if it provides for a safe installation then why wouldn't it be?

just to clarify please see below.................read from the bottom up, its an email stream between the ESS and the building minister









Dear Mr Williamson,

 

I am yet to receive a reply to my open letter sent some weeks ago to your office, I appreciate that you are a very busy person and would like to take the opportunity to add to that open letter the following.

 

Please see below correspondence between ESS and my self concerning the use of a British Standard as an alternative to the NON MANITORY part two of our NZ standard. It is of note that in light of all I have been accused of and what I have told you what has happened to me, acceptance of this would leave me 100% and totally innocent of any wrong doing what so ever. Baring all this in mind - a supposedly un-attached to the Board, Government Dept won’t give me an answer to two very easy and transparent questions. Is this fair? Also of note is that the only other Certifying/Craftsman Gasfitter present at my hearing was British. Is this fair?

 

Do you believe that NZ tradesman are given a level playing field? I don’t believe we are. It is more a kin to a minefield, presided over by the people who plant the mines and make a business out of forcing the tradesman to run the gauntlet of their minefield.

 

I have a question, if it happens again, who will they try to pin it on? I had warned about all this for 6 years before the explosion, and was ignored and then made a scape goat. With such a body of evidence that I have this won’t happen again to my family.

 

I am warning again, this man’s legacy is still out there, covered by dodgy paperwork, practices and workmanship. It is totally incomprehensible that it appears people are prepared to gamble with this man’s incompetence and flippant attitude to safe work.

 

Please Mr Williamson, God forbid if this happens again and nothing has been done to investigate my warnings then those responsible will have blood on their hands, we need a public inquiry ASAP. A fair and transparent one not funded and organised by the Board or their cronies.

 

I have publically accused the Board of corruption and they have done nothing, what does that say to you about them? You have previously written to me stating that you have no problem with industry groups being on industry Boards, I ask you to reconsider this in light of my recent letters. Do you still have confidence in this Board?

 

 

Yours Sincerely Paul Gee.

 

 

 

 


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From: Paul & Emma Gee [mailto:gasnsolarservices@gmail.com]
Sent: Tuesday, 18 September 2012 7:51 p.m.
To: 'Wal Gordon'
Subject: Letter to the editor

 

Letter to the editor,

 

If we have a level playing field with transparency where open and honest opinions are shared to allow you to carry out your work, why can’t I get an answer from ESS about the use of an alternative to the NON MANDATORY part two of the NZ standard, please see below correspondence. Would it mean that there is a connection between the Board and ESS?

 

 


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From: Paul & Emma Gee [mailto:gasnsolarservices@gmail.com]
Sent: Saturday, 15 September 2012 7:52 a.m.
To: 'Paul Stannard'
Subject: FW: Enquiry about use of alternative standard

 

 

Hi Paul,

 

It is only fair to inform you that I have passed my situation on to the ombudsman’s office, the Prime Minister, anti corruption advocates and the Shadow Attorney General and this will be followed up with a formal complaint and hopefully public inquiry, please in light of this can you please pass comment on my emails.

 

Thank you Paul.


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From: Paul & Emma Gee [mailto:gasnsolarservices@gmail.com]
Sent: Sunday, 9 September 2012 2:28 p.m.
To: 'Paul Stannard'
Subject: FW: Enquiry about use of alternative standard

 

 

Hi Paul,

 

Please can I get a ruling on this email below.

 

Thank you Paul Gee

 


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From: Paul & Emma Gee [mailto:gasnsolarservices@gmail.com]
Sent: Tuesday, 21 August 2012 1:25 p.m.
To: 'Paul Stannard'
Subject: RE: Enquiry about use of alternative standard

 

Dear Paul,

 

Thank you for you email I would ask that you could clarify for me a few things.

 

In reply to your comment,

 

This is unusual because the assessment of what standards are used for particular work should be done with the planning and design for that work and should have been decided upon at that time.

 

I did decide at the time of the install what information/standards to base installing the califont below an opening window, I decided using two reference documents as an alternative to the non mandatory part two of NZ 5261-

 

The British Standard that previously I sent just excerpts from, but I now attach in full.
 

&

 

The Rinnai document and the research mentioned within it.
 

I believe, both then and now, that these two documents reaffirm each other and ensure a safe application and site choice for the califont. I based my positioning of the califont, in relation to the opening window, in excess of recommended minimum limits of both documents, the British Standard measurement of 300mm and the Rinnai one of 500mm, placing the califont 540mm below an opening window.

