrical work. There will be minimal risk of falling foul of a cowboy electrician who is not registered because they will be able to ask for evidence of their registration.
Q8 George Hollingbery: I wonder what the builders think about that.
Diane Marshall: Currently, house builders use the option of doing not a competent persons scheme but certification to the latest British standard. That is an option within the regulations that we accept. They provide evidence by submitting a Part P certificate and using qualified electricians, so there is still a qualification aspect. Most of those qualified engineers will be members of one of the professional bodies for electrical engineers.
Q9 George Hollingbery: Mr Town, do you think everyone should be qualified to touch a plug?
Chris Town: I do, but I think there should be skill. Speaking from the landlords’ perspective, many do a lot of their own repairs, and in some cases it is the only way that makes the business work. If they are competent to carry out electrical work, that is to say they have some qualification in that regard, and it is kept up, I believe they should be allowed to work on their own stock with self-certification.
Q10 George Hollingbery: Does anyone else have an opinion?
Paul Everall: One of the options in the current DCLG consultation paper on Part P is for people to be able to self-certify and then to get someone else to come in and do a test of the final result. That might well be a satisfactory solution in those sorts of circumstances, although it is out to consultation.
At the moment local authorities are the Part P body of last resort, in the sense that they have to provide a service if people for some reason do not choose to use a competent persons scheme. It is not that we want the work, but, like all other aspects of the building regulations, we have to ensure compliance for those people who come to us. If everybody was a member of a competent persons scheme, or the same rules applied as in gas, we would be very happy.
Emma Clancy: We would look for competence to be defined in terms of practical experience as well as qualifications. That would be an important point to remember in this. There is also a weakness in that you are inspecting things after they have been installed. If you are using a competent person from the beginning of the job, you can be clear that they are seeing the standards all the way through the process, whereas if you are asking someone to check at the end, the wall may have been covered, or whatever. Therefore, there are some difficulties or points of detail that could be very important in terms of protecting the safety standards that we all hold dear.
Q11 George Hollingbery: Could these certificated or competent persons schemes be better integrated with local authorities and their competencies to try to square this circle?
Paul Everall: They certainly could. We have made representations to DCLG over the years for improvements. One of the biggest problems we have with competent persons schemes is that we have to be notified only up to 30 days after the work has been completed. We believe that, from the point of view of compliance, it would be so much better if we had to be notified in advance, as is the case with anybody wanting to have a house extension or work done on their property. That would give us a better opportunity to check whether the person is indeed on the competent persons register, whether they should have submitted a building notice, or whether they are doing unauthorised work and therefore we can take appropriate action. In relation to the current DCLG consultation paper, there will be an opportunity to put forward to them our thoughts about how Part P could be improved.
Q12 George Hollingbery: I want to ask about regulation and inspection of the DIY sector. How should the current scheme be changed? A lot of the representation we have had from the smaller end-contractors and people in the DIY market-is that they are being charged disproportionately. Do you have any thoughts on that?
Steve Bratt: From a DIY perspective there is a demarcation point at which carrying out like-for-like work is probably a reasonable thing. Many people may be expected to be capable of doing so. When you start to extend a circuit you move into the realms of being a competent person. If you add to that the cost of getting the thing approved, consumers are not going to save a lot of money by doing it themselves; they still have to have the thing validated. There is a distinction to be drawn between simple like-for-like work and extending a circuit, which is work only for competent people.
Phil Buckle: I echo Mr Bratt’s sentiment, but I also suggest that where people potentially feel aggrieved that they cannot do work there can be a review of what is and is not notifiable. The Electrical Safety Council would be supportive of a reduction in the type of work that is notifiable, but that should not extend to bathrooms or kitchens. When we were discussing the structure and requirements of the regulations introduced in 2005, it was clear that work undertaken in a kitchen, while not such a high-risk area as a bathroom for example, was often undertaken by those not competent to do any type of electrical work whatsoever. Typically, that was done by kitchen-fitting companies that perhaps used a carpenter to do work. From our point of view, there are very important and genuine safety reasons why work undertaken in bathrooms and kitchens was made notifiable.
I think that some of the concerns from the smaller end of the market that you mention are predicated on the feeling that they should be able to undertake work without any regard to the safety of the installation or the consumer. I am not saying they deliberately want to flout safety rules, but they do not understand electricity; they do not smell it and see it. Therefore, when something goes wrong, it is the silent killer that causes fires and takes life. We have examples where faulty installations across England and Wales have led to the unfortunate death of individuals.
Q13 George Hollingbery: Are there any further thoughts on that particular end of the market?
Paul Everall: One of the things that persuaded Ministers and Parliament generally back in 2005 was a case where a piece of work undertaken in a kitchen had been poorly done. The daughter of an MP was unfortunately killed. Incidents like that-simply touching a draining board and a clamp, providing a connection that is not properly earthed-bring home to you just how dangerous electrical wiring can be.
Q14 George Hollingbery: In summary, do you have some sympathy for small work to be taken out completely, but anything that involves even moderate or substantial work, like extending circuits and so on, should be completely regulated and inspected by a competent person? Is that a fair summary?
Phil Buckle: It should be undertaken by a competent person in the main, or, if not, notified through an appropriate route so that the work is checked and inspected, bearing in mind the point Emma Clancy raised that some of that work would be within the fabric and could not be seen by a third party.
Q15 Stephen Gilbert: If we say that people who are undertaking this work, which can be dangerous as has been suggested, have to be members of competent persons schemes, how are competent persons schemes regulated? Who is policing that part of the regulations?
Emma Clancy: Predominantly, UKAS. CLG obviously operates under the scheme rules policed by them, so those are the two main ways in which we are monitored.
