Replacing parts: Lack of regulation poses real danger

Neil Macdonald, technical manager at the Heating and Hotwater Council (HHIC), looks at the importance of selecting approved replacement parts when taking on a repair.

Consumer safety is of utmost concern to the gas industry. Full stop. As such, we are governed by stringent regulations regarding the installation of appliances – but what about replacement parts?

As gas engineers we are all very aware of our duties to protect the end user, and, should any replacement parts be needed, the reliance placed upon us to maintain the safety of the appliance.

Indeed, this is, quite rightly, a legal obligation. The Gas Safety (Installation & Use) Regulations 1998 (with 2018 amendments) states: “No person shall carry out any work in relation to a gas appliance which bears an indication that it conforms to a type approved by any person as complying with safety standards in such a manner that the appliance ceases to comply with those standards.”

However, as the spare part side of the industry remains largely unregulated, is this as simple as it should be to uphold? How easy is it to tell ‘genuine’ parts from those which could pose a potential threat?

I’m sure many of us have been subject to the disappointment that can arise from buying an ‘alternative’ version of a product we need, for various reasons, only to find it doesn’t work as well as intended and we have undoubtedly wasted money. When it comes to a set of headphones, for instance, this is something we can usually take on the chin, but when it comes to the gas industry the dangers are very real.

The extensive product research, development and testing that gas appliance manufacturers undertake when creating a new product and bringing it to market, gives reassurance for those installing the final, assembled product that each component part will perform as intended, in a holistic manner. Yet, when it comes to replacing a part, there may be a choice of options that appear the same, or very similar, but that may not be underpinned by such robust testing, of the type that ensures demonstrated safety within the appliances they are marketed for use with. Indeed, some may never have been physically tested within the appliances in this way.

The Gas Safe Register, in tandem with HHIC, and via Technical Bulletin 116, go as far as urging installers to only use manufacturer approved replacement parts. It notes that using unapproved parts when replacing controls could result in the product appearing ‘to work ok’ but is a ‘dangerous practice’. The main reason being that the safety and performance of the appliance cannot be assured if manufacturer’s recommended parts are not used. The HHIC are unequivocal in our stance that responsible businesses and engineers will whole-heartedly support the view that spare part selection should be based on ensuring safety, through correct specification.

Several of our HHIC manufacturing members have volunteered sobering information on the differences in performance of part variants available on the market, seemingly for the same application. Starting with basic visual indicators, and comparing to the manufacturers 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 inrush current can greatly exceed those of the OEM design, and so raise potential safety concerns.

Where does this leave installers and merchants wanting to buy and sell the best, and ensure that consumer safety is rightly paramount in the decision making process? At present, only opting for genuine parts is one way to safeguard themselves, but perhaps a clearer industryled labelling system could provide another solution to help support this.

For a potential analogy, think of Fairtrade coffee, and what if a similar “mark” could help registered gas engineers to discharge their legal duties referred to earlier? Of course, we already have the legally required CE mark, for gas appliances and many of their component parts, even when sold as spares, which is a great starting point, and the principles of which a mark of this type could build upon. However, it is an interesting concept to consider introducing a new dynamic of validated part/appliance safety in combination, something which could only help to support consumer safety, and registered engineer conscience.