 

The performance was also borne out by the occupier, that stated at no point in 6 years did any flue gases come back into the room, which would mean Part One of NZ 5261 was further proven to have been adhered to. By date this British Standard was and is relevant and is still in use today. So it is very much a proven and tested document, for over 12 years, by over 65 million people, in one of the biggest countries that uses gas, by a per capita measurement, in the world. This is with out any apparent ill effects in a country with similar weather and building design/style. The main difference between NZ and the UK is that Britain has a much denser, cheek by jowl, population which would emphasise any problems concerning clearances of an insufficient nature.

 

I have also since talked to a Dutch gas engineer, a very well thought of and very prominent in the NZ gas industry, who said there has also since some research been done in Holland that showed that the flue gases were pushed away from the building, even without the use of a fan. This was due to the aerodynamics in relation to the mass of the house and density of the fumes and any subsequent extra wind would then dilute the gases further. I note this is after the fact and only mention it in passing.

 

In reference to your comment-

 

It is unclear what status could have been attributed to the extracts headed ‘Additional provisions for gas burning appliances with rated output up to 70 kW (net)’ because they are not identified. I note that on their own they would not provide sufficient information for the design of a gas installation. 

I apologise for any confusion in my sending you incomplete extracts only, and not the full document. I have now attached the document in full FYI and hope this helps. I believe the “additional provisions” are explained when you read these extracts from the British Standard in context. This document is authorised by the Office of the Deputy Prime Minister of the UK and I would have thought that they were qualified to issue this document and would have done more than enough ground work and research in producing this document, I believe its application is safe and that the British Standard is a quality mark recognised around the world.

In reference to your comment-

 

The installation would not have been able to rely on the supplement to CSA-B149.1-05 Natural gas and propane installation code. Even though NZS 5261 refers to the 2000 version of the CSA Code, this supplement was published in January 2007.

Am I to believe that even though a document is referenced in our NZ 5261, I can’t reference it because it isn’t “published”? Why do we have documents referenced by NZ 5261 that are not “published”, which then prevents them from being used? I find this confusing because you then quote a section of NZ 5261 that states-

(a) that particular performance requirement is fully satisfied by 1 or more standards listed in Part 3 of NZS 5261; and

(b) the person complies with at least 1 of those standards.

This Canadian standard is listed within Part 3; I find this all very confusing.

 

Please Paul can you explain-

 

1.       Now that you are in possession of a full copy, can I use this British Standard, the one attached? Could I use it then, in 2006, and in the future? Please could I ask for a yes or no answer.

 

2.       If I can not use it, then please could you let me know why you feel this British Standard may not be of a sufficiently high standard and not well researched enough to be deemed safe? Can you let me know what you think are the potential short comings of its application and why?

 

I feel these are fair and transparent questions.

Thank you in advance for time.

Yours Sincerely Paul Gee.

 

 

 

 

 

 


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From: Paul Stannard [mailto:Paul.Stannard@med.govt.nz]
Sent: Wednesday, 8 August 2012 4:00 p.m.
To: Paul & Emma Gee
Subject: RE: Enquiry about use of alternative standard

 

Dear Paul

I refer to your further query of 29 July 2012 about the use of standards as alternatives to NZS 5261 Gas installation.

You advised that the appliance in question was installed in 2006. This is unusual because the assessment of what standards are used for particular work should be done with the planning and design for that work and should have been decided upon at that time.

In 2006 the relevant regulations were the Gas Regulations 1993 (‘the Regulations’). I include below the text of the relevant regulation 12 which, at that time, required gas installations to meet the essential safety requirements of Part 1 of NZS 5261: 2003 Gas installation.

The regulations deemed Parts 2 and 3 of NZS 5261 to be means of compliance with the mandatory requirements in Part 1 of that standard. This provided for the flexibility you claim is lacking as it provided for the acceptability of other standards that could be demonstrated to meet Part 1 of NZS 5261.

It is Energy Safety’s view that the assessment of any alternative to Part 2 would have had to be made, and documented, before commencement of the work. 

I make the following comments with regard to the documents you provided: 

·         It is unclear what status could have been attributed to the extracts headed ‘Additional provisions for gas burning appliances with rated output up to 70 kW (net)’ because they are not identified. I note that on their own they would not provide sufficient information for the design of a gas installation. 

·         The installation would not have been able to rely on the supplement to CSA-B149.1-05 Natural gas and propane installation code. Even though NZS 5261 refers to the 2000 version of the CSA Code, this supplement was published in January 2007.