Q16 Stephen Gilbert: What are the mechanics of that monitoring? How does that physically demonstrate itself? Does it come to light only when a customer makes a complaint and there is an investigation? What is the proactive role in maintaining some kind of assurance that the people who are working under the CPS schemes are competent persons?
Emma Clancy: The scheme operation is monitored by UKAS, who come and do their own inspections. They will look in detail at our complaints logs and how we are operating our procedures and practices to make sure we adhere to that. CLG operates the scheme rules and gives us criteria against which we operate. We as a competent persons scheme go out on an annual basis and check two jobs of a domestic installer. Those jobs are picked anonymously from a list. Trained engineers employed by us look at that work and say that it meets the standard and so on. They also do the paperwork audits; they will make sure that the competent persons scheme member has all the appropriate insurances and so on, so in that sense it is a thorough check.
Q17 Stephen Gilbert: Therefore, annually two jobs by a domestic installer are checked by you as a CPS operator?
Emma Clancy: That is correct.
Q18 Stephen Gilbert: In your experience in any year how much fraud is there? How many people out there come forward to say they are members of CPS schemes when they are not?
Emma Clancy: A reasonable number, and one which is growing in the recession. We take off the roll, to use our phrase, about 10% for a variety of reasons. A certain number do not meet the standard, so they cannot be registered with us anymore. We have a growing concern about misuse of logo and so on, and people who pretend to be members of competent persons schemes who are not, but we do a number of things to challenge that proactively. Those who are registered legitimately are very happy to help us track down those who are not, because they are the ones doing it the hard way. They raise things and we investigate them.
We have a number of campaigns to promote that. We have our Ask campaign and run a helpline. If you are getting work done in your home, give us a call and we will tell you whether or not your contractor is truly registered. We also have things like a wall of shame, where we display the names of those who have been naughty. That is a remarkable deterrent.
Q19 Stephen Gilbert: Presumably, that wall of shame is for people who are legitimate members of the CPS but have breached it?
Emma Clancy: Not necessarily; it is often people who pretend that they are. We then follow it up, investigate it properly and follow appropriate due diligence, but if they are found lacking, we will publicise that.
Q20 Stephen Gilbert: 10% a year strikes me as quite a high churn. Has that figure gone up over recent years, or is it about the same? One in 10 are people who claim to be competent providers.
Emma Clancy: Unfortunately, that also involves firms that have gone bust. Obviously, that has increased due to recessionary pressures in the last couple of years.
Q21 Stephen Gilbert: What would be the breakdown as between firms that are not fulfilling the criteria and those that are not able to weather the financial storm?
Emma Clancy: About half and half.
Q22 Stephen Gilbert: Therefore, about 5% of people each year within the scheme are not fulfilling the requirements?
Emma Clancy: Yes, which can be for a range of reasons.
Q23 David Heyes: The Electrical Safety Council told us that the costs associated with self-certification of competent persons were about £7 per notifiable job, compared with building control fees that average £230 per compliance certificate. Are those figures right? Is that a view shared by all the panel?
Paul Everall: I think they are reasonable figures in terms of their accuracy. You may find they are unreasonable in other ways. They are not comparable in the sense of what is done. If you go to the local authority, they will need to carry out inspections on that particular job and it is likely they will do two: one while the work is in place to see that wiring is being put in the right way, and then, at the end of the job, to have it tested to make sure that completion certificates can be issued.
The system of building regulations in this country is that it must be self-financing; there is no cross-subsidy from the ratepayer, so the building control departments in each local authority have to be self-financing. For each job they have to charge what it costs them to take on the work. The cost of a couple of inspections, checking the paperwork and the travel probably averages out at £200.
Q24 David Heyes: It is conceivable that the cost of that inspection could be greater than the cost of the original work.
Paul Everall: I think it is unlikely, because a lot of small work is not notifiable anyway. It is supposed to comply with Part P, but it is not notified to anybody. I think you would be doing well if you got a rewiring job done for less than £200.
Q25 David Heyes: I am not getting dissent on those figures from the other members of the panel. What can be done to make it more cost effective? I think that is where we are going with this.
Diane Marshall: From the NHBC’s point of view, we carry out the inspection of Part P alongside every other part of the home we inspect. The cost to us of providing building control on Part P is minimal, because it is part of the overall work; it is not a stand-alone bit. It is only when you are looking at regulating Part P that the costs are necessarily that high to cover the inspections relating to just that aspect of the work, not where it is absorbed as part of a bigger project. Our costs are minimal in comparison.
Phil Buckle: When we looked at those figures we discussed with industry colleagues how the notifications were structured. We are quite confident that they are reasonably accurate. One of the key things about having work done by an electrician who is a member of a competent persons scheme is the added benefit in regard to the warranty; insofar as there is a problem, most scheme providers provide to the customer through registered operatives. The customer also has the confidence that, if they need to make a complaint about the electrician’s work, they can go to that scheme operator. Therefore, there are additional safeguards for those who use a competent person.
Steve Bratt: There will be good reasons to use building control, as has been explained. For the vast majority of pure electrical work, it would be more cost-effective for a competent persons scheme provider to do that work. The issue for the consumer is knowing that they are using a competent person so they can have that work self-certified without incurring the cost of building control. That is why in the proposal we have talked about a levy to create a fund to encourage the consumer to choose a competent person right from the start, which was the point made earlier by one member of the Committee.
Q26 David Heyes: Mr Everall acknowledged earlier that there was a need to look at the administrative procedures surrounding Part P to improve them. Is that a shared view? If it is, what needs to be done?
