Answers to questions raised at the Technical Conference 2018

During the Technical Conference 2018 there was a session of round table discussions which asked delegates to raise issues or questions, some of which were addressed by a panel.

The following are the issues that were raised together with more detailed responses.

Technical Issues

  • Introduction of a reassessment of competence for electrical work like gas?

Unless the whole electrical industry agrees a need for formal qualifications it is unlikely that a formal requirement for re-assessment will be introduced. Keith Warren of CESA has investigated this and established that the ECS (Electrotechnical Certification Scheme) has a classification of Registered Electrician which requires a NVQ level 3 qualification and BS7671 qualification. As this card is accepted by CSCS (Construction Skills Certification Scheme) it has to be renewed every five years, however, the renewal does not require any additional training or assessment other than a current H&S course).

It is however, possible for ceda and CESA to set their own standards and require their members to ensure that all engineers complete the CCEECC course and then in due course introduce a 5 year re-assessment. At present we are still a long way from doing this as many members have not yet put all their engineers through the CCEECC course so the associations can only encourage members to certify their engineers’ competence.

  • Warranty calls in outlying areas example Isle of Wight is average 5 day response

It is understandable that manufacturers are not always able to meet all warranty requirements in outlying areas, however, there is nothing to stop distributors negotiating alternative warranty cover using their own or subcontract engineers who should be trained by the manufacturer.

  • Who approves the number of bottles for various items of equipment in a LPG installation in a tent? Does legislation require mechanical Ventilation, Air input and Interlock?

UKLPG COP 24 Part 3 section 2.2 (Build-ups, Gazebos, marquees, Tents, Stalls or other Temporary Structures) states “Where a single appliance supplied by a single cylinder without a flame supervision device is in use, ventilation shall be equal in area to the longest wall (from eaves to ground level). Also, additional ventilation shall be provided by a 150mm gap at ground level on each of the other walls.” A Single appliance fed from a single cylinder is out of scope of the Gas Regulations.

The document also provides information for installations using multiple appliances and cylinders. The information covers pipework, storage of cylinders as well as a formula in section 8 for calculating ventilation requirements. It is possible that ventilation can be provided by natural means, however, if mechanical extraction is required then an interlock will be required.

  • Manufacturer training on ice machines and dishwashers

Distributors should contact their suppliers for training on these products. If a supplier will only provide training to distributors who actively sell their products and not to service companies, ceda will be happy to take this up with the supplier on behalf of members.

  • Engineers working out of scope (LPG Street Traders and CC5)

Engineers working out of scope are committing an offence so they should be reported to HSE via concerns@hse.gsi.gov.uk. All reports are treated in confidence and those reporting the working out of scope remain anonymous.

  • Fake parts entering the market

It is recognised that fake parts are available through internet sellers, however, these are usually inferior to the OEM or OCM parts and can possibly be dangerous. Most reputable spares suppliers only supply OEM or OCM parts. Fake or generic parts can affect the CE validation of the equipment.

  • Engineer training quality

There are many providers of training for service engineers and ceda/CESA have licenced First Choice Group Training as they have proved to be both highly competent and competitive for members. It is accepted that many manufacturers do not have full time provision of engineer training and in these cases, it becomes a commercial decision for the distributor to determine who he buys from.

  • WRAS – Product approval process. Equivalent non WRAS standards are available

It is very important to qualify the requirements of the Water Supply Regulations requirements:

The requirements of the Water Supply (Water Fittings) Regulations for water fittings are as follows:

Regulation 4 – (1) (a) requires every water fitting to be of an appropriate quality and standard.

Regulation 4 – (2) requires that to be deemed of an appropriate quality or standard a water fitting must meet one of four criteria, i.e.: –

a. it bears an appropriate CE marking in accordance with the Construction Products Directive;

b. it conforms to an appropriate harmonised standard or European technical approval;

c. it conforms to an appropriate British Standard or some other national specification of an EEA State which provides an equivalent level of protection and performance; or,

d. it conforms to a specification approved by the regulator.

WRAS is a subscription membership company limited by guarantee and was incorporated on 4 August 2008. The subscribers of WRAS are the 26 UK Water Suppliers.

WRAS approval is only one way of ensuring that products comply with the regulations, however, water company inspectors, understandably tend to stipulate WRAS Approval as being necessary. You can argue with them and give them proof of other approvals that show compliance with the regulations, however, this can be time consuming so most manufacturers make a commercial decision and obtain WRAS approval.

Commercial Issues

  • Main Contractor payment terms and retentions

ceda is a member of Build UK and as such, all members are considered to be members of Build UK. In addition to subcontractors, Build UK also has major contractors as members. Build UK have a number of key priorities including zero retentions by 2025 and improved payment terms (30 days) by the end of 2018.  For further information see  https://builduk.wpengine.com/wp-content/uploads/2017/01/Implementing-the-Construction-Supply-Chain-Payment-Charter-Guidance-Note.pdf

  • Margin erosion

The ceda confidence survey shows that most members are reporting that their margins are as good or better in 2018 than in previous years. The survey also suggests that that around 80% of members report better or equal sales which suggests that the market is reasonably buoyant. 