·         When designing an installation, the installer should use documentation or written advice from the supplier related to that particular appliance. The relevance of documentation related to the suitability of another model, let alone make of appliance, is questionable at best. 

Regulation 12: 

12 Safety of gas installations

(1) Every person who installs a gas installation or a part of a gas installation must install that gas installation or part in accordance with Part 1 of NZS 5261.

(2) Subclause (3) applies to the following types of installation:—

(a) the installation of a gas installation that does not contain appliance with a rated input of more than 250 MJ/h:

(b) the installation of a part of a gas installation if the gas installation as a whole does not contain any gas appliance with a rated input of more than 250 MJ/h.

(3) Every person is deemed to have complied with subclause (1), in relation to an installation to which this subclause applies, if the person has complied with Part 2 of NZS 5261.

(4) Subclause (5) applies to the following types of installation:

(a) the installation of a gas installation that contains a gas appliance with a rated input of 250 MJ/h or more:

(b) the installation of a part of a gas installation if the gas installation as a whole contains a gas appliance with a rated input of 250 MJ/h or more.

(5) Every person is deemed to have complied with subclause (1), in relation to the application of a particular performance requirement of Part 1 of NZS 5261 to an installation to which this subclause applies, if—

(a) that particular performance requirement is fully satisfied by 1 or more standards listed in Part 3 of NZS 5261; and

(b) the person complies with at least 1 of those standards.

(6) This regulation does not apply to CNG stations.

Regulation 12: substituted, on 1 June 1998, by regulation 4 of the Gas Amendment Regulations 1998 (SR 1998/78).

Subclause (1): amended, on 17 October 2002, by regulation 10 of the Gas Amendment Regulations 2002 (SR 2002/271).

Regulation 12: substituted, on 2 September 2004, by regulation 8 of the Gas Amendment Regulations 2004 (SR 2004/229).

Regards,

Paul Stannard | Technical Officer |  Energy Safety 
Ministry of Business, Innovation & Employment
PO Box 1473, Wellington 6140, New Zealand
Free Phone 0508 ESS INFO (377463) | DDI +64 4 460 8565 | Fax +64 4 460 1365

Visit our website:  www.energysafety.govt.nz

Subscribe to the Energy Safety Business Update for our free newsletter

 

From: Paul & Emma Gee [mailto:gasnsolarservices@gmail.com]
Sent: Sunday, 29 July 2012 2:58 p.m.
To: Paul Stannard
Subject: RE: Enquiry about use of alternative standard

 

Hi Paul,

 

Thank you for your prompt reply and sound advice but I think I may have not explained myself properly. The job in question is an historic one; a Bosch 25e 200MJ or 55 kw installed 540mm below an opening window. Installed in 2006, so the attached 2000 British Standard would be more relevant by date. Also the occupier of the house has had no problems with the install.

 

I had also used the attached Rinnai documents which were given to me by an ex boss who was a Craftsman Gasfitter and member of NZ institute of Gas Engineers, I note it is for a Rinnai one of the biggest califont producers in NZ, but the design if not identical is very similar for all fan forced flued califonts (i.e.  Bosch, Rinnai, Rheems and Paloma to name but four) and the performance of their flue gasses are identical, i.e. forced away from the building at 90 degrees some 3 to 4 Meters. Also NZ5261 does not differentiate between the make, it is based on just MJ ratings. These attached Rinnai documents are for units much larger in MJ rating and recessed in a box, making them nearer than surface mounted unit, which the job in question is, to a window above allowing a minimum of 500mm.

 

The rigidity of the clearances for a flue terminal in relation to an opening window within 5261 is undermined by the attached Canadian Standard, which is stated in NZ 5261 in part 3 as being a standard that if adhered to means you have complied, on page 121 of NZ 5261 , and is also produced in 2000. It states in 8.14.8 that (iii) 3 ft (900 mm) for inputs exceeding 100 000 Btuh (30 kW); please note that there is no upper limit for mega joule rating or whether it is fan driven, which 5261 does and allows much smaller distances for fan forced flues. This would allow a gravity type flue 900mm below an opening window with the fumes behaving like cigarette smoke drifting upwards where as the appliance in question would eject to fumes some 3 or 4 metres away perpendicular to the dwelling, where they would be diluted before potentially returning to any opening in to the building.

 

Also Table 16 in 5261 allows for an “active” mechanical inlet, mentioning specifically a spa blower, 500mm nearer than a “passive” open window. This is confusing because it would place the fumes directly below the occupier of the spa, with them masked by the steam, in one of the smallest rooms in the house, which is also not allowed for. So we have a situation where a very powerful fan sucking air into a building is allowed 500mm nearer than a window that is just open, with no vacuum behind it.