Emma Clancy: One of the key points of the proposal from the ECA and NICEIC is the introduction of risk-based assessment, and the idea that we will look more closely at those we need to look at but look less often at those who have a history of doing good work and no complaints and so on. That would, we believe, cut down the paperwork in a way that also allowed us to maintain those safety standards that we think are very important.
Q27 Bob Blackman: Perhaps I may touch on local authority fees for do-it-yourself jobs. In the written evidence NICEIC say there is evidence of inconsistencies between the fees charged by local authorities. What evidence is there for the range of fees charged for the same jobs?
Emma Clancy: The evidence we are talking about is gathered by our contractors and employees when they are on the scene. There can be a difference of about £100 between different building controls for the same type of work, and there is a huge variation for that reason.
Q28 Bob Blackman: Has there been an explanation for why that would be the case?
Emma Clancy: It is not something into which we have inquired.
Q29 Bob Blackman: Mr Everall, I was going to come to you next. What is the explanation for the inconsistency in the fees charged?
Paul Everall: I think it is logical given what I said earlier about each local authority having to be self-financing. It will depend on the nature of the authority. If an authority has a great deal of town centre redevelopment, or something of that sort, it may not need to charge so much money for small jobs. If it is a big rural area where travel costs are a large proportion of the inspection costs, the costs are likely to be higher than in a densely packed local authority with tight boundaries.
Two or three years ago the Government set the fees for all local authorities. That was changed as a result of representations that that was unfair, in that many authorities were not able to charge what they needed to charge to break even on their building control account and yet others were making a surplus. The logic of having a system of regulations that required each local authority to break even is that they need to vary their charges to achieve that.
Q30 Bob Blackman: At the moment a do-it-yourself person can go only to their own local authority for this inspection work?
Paul Everall: Yes.
Q31 Bob Blackman: He cannot shop around and go to the next-door borough, which does it for half the price but is still competent because it is inspecting things?
Paul Everall: At the moment local authorities are not allowed to carry out the building control function in another authority area.
Q32 Bob Blackman: They are not allowed to make a profit on the fees they charge for these services?
Paul Everall: No; they are supposed to break even on a rolling basis. Of course, the accounts are subject to audit, like all local authority functions.
Q33 Bob Blackman: Having been in local government for a long time, I know a bit about this. The fees charged are not transparent figures, are they?
Paul Everall: Local authorities are normally expected to have a scale of charges that people can look at before they decide to carry out the work. It is not a hidden cost in that sense. Local authorities have scales of fees and charges.
Q34 Bob Blackman: To broaden it, should there be wider exemptions for do-it-yourself work rather than the existing position?
Chris Town: To go back to the local authority issue, we know anecdotally that some authorities use third-party inspections; they do not do it themselves. That could explain some of the price variations.
Paul Everall: If we do not have the expertise in-house, we need someone to go out there and do the checking for us.
Q35 Bob Blackman: A local authority could contract out this work?
Paul Everall: The inspection and testing, yes.
Q36 Bob Blackman: It would then determine the fees in accordance with the charges being made by the external consultants, as it were?
Paul Everall: Yes.
Q37 Bob Blackman: Do any of the panel think there should be greater exemptions?
Phil Buckle: Apart from a relaxation of some of the notifiable work that would not be detrimental to the safety of the installation, I do not think there should be wider exemptions for DIY-ers. We are currently in a position where the public are not fully aware of their responsibilities and obligations to ensure that the electrical installation work they are having done, either by themselves or by a professional electrician, should comply with Part P in a domestic situation.
If the person doing the work prefers not to use a competent persons scheme electrician, they need to go through a process whereby that work is notified. It may be that the contracting out could be through a competent persons scheme company that provides that third-party inspection, potentially at a cost lower than that charged by the local authority for that service. There are some disadvantages to that, as has been outlined by colleagues. We come back to Steve’s point about publicity. The Electrical Safety Council can certainly play its part in raising awareness among consumers about their obligations.
Q38 Bob Blackman: I think we will come to communications in a minute. Paul, to come back to you, how many people have action taken against them for failure to comply with this on the do-it-yourself side? Do you have evidence of how many people have action taken against them?
Paul Everall: Not evidence in the sense we have collected statistics nationally. A few cases go to the courts where people are prosecuted for failure to comply with Part P, but it is a relatively small number.
Q39 Bob Blackman: How does that evidence come to pass? If it is someone who does their own work in their own home and they never bother notifying building control, how are they found out?
Paul Everall: Maybe because there is a fire, death or injury.
Q40 Bob Blackman: It would be only in those terrible cases where there was a fire or some other incident that action would be taken?
Paul Everall: Yes. Part of the problem is that a lot of work goes on that ideally should be carried out competently by a member of a competent persons scheme or checked by a third party to make sure it complies.
Q41 Bob Blackman: And you do not have any national statistics on the number of people who have action taken against them?
Paul Everall: No.
Emma Clancy: The NICEIC with Trading Standards have prosecuted six people in the last year for exactly that scenario. Obviously, it does not represent all in that sense, but we have had those successful prosecutions, where, as Paul has indicated, something goes wrong afterwards and it comes to light, maybe when new people move in or other contractors suggest it is an area we should investigate with Trading Standards. Those are the two ways that it comes to light.
Steve Bratt: In terms of monitoring, the scheme operators and the competent persons themselves often report cases of bad workmanship. An electrician will notify the scheme operator, who will take it up with the local authority, so that monitoring goes on. The problem usually arises when there is a difficulty in doing something about it. It brings you back to the point that, if they were to use a competent person in the first place, and we did as much about that, everybody would really benefit.
