Rosko, Agreed that any situation which in effect means all installs must be subject to a check by competent persons should at face value work. Leaning on insurers so they all require vehicles to be UKLPG registered is an obvious way to achieve this, and should at face value work, but this assumes that UKLPG database registered status means vehicles have actually been checked by competent persons - There are problems:
UKLPG's scheme is already easily cheated, Mike Chapman from UKLPG agrees and cannot see how this can be prevented (other than suggesting vigilance by members AND none members - I replied members who take cash over the phone and none members are unlikely to 'bite off their nose to spite their face' - Mike agreed again)... Likely if UKLPG's scheme was involved with 100% of installs we would simply see an even greater increase in the number of cheated registrations with no way of preventing them. Related argument - any scheme which involves certifying own work is less substantial than one that involves independent certification.
Mike said that UKLPG's scheme runs at a loss, the shortfall paid for by gas supply companies, that UKLPG currently sees only 33% of converted vehicles. If it were to cover 100% of converted vehicles they would need to employ more staff, would run at an even bigger loss or scheme charges / gas prices at the pump might need to increase. Nobody wants pump prices to go up, UKLPG doesn't have a majority membership of installers as it stands, higher UKLPG membership costs might not encourage a greater percentage membership even if all insurers required database registration - instead even more registrations might be fraudulent.
Mike said UKLPG don't want to be running the scheme - he has suggested the MOT scheme to government himself. What happens if UKLPG say 'no thanks we're not doing this anymore'... Then we would be in a situation where government has to scrap the idea or set up a new body to check new LPG installs or maybe offer UKLPG incentives such as payment so they will continue, all of which could have been avoided by using the MOT scheme.
How would government lean on insurers? Seems the relevant standard by law is more likely to be BSEN than COP11 so this might imply the government needing to have dual standards or a change in law. All insurers will already have had UKLPG's scheme / case presented to them, yet only a minority have acted on UKLPG's advice... Maybe insurers are put-off by the legal standard being BSEN whilst the trade body touts COP11 / the lack of incidents involving LPG vehicles / they might feel UKLPGs scheme is ineffective / insurers might not want to lose custom by making their customers jump through what they consider unnecessary hoops whilst other insurers don't). Maybe any leaning would need to include the same type of changes in law that, when presented as a requirement for the MOT scheme, you've said couldn't / wouldn't happen.
Recent emails between Mike and myself below... I'm not going behind Mike's back by posting emails etc, he has said he is happy for me to quote him in part or entirely.. Obviously the following are in reverse date/time order due to being copied / pasted emails... start at the bottom and work up! :
Mike Chapman Oct 14 at 6:41 PM
To
simon andrew
Thank you for your message.
I am currently out of the office on annual leave, returning on 2nd November
I will endeavour to reply as soon as possible , but if you require an urgent response please email
autogas@uklpg.org with your enquiry
Mike Chapman
Autogas Manager
UKLPG
Simon andrew Today at 6:41 PM
To
Mike Chapman
Hi Mike,
This was meant to be a quickie, sorry for the length!
Here's the link to the BMW forum thread..
http://www.bimmerforums.co.uk/forum/f15 ... ndex2.html
The above link to the BMW thread was posted on the LPG forum thread:
http://www.lpgforum.co.uk/viewtopic.php?f=33&t=11760
We may have to disagree on our thoughts on the hypothetical comparison in the email I just sent... In the extreme situation comparison, situation 1 would mean only (literally) a couple of vehicles would be checked thoroughly, with the rest (above 99.5%) not being checked at all.. I think situation 2, which would only check the tank couldn't wobble about but applicable to 100% of installs, would be a better situation. The wobble test would of course be an extremely and laughably basic test, but one which could easily be extended to check tank fastening where fastening points are visible without having to dismantle things like carpets - since dismantling doesn't need to be done on the majority of installs (particularly now most tanks fitted seem to be 30deg internal toroidal) to check tank fastening points / spreader plates, the above comparisons based on real figures would become 33% of installs having a thorough check but 67% of vehicles not being checked at all in situation 1, and in situation2 maybe 80% of vehicles having a meaningful check on tank security but no further checks. Would think tank security to be the most safety critical aspect of an install? I would also suggest that getting MOT man involved at even a very basic level in commissioning LPG systems as 'safe' would raise MOT man's awareness of LPG system safety and this would be reflected in him checking LPG systems more thoroughly during the usual annual MOTs. All above situations involve compromises, point of view will depend on which set of compromises are preferred.
You and I would prefer MOT man to commission LPG systems as safe instead of UKLPG members, DOT won't (literally) buy into it. You also recently pointed out that Vosa wouldn't want to be held responsible for unsafe installs - to this I would answer there will be many vehicles involved in accidents due to vehicle problems even where vehicles have just passed an MOT, on the printed MOTs there was a kind of disclaimer 'this document doesn't necessarily mean the vehicle is safe'. As long as MOT man checks the points he is obligated to check, he and VOSA have done their bit and cannot be held responsible. On the forum I have said before that MOT man is accountable to VOSA and can lose his licence for not doing his job properly, and if found to be at fault will lose his licence to do MOT's. In comparison, an installer can be struck out of UKLPG and still legally convert vehicles... In the general context of the discussion, the argument for responsibility and blame cuts both ways. Maybe to reassure DOT / Vosa, an acceptable compromise would be a test which wouldn't be too technically specific for MOT man, and this kind of basic test also wouldn't involve expensive retraining.
