Renting Homes (Wales) Act update: where should carbon monoxide alarms be positioned?
If you’re a landlord in Wales, you should know that since The Renting Homes (Fitness for Human Habitation) (Wales) Regulations 2022 came into force on 1st December 2022, it’s been a legal requirement to have a carbon monoxide (CO) alarm in any room with a gas, oil-fired combustion or a solid fuel burning combustion appliance.
The most commonly-asked question we’ve had from landlords is “Does this include rooms with a gas boiler?”, and the answer is: “Yes, all gas boilers.”
The second most commonly-asked question is “Where should the alarm be positioned?”. To answer this, we need to look beyond the Regulations, as they only goes as far as defining what a room is, rather than where in the room the alarm should be placed. In case you’re wondering, the Regulations say a room “includes a hall, landing or corridor”.
Guidance and a British Standard
Welsh Government guidance says that positioning CO alarms on the ceiling “is not necessarily the best place to install carbon monoxide detectors” as “concentration of carbon monoxide could reach dangerous levels before reaching ceiling height”. However, a recently-released British Standard (BS EN 50292:2023) says ceiling-mounting and wall-mounting are equally as allowed: though we'd strongly recommend reading the instructions that come with the alarm purchased in order to determine if that particular product can only be ceiling or wall-mounted.
We consulted a leading manufacturer in CO alarms, who said Welsh Gov’s advice “is not in line with guidance of the product standard” and “as an industry, we have advised them that the information on their website is incorrect”.
The British Standard provides further installation advice (wall-mounted alarms must be above windows and doors, for example) and a list of locations that are unsuitable for the installation of a CO alarm. These locations include enclosed spaces (cupboards, for example) or damp/humid locations, but there are exceptions to this.
What if you have a fuel burning appliance in a damp/humid location, like a bathroom?
This is a question that has reared its head once or twice already. A quick look online says that humid rooms can cause CO alarms to falsely sound, suggesting they are not a suitable location. However, installing them anywhere else would seemingly be a breach of The Renting Homes (Fitness for Human Habitation) (Wales) Regulations 2022, so what is a landlord to do?
The aforementioned British Standard states that CO alarms can be sited in bathrooms if the manufacturer advises their product is suitable for it and has a test button, so in order to comply with the Regulations, landlords should buy an alarm suitable for humid conditions. We do not believe the powers-that-be will deem it acceptable for an alarm to be positioned outside of a humid room when there are products available to fit the purpose.
As an example, Aico’s Ei208 product says it can be “installed in a bathroom, but do not place the detector directly above a sink, shower or bath where it will be subject to splashing water and a high level of condensation”.
What if your fuel burning appliance is located inside a cupboard?
This scenario has also come up a few times. As long as it complies with the British Standard's rules regarding placement – one of which being that it must be at least 1m away from the appliance (horizontally) – it can be cited in the cupboard.
Share the burden of the new legislation and benefit from the peace of mind we provide
With enactment of The Renting Homes (Wales) Act still less than nine-months-old, elements of it are only now being tried and tested. On an almost-weekly basis, we’re unravelling the complexities of the legislation when the practicalities of abiding by it are put into practice, which is throwing up many questions that – on the face of it – are difficult to answer.
Between the Act, its Regulations, Welsh Government guidance, British Standards and more, it’s a minefield. So much so, more and more landlords are choosing to instruct CPS Homes to navigate the choppy waters and provide the peace of mind they crave, as we are prepared to seek answers on the most effective and efficient route to compliance from the powers-that-be.
Call 02920 668585 or email nikki.lewis@cpshomes.co.uk and instruct CPS Homes to manage your property today. Free management terms are available where your current agent may charge you for exiting your contract with them.