Phil Buckle: As you point out, the DIY-er can do the work and it is hidden for many years, if it is not going to cause a problem. Fortunately, the system of house selling picks that up, because when they go to sell their property they have to fill in a form through the solicitor and provide evidence that they have had the gas and electrical installations checked. If not, they must have a condition report undertaken. That condition report will highlight problems and concerns about the safety of the installation, so at the point of sale issues will come to light. It is not ideal, but at least it provides a check and balance. Those safeguards are in place.
Q42 Simon Danczuk: I am conscious that there is nobody on the panel representing DIY-ers in terms of electrical work. We will talk about your case later. I am also conscious that the number of accidents is decreasing. It could well be the case that there are DIY-ers out there who have done lots of competent work. Is that not the case?
Phil Buckle: We have done many surveys to develop our baseline evidence about consumer attitudes, because the way we work is to try to change behaviours. The competent DIY-er will take care and be cautious and is likely to find a competent electrician to confirm that the work is to the required standard. There are also cavalier DIY-ers, who have no regard for their safety or the safety of anybody else and will carry on regardless. It is about educating those people to bring them to a point where they understand that their behaviour could be detrimental to the safety of people using their installations.
Q43 Heidi Alexander: I would like to ask some questions about raising public awareness in respect of the regulations that control the safety of electrical installations. I grew up in a household where, since I was this high, my father was a very small electrical contractor, so I am quite familiar with the whole language and systems that changed in 2005. Who do you think should be responsible for raising public awareness of these regulations and the liability on the householder, not the person who has done the installation? Mr Buckle, I think you said that perhaps the Electrical Safety Council has a role to pay, but who do you think should be ultimately responsible for raising public awareness?
Emma Clancy: I think the scheme operators have a significant responsibility, and that is one of the reasons we are asserting there should be a levy to fund and provide that. Certainly, the NICEIC does a lot of work in the form of national media campaigns. We try to make it relevant and fun; we have Linda Barker and other stars promoting things to try to make it relevant to people and give real examples about when you should use a competent person in your home. I think it is very much the responsibility of scheme operators to do that.
Q44 Heidi Alexander: Would the operators cover the costs as opposed to the people who are registered with your scheme?
Emma Clancy: Yes, that would be the current situation.
Q45 Heidi Alexander: Is there a role for anyone else in raising public awareness? There are probably millions of people out there who are blissfully unaware of these regulations.
Phil Buckle: It is a collective effort. We all have a responsibility, but it is about making sure the messages are consistent. There is a risk that with a number of scheme operators there might be a different slant on the message. However messages are developed, they need to be delivered consistently. It is analogous to the smoke alarm campaign that went on for many years; it is about raising awareness of the importance of safe electrical installations. The campaigning activities in which the Electrical Safety Council has been involved have started to have an impact, but there is a long way to go to increase awareness.
Paul Everall: As colleagues have said, there has to be a collective effort. Most, if not all, local authorities have booklets about what building regulations cover. Therefore, part of that will deal with Part P, so anybody who comes along to a local authority can get information on that. I believe that one of the strongest advocates for safe electrical wiring ought to be the companies that sell the products-for example, B&Q and things of this sort. To be fair to them, a number do participate in campaigns with installers. I agree that more can be done to raise public awareness.
Q46 Heather Wheeler: That was to be my exact question. As we are talking about DIY-ers, what responsibility is there on the shops that sell the kit? Do they stick up signs around the stores where electrical equipment is for sale saying, "Do you comply with Part P? Do you have a competent person signing off on this? Have you been to LABC?" I have never noticed any of those signs when I have walked round Wickes, B&Q or anywhere like that.
Phil Buckle: There are challenges in that regard. We have worked hard to try to get B&Q to have point-of-sale information, which we have now achieved in some of their stores. They have a commercial imperative to sell product to whoever comes through their doors, whether or not they are competent, but a more responsible attitude is being taken in respect of Part P.
Q47 Stephen Gilbert: You say there are challenges with the supermarket retailers. You gave the example of B&Q-that they found it difficult to put customer safety first and foremost, and therefore perhaps restrict the market to which they are able to sell products.
Phil Buckle: Perhaps it would be fairer to ask B&Q that question.
Q48 Stephen Gilbert: What is your experience?
Phil Buckle: My experience of DIY sheds in general is that they will sell product to whoever comes through their doors regardless of whether that person is putting it in themselves or getting someone else to do it. Rather than DIY, I am an advocate of GSI, or getting someone in. You can buy it yourself and get someone to do it. There are potential ways to raise awareness through those sheds to allow them still to sell their product but then to get a registered installer to do the work.
Q49 Chair: However hard you try, you will struggle in some areas to raise public awareness. You might raise it with someone who is going to do a job themselves in the home, but if someone orders a new kitchen, for example, they are interested in how it looks-the make and model of taps, the sort of cooker to be put in and all that sort of thing, quite rightly. They will assume that the people who put it in are competent, and that the plumber will do the plumbing and the electrician will do the electrical work, and it will all be all right. Surely, to put the onus on them to make sure that a competent person has done the electrical work is something you will never be able to communicate to the public, will you? Why should not the onus be on the person who is paid to do the work to be a member of the scheme and to be competent to do that work, rather than on the householder who knows very little about this to ensure that the person doing the work is a competent person?
Phil Buckle: It is a double-edged sword, isn’t it? You have to encourage the procurer of the work to do their checks. Are they a card-carrying member of a scheme? That is a clear message to give them. You mentioned kitchen-fitting companies. They have had a bad reputation. There are good and poor kitchen-fitting companies out there. Unfortunately, they may bring in somebody to fit the kitchen who is very competent at making it look nice on the face of it, but everything behind it is perhaps lacking in regard to electrical or even gas safety. The customer has to ask the question and have evidence provided to ensure that the work is adequately carried out.