Perhaps we could come up with a suggestion for DOT that would include checking 100% of vehicles but not be too costly or technically specific to prevent DOT from implementing it. Such a scheme will of course mean compromises on what is checked and under what circumstances, i.e. regards the spreader plates point - I would suggest check the suitability if visible without dismantling. Despite talk, which I can only agree with, regards MOT man not being able to dismantle, I have known MOT man to remove carpets etc to check inner sills, floors, etc for corrosion where they have been unsure as to the extent of corrosion having only seen one side of suspected corrosion...
Regards,
Simon Andrew
LPG Conversions
www.Lpgc.co.uk
07816237240
From: Mike Chapman <
mike.chapman@uklpg.org>
To: 'simon andrew' <
cheapmotoring@yahoo.co.uk>
Sent: Tuesday, 14 October 2014, 17:01
Subject: RE: UKLPG
Hi Simon
I have to say I disagree regarding the emails – MOT inspectors can’t even lift the boot floor to check if a tank is loose! Checking 100% of very little is worse than a thorough check on 33% and the checks by our installers have picked up real issues which would not have been picked up by the MOT basis.
Am happy for you to go public with my views, we are transparent in what I / we do.
What you have posted is a fair reflection – my only issue was with the MOT which I thus raised.
As regards the Forum, I do not have the hours to devote to checking everything on this or any other Forum and leave our installers to raise points as they wish or advise me if there is a situation they are concerned about
Please do not hesitate to keep in touch or contact me to clarify any issues or concerns you may have
When we spoke you mentioned the BMW Forum with details of the tank installation. I have not been able to find it – do you have a link so I can follow up?
Regards
Mike Chapman
Autogas Manager
UKLPG, the trade association of the UK LP Gas industry.
mike.chapman@uklpg.org | Visit:
www.uklpg.org.
UKLPG is Registered in England No. 977549.
www.drivelpg.co.uk the independent consumer guide to LPG autogas in the UK
From: simon andrew [mailto:
cheapmotoring@yahoo.co.uk]
Sent: 14 October 2014 16:52
To: Mike Chapman
Subject: Re: UKLPG
Hi Mike,
Thanks, I enjoyed our meeting too, was nice to meet you.
Since our meeting, as you know, I have listed points discussed etc on the forum, I hope you agree I've given a fair representation? I did say that you didn't agree that the MOT scheme was suitable as is and mentioned your point about spreader plates.
In my more recent post I again mentioned my thought that although the MOT system, as is, wouldn't be as thorough as a UKLPG check, where only maybe 1/3rd of vehicles are submitted for a UKLPG check, 100% of vehicles could be submitted for a mandatory MOT check. If we took both situations to the extreme for comparative purposes in the following situations then I believe the MOT check would be better... Those situations might be - Situation 1... An MOT check only checks to make sure the tank cannot flop around in the boot, nothing else, but it does that on 100% of converted vehicles. Situation 2... A UKLPG check closely examines every aspect of the LPG system, but only does that on a couple of converted vehicles per year.
I didn't realise that VOSA didn't want to be involved because they feel it would open them up for claims etc, can't remember you bringing up this specific point during our chat. if I mention this now, then I would need to mention our recent emails etc... I hope you're not offended by my listing points discussed during our chat - I didn't get the impression that you would be at the time, and haven't said anything to make me believe you would be since. Still, I'm a little uneasy quoting points discussed in private emails / face to face etc! Not usually the kind of thing I would do... Would you have anything against joining discussion on the forum, consider this an invite?
Best regards,
Yours,
Simon Andrew
LPG Conversions
www.Lpgc.co.uk
07816237240
From: Mike Chapman <
mike.chapman@uklpg.org>
To: "'
cheapmotoring@yahoo.co.uk'" <
cheapmotoring@yahoo.co.uk>
Cc: "'
info@blazegas.com'" <
info@blazegas.com>
Sent: Tuesday, 14 October 2014, 15:50
Subject: UKLPG
Hi Simon
It was good to have our chat recently and having got back to the office have picked up on your comments on the LPG Discussion Forum
The only thing I would add regarding the MOT, and as mentioned, is that all MOT stations are restricted to assessing components on what they can see and are thus unable to move or lift or remove any items on a vehicle. This would render checks by an MOT station as quite insufficient for checking such things as filler boots, spreader plates etc.
In my discussions with VOSA this restriction on MOT inspectors is sacrosanct to prevent claims on VOSA so without a fundamental change to their way of operating and costs what you are suggesting, whilst on the face of it quite validly, is not something they ate prepared to adopt.
I confirm my / our desire for a legal requirement for proper government checks to replace the Scheme but in its absence we will do the best we can
Regards
Mike Chapman
Autogas Manager
UKLPG, the trade association of the UK LP Gas industry.
mike.chapman@uklpg.org | Visit:
www.uklpg.org.
UKLPG is Registered in England No. 977549.
www.drivelpg.co.uk the independent consumer guide to LPG autogas in the UK