Gas safety before the heating season, and the two month window

Most heating systems in the country will be running again within six weeks. Before that happens, every relevant property needs a gas safety check that is in date, and the useful thing about September is that you can bring a lot of them forward without paying for it in lost time.

Under regulation 36 of the Gas Safety (Installation and Use) Regulations 1998, a landlord has to have every gas appliance, flue and associated pipework in a rented property checked by a Gas Safe registered engineer at least once every twelve months. That much is well known. The part that gets used less than it should is regulation 36A.

The two month window

Since the Gas Safety (Installation and Use) (Amendment) Regulations 2018, a landlord can carry out the annual check up to two months before it is due and keep the original deadline date, exactly as though it had been done on the twelve month anniversary (HSE). It works the way an MOT does. Nothing is lost by going early.

That single provision is what makes a September sweep worth planning. Anything falling due in September, October or November can be done now, in one visit pattern, with one contractor, before the first cold week produces a queue of no-heating calls and an engineer who cannot get to you.

The trade off is on the record keeping rather than the dates. A gas safety record has to be kept for two years, but where the early check flexibility has been used, the record needs to be kept until two further checks have been carried out. Worth setting up once rather than discovering later.

What the record has to do

The check is only half the duty. The record has to reach people:

A copy to each existing tenant within 28 days of the check being completed.

A copy to any new tenant before they move in.

The record itself retained for at least two years, longer where regulation 36A has been used.

None of this is difficult. It goes wrong at scale, across a portfolio, when the certificate lives in an engineer's email, the expiry date lives in a spreadsheet somebody left, and the proof that a tenant received their copy lives nowhere at all. The enforcement question is rarely whether the check happened. It is whether you can show it happened, when, and that the tenant was given the record.

The alarm that goes with it

The Smoke and Carbon Monoxide Alarm (Amendment) Regulations 2022 came into force on 1 October 2022 and sit alongside the gas duty. A carbon monoxide alarm has to be provided in any room used as living accommodation that contains a fixed combustion appliance, excluding gas cookers, and a smoke alarm on every storey with a room used as living accommodation. The alarms have to be in working order at the start of a tenancy, and repaired or replaced once a fault is reported.

A fixed combustion appliance is anything with fuel burning in it, so the duty reaches beyond gas. Oil boilers count. Log burners count, and they are increasingly common in the sort of period conversion that never had one when the tenancy started.

The reason to take it seriously is small in number and severe in kind. HSE puts it at around seven deaths a year from carbon monoxide poisoning caused by gas appliances and flues that were not properly installed, not maintained, or poorly ventilated (Health and Safety Executive). A one off event that a working alarm and an in date check would very likely have prevented.

Doing it as a portfolio rather than a property

A single property is a diary entry. Thirty properties is a system, and the failures are always the same three:

The expiry dates are not in one place, so nobody sees the cluster forming in November until it forms.

The certificate and the appliance are stored separately, so a boiler replaced in March leaves an old record attached to a property that no longer matches it.

The evidence that a tenant received their copy is a sent email nobody can find.

What actually helps is treating the LGSR as a dated record attached to a specific appliance in a specific building, with the next due date derived from it rather than typed in somewhere else. Then the November cluster is visible in September, which is the only month it is cheap to fix.

Where SAMRISK puts it

SAMRISK holds the building and the land it sits on across thirty connected systems, twenty for the building and ten for the land. Gas safety records sit in the compliance calendar the same way the EICR, the FRA and the LOLER inspection do, with the certificate attached to the asset and the expiry driving the next task rather than an entry in a separate spreadsheet.

The point is not the certificate. It is that in February, when somebody asks, the answer is a date, a document and an engineer's registration number rather than a search through an inbox.

Heating goes on in a few weeks. The window to get in front of it is open now, and it closes when everyone else notices.