Q50 Chair: Why do we not turn it around and make sure that the company doing the work is itself part of the competent persons scheme; otherwise, they are committing the offence, not the householder?
Phil Buckle: We would support a mandatory requirement for people to be in a competent persons scheme. However, the customer should still ask the question. When I have work done, I ask to see proof that they are a member of a competent persons scheme.
Bob Blackman: It is that message.
Paul Everall: Surely, there is a difference between gas and electricity. You have to use a registered gas company to have gas work done, but you do not have to use a Part P-competent person to do electrical wiring. Although I think that the proportion of people using competent persons is steadily rising since it was introduced, there is a long way to go before the same message is got across. Of course, CORGI was in existence for many years to raise awareness in the same way that Part P has yet to achieve.
Phil Buckle: If, as we said earlier, everybody was a member of a competent persons scheme, the onus would be on the installer to ensure they were appropriately registered. That would take the burden off the home owner or purchaser of the work.
Q51 Chair: Is there general support for that sort of approach?
Phil Buckle: Yes.
Diane Marshall: If you require everyone to be a member of a competent persons scheme and go through that route, you are putting an extra burden on part of the industry in the new build housing sector, where there are professionally qualified installations that do not go through a CPS.
Chair: We hear that. Thank you very much indeed for your evidence.
Examination of Witnesses
Witnesses: Paul Everall, Chief Executive, Local Authority Building Control, and Trustee of Gas Safety Trust, Simon Ayers, Service Director, Gas Safe Register, Chris Bielby, Chair, Gas Safety Trust, and Chair, Gas Industry Safety Group, and Chris Yates, Deputy Director, Heating and Hotwater Industry Council, gave evidence.
Q52 Chair: Welcome to the second part of our evidence session this afternoon. I will try to get it right this time and ask all of you at the beginning to indicate who you are and the organisation you represent. Mr Everall, we have already seen you once.
Paul Everall: I will not repeat what I said before, but I would add that I am also a trustee of the Gas Safety Trust.
Chris Yates: I am Chris Yates. I work for the Heating and Hotwater Industry Council. We represent the domestic sector, which covers virtually all the gas-boiler manufacturers in the UK, including micro combined heat and power. We also represent builders’ merchants and predominantly large gas-installation companies and also some small installers, so the whole spectrum of the installation and supply network.
Simon Ayers: I am Simon Ayers. I work for Gas Safe Register, the replacement for CORGI. Currently, we have 68,500 registered businesses and 136,000 competent engineers. We manage that process through very different means.
Chris Bielby: My name is Chris Bielby, chairman of the Gas Industry Safety Group and Gas Safety Trust, although the people who pay my wages are Scotia Gas Networks. The Gas Industry Safety Group was set up 10 years ago to look at any cracks in the safety regime of the UK, and we put corrective measures in place. The Gas Safety Trust is about furtherance of gas safety among consumers, so we provide and fund underpinning research for campaigns.
Q53 Chair: Thank you very much. You probably heard the session we had with the people about electrical installation. From what we understand, that was the easy part. We got on to gas, which appears to be incredibly complicated, with a mix of building regulations and health and safety legislation. Is it really that complicated? Do you think improvements could be made to make it more understandable and perhaps safer?
Simon Ayers: The gas safety installation and use regulations that determine the need for Gas Safe Register and competent engineers working for businesses are under review, as are all the other ACoPs, but have been around for a number of years. Mandatory registration came into play in 1991, and since then we have seen huge leaps and bounds in terms of competent engineers and safer work. A number of people still operate outside the legal requirements and we spend a lot of time trying to chase them up. Overall, I think those regulations are proportionate and fair in terms of the gas industry. It becomes slightly more grey when we move into the area of building regulations on the grounds that we have to insist that engineers comply with certain approved documents of the building regulations, but sometimes they do not understand the requirement to comply with a broader set of regulations, so it is not just one but a set of approved documents. Similar to what was said previously, when we have engineers that comply, they will comply well, but there is quite a lot of misunderstanding and confusion in terms of both engineers but also consumers. I do not think consumers truly understand what they are asking and expecting.
Chris Yates: As to building regulations, it is not just about gas but oil and other solid fuel appliances. Quite often, although it is outside gas safety, it is applying the same principles in terms of a central heating system. By and large, there is similarity between a gas and oil installation. The fact you have one document helps to channel the thinking, so you could have engineers that are doing gas, oil and solid fuel, and one set of documents covers all of that for them. By and large, they are following the same sorts of principles. Trying to combine it and perhaps put some of the gas safety issues within building regulations might confuse what you are trying to achieve overall. The building regulations are telling you how to do something and what considerations you can take into account. Simon is right that it is not always obvious.
When you talk to engineers they are not always aware of the latest regulations. That is really a communications issue, which was talked about in the previous session, where industry has a big role to play. We see the information and it is down to us to push it out to installers. The installer is the primary contact with the householder. Most householders do not really appreciate what the heating system is about; they will not know who the boiler manufacturer is. They might know who the energy supplier is but they will not have much of an appreciation of the heating system, so the emphasis is probably more on the trade to communicate that. When it comes to replacing appliances, in 90% of cases that is dictated by the installer. There is a huge amount of responsibility on the installer, but the fact is that the consumer trusts that individual.
Paul Everall: It certainly is complicated. When Gas Safe Register took over the running of the gas register, one of the things on which we had lengthy discussions with them was the education and training of installers. Undoubtedly, they are competent in the gas work they do: the boiler installation and things of that sort. It is very important that you do not undermine other bits of the building regulations, for example by putting a pipe through somewhere or through the fire stopping, which is an integral part of fire safety in the building. LABC works closely with Gas Safe Register to ensure that all of their registered members appreciate that there are parts of the building regulations other than just the installation of a boiler.