 

The attached British document is the one I would like you to pass judgment on its use, specifically clearances from opening windows for fan forced flues, which allows for 300mm, nearly half the 540mm on site. I also bring to your attention the reports mentioned in the Rinnai letter and ask you to view in light of this and that is from an Australian Gas Authority.

 

Also of note the clearances for table 16 were amended in May 05, specifically for clearances to opening windows, all be it for horizontal measurements.

 

There are other numerous references to other British Standards and would have thought if these were ok then this one would be too, British Standards are recognised around the world and as a mark of quality and safety.

 

This British Standard is still used by over 65 million people who live, in some areas, in much denser numbers very close together. The weather is very much the same as NZ and gas has a much larger per capita use by a far greater population of the UK. The houses are built in a western style very similar to NZ, the biggest difference being that we have much more space here in NZ.

 

Basically what I am asking is can I apply the 300mm clearance mentioned in the British Standard to site a 200mj califont 540mm below an opening window?

 

Thank you for your consideration. Yours Sincerely Paul Gee.

 


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From: Paul Stannard [mailto:Paul.Stannard@med.govt.nz]
Sent: Tuesday, 3 July 2012 4:42 p.m.
To: gspservices@xtra.co.nz
Subject: Enquiry about use of alternative standard

 

Dear Mr Gee

Thank you for your email of 29 June 2012. You have written saying that you have an installation where the clearances do not comply with the means of compliance of NZS 5261 and you have asked us whether you can use, as an alternative, an unspecified British Standard that is over 12 years old.

I should first point out that the installation standard specified in the Gas (Safety & Measurement) Regulations 2010 is now AS/NZS 5601.1: Gas Installations: Part 1 General installations: 2010. While transitional regulations allow NZS 5261 to be used until 31 December 2012, the standard AS/NZS 5601 is the preferred option.

AS/NZS 5601 has a similar structure to NZ 5261. Section 2 of the standard contains the mandatory essential safety requirements while sections 3 onward give the means of compliance. A significant difference to 5261 is the wording of section 2.1 which states:

Where gas installations are designed to the performance requirements of this Section, rather than by using the means of compliance under Sections 3 to 6, the level of safety, convenience and efficiency of operation shall be not less than an installation carried out according to Sections 3 to 6. Such designs shall be documented and kept for 7 years.

If you install an installation that meets the recognised means of compliance then you are deemed to meet the requirements of the regulations. If you go down the essential safety path then you carry a far greater liability. The means of compliance sections should be considered as the collective wisdom of the NZ and Australian gas industries and if you install something that is not in compliance with that then you should be able to fully document why you think it achieves the same levels of safety regardless of whether the proposed solution is in a British standard.

You would have to verify whether the 2000 version of this unspecified standard is still current and is used, whether there are other aspects of this standard that might influence the particular part you wish to use, and whether this standard is applicable to the types of building construction used in New Zealand. You may also need to take manufacturer’s relevant instructions for installation of the appliance and the power flue into account.

Regards,

Paul Stannard | Technical Officer |  Energy Safety 
Ministry of Business, Innovation & Employment
PO Box 1473, Wellington 6140, New Zealand
Free Phone 0508 ESS INFO (377463) | DDI +64 4 460 8565 | Fax +64 4 460 1365

Visit our website:  www.energysafety.govt.nz

it is between "ME" and the ESS and the building minister, sorry for any confusion

hi guys, what about `acceptable solutions`does that not apply to gasfitting,cheers

ah true Thunderhead

sorry badger where does it state that part 2 is a non mandatory part of the code?...i am unable to find it. cheers
But looking at the wording you a correct as it states that "Part 2 provides A means of compliance .....and not THE means of compliance so if you can prove that what you have done complies with part 1 then all should be good.

Part one, contains the mandatory performance criteria for the design, which is proven by the 65 million people in the UK who have used it since 2000, and still use it.... in a population with a much higher per capita use of gas and in much more tightly packed population, with a similar house design, in a country with about 20 times the population of NZ.

Part one is the only mandatory part of the standard... the other parts are a way of complying, it actually states a few times in the NZ 5261 that these parts 2 and 3 are not the only way to do it.

Just asking for a yes or no answer....is it safe or not? its a fair question

Bowtie, this is the only thing they have on me after 3 years persecutiuon....and it is bollox