HETAS Approved Biomass Maintenance Scheme (HABMS) consultation update
Following the HETAS Approved Biomass Maintenance Scheme (HABMS) Working Group’s feedback of a consultation held in April, HETAS has been working to review how competency is both defined and demonstrated, and what additional assessments are necessary – especially for HETAS Approved Biomass Maintenance Scheme (HABMS) registrants maintaining large or complex biomass boiler systems.
The consultation and further feedback have presented a number of next steps for the evolution of, competencies, MCS 040, and the HABMS, positioned to ensure businesses working on complex systems have the skills, experience, and knowledge to complete the maintenance work in addition to the competency.
Maintenance Standard MCS 040 deals specifically with planned preventative maintenance, and whilst an individual’s skills, knowledge, and experience are key to understanding the working, efficiency, and safety principles of a system, certain elements could be deemed as system maintenance, which can require further knowledge – and sometimes additional, specific qualifications.
Key findings
Several core themes arose from the consultation and further feedback:
- Defining criteria for what constitutes a ‘complex’ biomass boiler installation, making the scope go beyond boiler output.
- Determining if existing frameworks are sufficient for managing complex and large systems, and if supplementary measures would be practical and actionable.
- Understanding how to ensure operatives or businesses have the correct mix of skills, knowledge, experience, and behaviours to evidence their competence to undertake maintenance work on complex boilers.
- Ensuring no additional barriers are created through increased compliance for non-domestic RHI participants seeking competent operatives.
There was a consistent pattern throughout the responses we received: frameworks that grant competence are sufficient for certain generalist criteria, but for more complex and specialist systems there is a lack of uniformity, due to access to training and generic updates from some manufacturers – particularly in discontinued systems.
Criteria for complex installations
HETAS and the Working Group have developed an initial set of criteria to define complex biomass systems, increasing the scope to more than just large boilers (over 1000kW) – this criteria includes, but is not limited to:
| Bespoke boilers | Boilers (regardless of size) custom-designed and built to meet the specific heating requirements of a commercial or industrial property or process. |
| Complex fuel feed systems | A bespoke or specialized handling and feeding equipment to ensure a consistent and controlled supply of fuel, and that can require additional safety practice (i.e wood dust). |
| Complex or site-specific control systems | Boilers where the control systems are specialised (or bespoke) and locked to achieve manufacturer combustion parameters. |
| Limited or no manufacturer support (where original ‘like-for-like’ parts are not available) | Where the boiler manufacturer is no longer in existence or is no longer supported in the UK, with very limited access to original replacement parts. |
| Hazardous classifications | Biomass boilers that present a higher risk due to either; fuel type/supply (e.g wood dust) or hydronic system (e.g high pressure steam) and/or boilers that require evidence of Compliance with specific legislation (DSEAR, ATEX, Hazardous Area Classification) – this includes those where confined or restricted access and egress is required. |
| Ongoing issues with emissions or operational performance | |
| Complex hydraulic distribution, including: a) high pressure/temperature air/water/steam b) interconnected/network or bespoke system | a) Items classified under PSSR (Pressure Systems Safety Regulations). b) Suitable evidence of competence required. |
| Interconnected/linked system with bespoke or site-specific control systems: a) Cascaded or multi technology b) Integration-limiting maintenance | a) Cascaded (multiple) biomass boilers which have bespoke control systems or those combining different technologies, integrating biomass with other energy sources / combustion appliances. b) Biomass systems where integration limits maintenance – cannot be safely isolated e.g. boilers that provide critical primary or back-up systems. |
| Any Combined Heat & Power (CHP) System | Any biomass boiler that generates both heat and electricity from a single (woody) biomass fuel source. |
This criteria helps clarify some instances where enhanced competence requirements are required and can be built upon through further feedback.
Generalised and specialist criteria
It has also been recognised that the competency requirements – universally made up of skills, knowledge, behaviours, and experience vary across generalised and specialist engineers.
Stronger competency without barriers
An essential requirement of any of this criteria that was also identified was the need to not impose barriers that would affect non-domestic RHI participants’ access to suitably competent engineers to maintain their boilers.
Implementing a competency framework (where none has previously existed) is challenging, and it is important that we consider the feedback that accessing further formal qualifications and training for complex systems can be difficult. Progression must also not inhibit existing systems from being maintained and create a lack of skilled operatives from being able to maintain them.
Further actions and next steps
Following this consultation, representatives from HETAS will:
- Meet with manufacturers to discuss future actions and how the criteria can be developed.
- Continue their work with the HABMS Working Group, assessing the most robust and practical improvements to competency.
- Undertake a gap analysis of current training and experience across operatives, utilising the experience of the Training and Compliance teams to identify where improvements and clarifications are needed.
Greater emphasis on case-by-case, system-specific risk assessments will be used to complement competency, ensuring the comprehensive and compliant maintenance of complex biomass boiler systems.
The HETAS Approved Biomass Maintenance Scheme will continue to assess an operative’s competency and will subsequently include a review of businesses/engineers completing their own risk assessment when working on complex systems (any of those that fall within the criteria listed above). This will allow operatives to ensure compliance and work with systems with which they have the capabilities to work with.
In assessing these challenges and working with you, we are hoping to appropriately feed into a revision of MCS 040. By placing emphasis on the need for a risk assessment on specific, complex cases, an individual’s skills, experience, and qualifications to work on a boiler can be assessed. Amending Appendix A – the Example Service Report Checklist – to include this will allow HETAS to monitor its implementation, noting the successes and additional requirements it brings.
We are looking to shape a competency that is practical and safe, whilst not inhibiting any of your clients. If you have any additional feedback or wish to join the group, please get in touch – your opinion matters to us.