The other point I make about complication is that having to work with two separate Government Departments makes it more difficult for a representative body like ours. The principal responsibility of GSR is to the HSE; the principal responsibility of building regulations is to DCLG. That can bring added complications in trying to find solutions.
Q54 Chair: You are not saying that two bits of Government do not work together?
Paul Everall: As a former civil servant, I would not dream of making that comment. Sometimes it is more difficult than on other occasions.
Chris Bielby: From my point of view, there is a regime of legislation right from the gas safety management regulations, which govern instant investigations, through to the installation and use regulations. As Simon indicated, there is a fundamental review of the approved code of practice this year funded by the HSE. That will cover any additions to that guidance document.
Of course, every gas operative goes through an assessment every five years to test their competence. There is a plethora of legislation from the point of view of a gas operative. Some companies take it very seriously. As the electrical people said, some people practise within the competence regime and some practise without. We have to guard against that, educate and bring them into the regime.
As I understand it, the legislation is quite clear about the responsibilities of operatives, and the guidance document just needs updating to take account of new issues that arise, like flues in voids, smart metering and things that will be coming on to the terrain in the next 12 months.
Q55 Simon Danczuk: I have a simple yes or no question. I have here some statistics from the Gas Safe Register that show 55% of work carried out by unregistered workers is unsafe. Some figures from the Association of Registered Gas Installers show that at least 50% of all gas work carried out in the UK is considered to be illegal. My question to each of you-it can be answered yes or no-is, do you think that the current building regulations are adequate when it comes to the installation of gas heating appliances? Paul, what do you think-yes or no?
Paul Everall: No, because gas safety is not covered by the building regulations.
Chris Yates: My answer is the same as Paul’s.
Simon Ayers: It is very difficult because I am quoting two pieces of legislation, so it would be "no" for one and "yes" for the other.
Chris Bielby: From my point of view, yes; if they are in the competence framework, they are aware and taking the test. For the others you cannot legislate.
Q56 Simon Danczuk: Do you think there is a need to monitor compliance better than currently?
Simon Ayers: In terms of compliance, we must not forget that at the moment Gas Safe Register is undertaking over 40,000 inspections a year of its engineers and businesses. We already have in place an effective risk engine, so we focus our resource where we need to. Currently, we have 84 inspectors based around GB undertaking those inspections, so we already have in place a pretty strict compliance regime.
We also pick up a lot of work through things like complaints. If a consumer makes a complaint, whether against a registered or unregistered business, we will investigate and work with the HSE to enforce some action through that process.
Q57 Simon Danczuk: To be fair, all that sounds great, but these statistics suggest that half the work is either illegal or defective. Do we need to encourage more compliance? It is a serious risk, isn’t it?
Simon Ayers: As to the current numbers for unregistered illegal work, you quote the figure of 55%. These are people who flout the law and do not go through a recognised competency regime; they do not become registered and undertake gas work. Without a doubt, that is where we find the biggest risk, but we also have a team of inspectors dedicated to looking for those people. Again, we have almost a hit squad that works tirelessly to reduce those numbers. I think that in there it quotes 250,000 jobs.
Q58 Simon Danczuk: The hit squad is not hitting the problem, because half of it is not right.
Chris Yates: We run a scheme called Benchmark, which is referenced in the building regulations and is a means of compliance. Within that you have to detail the appliance and its serial number. The manufacturer is using that as part of its warranty. It is not just terms and conditions; it is the other extended warranties, if you like. Provided that form is filled in, they will get the other part, the warranty. The benefit of it is that you have the serial number and you know that appliance has gone in and you can trace it back to the manufacturer. It does not solve all the issues but it goes a way to try to get visibility. Unlike a car, you do not know where a gas central heating system or any boiler is.
Q59 Simon Danczuk: Paul, do you have a view?
Paul Everall: Not really, because the main responsibility for compliance with the Gas Safe Register is nothing to do with local authorities or building control.
Q60 Heather Wheeler: I think you have just said a magic word. Did you say that gas boilers had a serial number on them?
Chris Yates: Yes. As part of the product standards they must have a serial number.
Q61 Heather Wheeler: The other week we did an inquiry in which somebody suggested there was no such thing, like a VIN number on a motor vehicle. Somebody gets a gas boiler installed and three months later they are burgled and the gas boiler is nicked and moved somewhere else. Therefore, that could be traced.
Chris Yates: Provided you have the number, it could be traced, but that assumes it is on there.
Q62 Heather Wheeler: You will have the number because it will be on your warranty?
Chris Yates: You could. If one is stolen it would be relatively easy. Unlike a VIN, which is stamped on the body of the car and is hard to remove, this number is on foil. It is to a certain specification, but it is stuck to the inside of the boiler, and it could be taken off, if you had a mind to do it.
Q63 Heather Wheeler: But the next person buying it should check that it has a new number for a warranty?
Chris Yates: Yes, they should. That is part of the communication exercise. The whole point is that you want to know where it is, but it is a difficult area. I have been in the industry for 12 years, and trying to get people to register products so you know where they are is a constant battle. Compliance is at best 40%; typically, it is 10% to 15% depending on the manufacturer, but the changes we have made under Benchmark are moving in that direction.
Q64 George Hollingbery: Gentlemen, you know that we have just been talking to the electrical side of the business. Can you describe to me how the Gas Safe scheme works and is different from the electrical scheme, assuming you know enough about the latter?