It is accepted that many large customers stipulate the labour rates they will pay for maintenance work and it is therefore a commercial decision as to whether a company accepts this. Efficient businesses will seek to reduce their own costs by various means including technology so as to retain acceptable margins. A question was also raised concerning a potential scenario of a customer proposing margin percentages for spare parts.

Whilst the relevant non-ministerial government department (CMA) is unable to comment on general situations, they are able to comment and/or investigate if there is a specific complaint made to them.

  • Warranty feedback required no matter if chargeable or not. Speed of invoicing if chargeable

ceda and CESA surveyed their members and partners to determine what the market requirements for warranty work are and ceda have published a guidance document which is intended to help members reach a formal agreement with suppliers. This document covers feedback etc.

  • Manufacturers trying to tie customers into service contracts during warranty calls (back door approach)

Whilst this is understandable, distributors should discuss this with their suppliers and reach a formal agreement.

  • Internet pricing

There are some actions a distributor can take to minimise the impact of internet prices. Firstly, they should avoid using suppliers who supply the internet box shifters and secondly, they should sell the “added value” that they provide. ceda is actively promoting the benefits of dealing with a member company to the market through video and social media.

  • Prices/margins of equipment sales are being driven down but installation prices are increasing due to lack of engineers, difficulty of installation, travel and fuel costs

There is a general shortage of engineers both for service and installation. ceda is trying to help members address this by developing a funded apprenticeship which is planned to be available from autumn 2019 and also by establishing a programme for training ex military personnel. There is also an electrical and electronic service and installation service engineer trailblazer which qualifies for funding and which is delivered nationally.  https://www.instituteforapprenticeships.org/apprenticeship-standards/electrical-electronic-product-service-and-installation-engineer/

  • NICEIC at conference to clarify their standards and processes

This is a good suggestion and will be included in our planning for the next technical conference.

  • Bogus injury claims i.e. whiplash. Insurance companies should clamp down on these

The insurance industry is working hard to address this problem see https://www.abi.org.uk/news/news-articles/2017/07/the-cons-not-on–insurers-thwart-2400-fraudulent-insurance-claims-valued-at-25-million-every-week/

What more can your trade association do for your business

  • Continue to raise the profile of the industry

ceda already promotes the benefits of using its members to end-user associations and is developing a series of videos to promote ceda members to a wider audience through social media. It is planned to increase this campaign over the next twelve months.

CESA has extensive resources available to represent manufacturers, distributors, resellers, service companies and operators. It provides Information Involvement and Influence on all of the key industry issues and continues to promote this advice through all media channels.

  • Lobby for change like electrical reassessment

This has already been addressed in the Technical issues.

  • Raise awareness in schools about our industry as a career option.

Both ceda and CESA intend to participate skills exhibitions to promote both the engineer apprenticeships and other career opportunities in our industry.

  • Is there an anticipated date for the issue of the Warranty Guidance Document?

This was distributed to ceda members and partners on the 7th November

  • More conference calls and less meetings.

Some meetings (such as the technical conference) need to be face to face particularly when a large number of people are involved, however, both associations are using more conference calls and video conferencing where feasible.

  • How do we know if guidance has changed since DEFRA has withdrawn its guidance document regarding odour and noise control? What replaces it? How does this impact on existing installations? Cost of reskilling staff to be compliant in the new guidance?

At the present time there is no detailed guidance available since DEFRA withdrew their guidance document. BESA are working to produce new guidance as quickly as possible.

  • WRAS/Water Regulations – We need a standard across the country (Basic Standards)

The water regulations like all regulations are open to interpretation in some areas, however, it is a fact that different water suppliers (and even different inspectors in the same company) interpret them differently. ceda/CESA intends to try to open a dialogue with WRAS and the water companies on this through CESRB.

  • Lack of qualified engineers (However in hand)

As already stated, ceda and CESA are addressing this by the development of apprenticeship programmes and also by setting up a scheme to train ex forces personnel.

  • IT Innovation updates from outside of our industry

Both associations try to publicise new technology when we become aware of it. For example at the 2017 technical conference we had an exhibitor promoting video cameras mounted in a form of spectacle frame to enable engineers on site to communicate directly with remote specialist help

  • Training videos for engineers to help fault finding on equipment.

Manufacturers are responsive to assisting with the identification of faults and technical advice is available directly from them. ceda is encouraging manufacturers to develop engineer training videos which, when available, will be accessed through the ceda E learning platform.

  • When the apprenticeship is up and running we should advertise it at grass roots level, Schools, Job Fairs. ceda members to attend with ceda. Other areas of the business should  be promoted i.e. sales, service admin, Install other than service only

Already addressed above.

  • Both associations need to point out at point of sale that kit needs servicing as part of the warranty conditions.

Manufacturers’ installation and use instruction manuals will stipulate that regular servicing is vital to protect the warranty and to ensure the longevity of the equipment and also its safe operation. Whilst both associations offer advice on this type of issue, it is essential that the buyer and seller are clear on what is and what is not covered. Professional commissioning of equipment is an essential requirement for all installed equipment.

Member due diligence

ceda members agreed at the last AGM to a new Code of Practice which comes into force in January 2019.  This requires due diligence.

  • Better OEM engagement on technical issues and support

Manufacturers are responsive to assisting with the identification of faults and technical advice/support is available directly from them.

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