CIH Northern Ireland response to proposed amendments to the Gas Safety (Installation and Use) Regulations (Northern Ireland) 2004

Chartered Institute of Housing (CIH) Northern Ireland welcomes the opportunity to respond to the HSENI consultation on proposed amendments to the Gas Safety (Installation and Use) Regulations (Northern Ireland) 2004 (GSIUR). As the professional body for housing, our response is informed by feedback from our members and partners who manage both social and private residential tenancies across Northern Ireland.

Response to part one: Landlord gas safety record flexibility

1. Do you agree with the proposal to allow a 10 to 12-month window for safety checks while preserving the existing expiry date?

CIH Northern Ireland supports the proposal to allow gas safety checks to be carried out within a window of 10 to 12 months after the previous check.

Feedback from the sector, including private landlords and property management companies, indicates that this flexibility will allow for more efficient scheduling between property managers, tenants and inspectors. By treating the check as if it were carried out on the last day of the validity period, the amendment removes the current ‘penalty’ where early access results in a shortening of the overall safety cycle.

We agree with HSENI’s assessment that this administrative flexibility can be introduced without compromising the safety of tenants.

2. Do you think there could be any unanticipated consequences for landlords as a result of this amendment?

The primary concern raised by our members regarding unanticipated consequences relates to technical infrastructure. Specifically, some existing property management software programmes may be designed to recognise only finite expiry dates rather than a flexible range. Landlords may require a transition period to update IT systems to accommodate the new ‘MOT-style’ anniversary preservation.

Response to parts two, three and four

3. Do you have any other feedback on Parts 2, 3, or 4 of the consultation?

Northern Ireland has no specific objections or detailed technical feedback to offer regarding the proposals for:

Part two: Disapplication for dedicated vehicle gas installations
Part three: Alternative safety checks for engineers when heat input/operating pressure cannot be measured
Part four: Designating Service Layer Engineers (SLEs) to perform specific meter disconnections without Gas Safe registration.

We trust that the competency requirements for SLEs under regulation 3(1) will remain robustly enforced.

Conclusion

Overall, CIH Northern Ireland views these proposals as a pragmatic step toward reducing administrative burdens on landlords while maintaining high safety standards.