Simon Ayers: For me, the key would be that in 1991 it became a mandatory requirement for any engineer undertaking gas work for gain to become registered, so we ended up with a change in the regulations. The gas safety installation and use regulations included that requirement under regulation 3. We are not a competent persons scheme; we are a mandatory scheme with registrants and we are the registrar. We are clear about that message. We also have to be a competent persons scheme for some areas of building regulations, and that is where a lot of confusion arises, especially as gas engineers in their everyday jobs of installing central heating systems may install the radiators, water system and electrical system so they would need to be compliant in a number of areas. That is where we tend to see people drifting into different things as well.
In terms of competence, I do not think anybody would argue that there is a similar requirement across the board for people to be competent when undertaking electrical or gas work and other areas that have been mentioned such as oil and so on. We have a high number of very competent, able and skilled building services people, but we also have a number who will flout both those areas.
Q65 George Hollingbery: Just to be clear, you are not at all responsible for the building regulations side of things. Do you even certify for the competent persons scheme?
Chris Yates: Yes. To go back to the point made earlier about serial numbers, we have a notification process, so a gas engineer has the ability to self-certificate for compliance with building regulations. The current cost is £2.20, so it is a fairly cost-effective process to go through. They are self-certificating as a competent person that the installation is compliant with building regulations. We have tried to pull this together to allow probably a less costly and easier process for the person to be compliant.
Q66 George Hollingbery: Mr Everall, if, let’s say, we have a mandatory competent persons scheme for electricity, it will be different from the gas scheme because building regulations will not be involved at all on the electrical side of things. Is that correct?
Paul Everall: Local authority building control would not be involved at all. The building regulations and the means of complying would still be there. If you were to go down that route with electrical work, it would be similar to gas, except that you would not have the gas installation and use regulations on top of the building regulations.
Q67 George Hollingbery: You still have the complications about going through firewalls and so on and so forth. If you had a competent persons scheme, there would be exactly the same complication but there is also a raft of building regulations?
Paul Everall: But one of the requirements of any competent persons scheme operator, not just in electricity but elsewhere, is that the work must comply with all parts of the building regulations, not just the specialism that is being put in at that time.
Q68 George Hollingbery: If we as a Committee recommended that something like the Gas Safe scheme was put in as a competent persons scheme-I suspect that Gas Safe will always be at a higher standard, maybe not-it will still end up looking very like the Gas Safe scheme with the building regulations lying underneath it?
Paul Everall: Yes.
Q69 George Hollingbery: Do any of the gentlemen from the gas industry recommend that as an approach for electricity? Do you feel competent to answer that?
Chris Yates: I could not judge the electrical scheme. I am pretty comfortable with the way Gas Safe works. As a model I would say it is very good, but I could not draw a comparison between that and the electrical sector.
Q70 George Hollingbery: I have no doubt it has become more expensive to install gas over the last 20 to 25 years because you have to have much more competent and highly trained people and so on, quite rightly. That reflects the inherent dangers. Would we expect, therefore, to see the same thing happen in the electrical arena? Would we expect householders to end up paying more to have electrical circuits installed?
Paul Everall: Not necessarily, given the earlier discussion. There would not be substantial fees being paid to local authorities, for example, if all the work was done in that way. You heard a comparison between the figures charged by competent persons schemes and people like the NICEIC, so there would be savings as well as additional costs. I would argue that one of the benefits of the Part P scheme is that there are more competent electricians around now than 10 years ago. They may not all be competent yet, but we are heading in the right direction at the very least.
Q71 George Hollingbery: Mr Ayers, I am sure you run a perfect organisation. However, would you allow us to inquire what does not work in Gas Safe and ought to be improved, and what you would like to see done?
Simon Ayers: The one area where improvement could probably be made is in the messaging and the understanding of areas that need compliance. I think we have made that clear in our submission.
Q72 George Hollingbery: We will be asking questions about that later, so I do not want to press you on that. Are you happy that as a scheme to regulate a dangerous activity within the domestic setting it is about right?
Simon Ayers: Yes.
Chris Bielby: One system for reporting dangerous occurrences within the gas arena is RIDDOR. Any fatalities or major injuries are reported consistently through gas safety management regulations as well, so when it comes to reported statistics we know there is a pretty accurate correlation with HSE. There is not just one registration scheme; there is also one system of reporting injuries and accidents.
Q73 George Hollingbery: Mr Everall, the NHBC did make the point that there was confusion in the building regulations about voids and communal spaces, and where Gas Safe, building regulations and so on were involved. Do you accept that there is some tidying up to be done in the regulations?
Paul Everall: Yes.
Q74 Stephen Gilbert: Each year 4,000 people go to A&E as a result of carbon monoxide poisoning. Of those, 200 are admitted; of those 200, 50 die each year, which is more than the number of people in this room. The country loses about £158 million a year in terms of either lost revenue through NHS services provided to those people who suffer carbon monoxide poisoning or lost productivity from the people who are out of circulation. Clearly, the regime is not working 100% effectively, and perhaps you could argue that no regime would, but how can we take extra steps to prevent that level of carbon monoxide poisoning occurring?
Chris Bielby: To make one clarification, not all the 50 deaths are attributed to mains natural gas or LPG; they are across all fossil fuels, so oil, coal and other solid fuel. Two reports are issued each year: one is the HSE’s "Re Gas" report; the other is the downstream incident data report of the Gas Safety Trust Commission, a copy of which I will leave for your reference. One report runs from June through to July, so it takes into account the heating season of October to March; the HSE report runs from January. The correlation is good, but this year we will be announcing, as we did at a breakfast meeting the other week, eight mains and LPG gas-related deaths; the rest are to do with other fossil fuels. There has been a downward trend over the last 25 years.
Q75 Stephen Gilbert: I do not suppose it matters to the other 42 people that it was not mains gas that made them peg out. Overall, how can we improve it?
Chris Bielby: We would like to encourage the RIDDOR reporting process to cover all fossil fuels so we get accurate reporting across the field. A number of trusts exist. One of them is under Gas Safe and I chair one. We do a lot through the medical fraternity. Last year we did a large study of four A&E departments to look at those cases where people come in with flu-like symptoms. You will see a lot happening in the medical fraternity about algorithms used to assess whether it is flu or carbon monoxide poisoning. We are repeating that study through GP surgeries. One of the recommendations of the report of the all-party gas safety group chaired by Baroness Finlay is that we widen that research and, once we have found out the reasons, use that awareness in the medical fraternity and all first-call operatives, whether health visitors or community nurses. At the moment that piece of research is funded by the trust.
Q76 Stephen Gilbert: I have read the report of the all-party parliamentary group. To press you on the point, I expected you to say, because I thought your evidence suggested it, that carbon monoxide detector alarms should be installed or, where necessary, replaced whenever notifiable work was carried out. I notice that is different from what the all-party parliamentary group suggests.
Chris Bielby: All the reports are consistent. Our wish is to get carbon monoxide alarms in every home in the land. If it was the same as smoke alarms at 84%, the accident rate comes down quickly and dramatically. At the moment, between 12% and 15% of properties have carbon monoxide alarms. Whether different groups want common denominators, the one thing that prompts action is an audible carbon monoxide alarm.
Paul Everall: Under the current building regulations carbon monoxide detectors are a requirement for solid fuel appliances. I would agree with the recommendation in the APPG report that it should apply to all fuels. Later this year we shall see the introduction of the Green Deal, which will allow people to have energy efficiency improvements done at no upfront cost. If it was made a requirement that a carbon monoxide alarm should be fitted in all dwellings where energy efficiency work is done under the Green Deal, that would help to solve a lot of the problems. A big problem is that building regulations can bite only where building work takes place, and what we really need to do in many of these policy areas is tackle the existing stock.
Chris Yates: I fully agree with the necessity of carbon monoxide alarms, but it must not be a replacement for annual servicing. There are instances where people put them in and think, "Fantastic. I don’t need to bother about a Gas Safe-registered engineer coming to inspect my property every year." That is a dangerous situation to get into, and it comes back to communication. We must have a consistent message. Part J of the building regulations details that because it follows the British standard. It cannot be a substitute for annual servicing, and it is very important that they are linked together.
Simon Ayers: For me, there are two aspects to add to this. First, as the register we now have really good awareness in terms of gas. We aim to send messages about Gas Safe Register and carbon monoxide to every user at least 10 times in a 12-month period. We are also talking to all the charities concerned with carbon monoxide; we talk to all of our 400 stakeholders to get out the wider message, so that is a regular point.
Secondly, wearing a slightly different hat, I am also a trustee of the Gas Safe charity. We are working with people like WRVS and RoSPA to broaden that awareness. I think that will touch a wider audience than just gas. That is probably where you will start to see more around solid fuel, oil etc. A lot is taking place.
Chris Yates: One thing worth emphasising is the fact that the industry takes it as an absolutely critical issue. We have been involved in quite a lot of different issues related to CO over the last three years. We have made a lot of strides in getting the same message out from every manufacturer through every training programme. When you make recommendations to installers, they get the same message from each manufacturer. That has helped in training engineers to be aware of the potential problems and to do something about it. We have proved it can be done, and it is a case of continuing to look at it and at what opportunities industry has to try to influence that.
Chris Bielby: To complement that, in 2007 Ofgem in its supplier licence review made sure that each year any energy retailer gave information on the safety of gas and carbon monoxide. That means every home in the land gets some communication each year about carbon monoxide hints and tips.
Q77 Heather Wheeler: Earlier we talked a little about publicity, particularly along the lines of using registered competent firms that are qualified to do the job. But we have statistics showing that time and again work has been done by rogue contractors. Whose responsibility is it to get the information out there so the public understand the simple change from CORGI to Gas Safe? That was a big jump to me. We understand CORGI. I remember filling in a survey about 10 days ago, and I did not know Gas Safe. If it had asked whether I was aware of CORGI, I would have known. What are you guys doing about getting publicity out there to the public?
Simon Ayers: We probably have two angles on this. The first is that we have identified that the registered businesses were perhaps not the best ambassadors in the world. They are all issued with individual licence cards and are registered as being competent in anything up to 93 different areas of work. We have gone to a back-to-basics-style process to get them to start to show the card when they arrive at a door. Rather than being asked, they start to promote themselves positively. We also work with energy suppliers on a pool process to get them to use straplines on bills to get messages out to say you should use a Gas Safe-registered business and engineer; you should have CO alarms; you should have your appliances serviced, and all the key messages. We also go to our 400-plus stakeholders, who put out a huge number of messages. It is very, very difficult, because in most cases behaviourally we find that people normally want to engage only when they need to do so. They need to understand when the boiler goes wrong, something happens, or when a cooker needs to be fitted, and that is quite a difficult one to change.
Chris Bielby: When Gas Safe came into being it did some very vivid television advertising about cowboys. All the vehicles now must have the Gas Safe livery. I know that your inspection team looks for that. There is a review of the building regulations going on at the moment. I know there will soon be a review of the approved code of practice under the installation-and-use regulations. I also know that work is being done by the HSE research establishment at Buxton on flues in voids, which have an implicit impact on building regulations. If the timing is right, all of this could come together in a very coordinated way. I just make you aware that there are other pieces of research going on at the same time that will impact on building regulations. The HSE and Building Research Establishment are very much involved in that.
Chair: Thank you very much indeed for your evidence this afternoon.