CGRAS performance on operating Gas Safe Register in NI, appointment and public awareness

Response to this request is long overdue. By law, under all circumstances, Health and Safety Executive for Northern Ireland should have responded by now (details). You can complain by requesting an internal review.

Dear Health and Safety Executive for Northern Ireland,

Request under Freedom of Information Act

Below I ask question where HSENI may try to avoid or deflect question such as ask Gas Safe(CGRAS) but as the employer and body that grants the operation of the Gas Safe Register in NI this information needs to be asked through the controlling body of CGRAS that is HSENI.

We would expect all questions to be answered to their fullest ability in line with the Parliamentary Ombudsman guide Principles of Good Administration.

How has HSENI and CGRAS worked together pre takeover and operation of the Gas Safe registstration post 1/4/10 to raise the awareness of the register in NI through practical and robust marketing strategy? Please provide the following to support the Gas Safe brand with NI focused evidence please.

Marketing plan and strategy which was agreed for NI with HSENI
Marketing communications plan which was agreed for NI with HSENI
PR Plan which was agreed for NI with HSENI
Website plan which was agreed for NI with HSENI

Marketing approach to target the following groups in NI
Home owners and 1st time buyers
Tenants and landlords
The elderly and vulnerable
Commercial and businesses

Detail of launch activity Gas Safe brand in
(NI only for the following topics excluding GB)

Details of Press and printed media both (£ expenditure NI) and examples.
Details of Digital banner ads PPC examples of ads and (£ expenditure NI)
Details of social media promoted and boosted ads examples of ads and (£ expenditure)
Approval of plan by HSENI
Radio advertising samples of audio and (£ expenditure NI)
TV advertising samples of video and audio and (£ expenditure NI)
Evidence of achieving service level set out in schedule 3 of contract.

Co awareness at launch of the Contract with CGRAS and ongoing message over last 9 years for the above items?

Details of agreement where HSENI decided to have a different contractual arrangement from GB with CGRAS.

Reasons for not simply implementing the same contract as operated in GB?

Who suggested the different terms, CGRAS or HSENI?

Why did NI need a different contract from GB?

Given that CGRAS charge NI businesses the same as GB and has been alleged that HSENI was to undertake public awareness was it right of CGRAS to still charge NI businesses the full fee for the lesser service whilst the cost of the PR would be borne by tax payer in NI?

Given that work notification for building control, “”, road shows, trade engagement did not happen, doesn’t work in NI why are we charged the same?

Who decided to withhold this information from businesses about the different terms of the contract? HSENI or CGRAS?

Can HSENI please provide why this was withheld as it is not in line with Parliamentary Ombudsman’s document and HSENI own policy of openness and transparency?

Does HSENI have a declaration of interest policy to prevent conflicts for meetings which influence and set policy, award contracts. This would require declaration were employees, their spouses, family members where conflict of interest could occur with personal investments, share holdings or investment plans?
If not why not?

What specific training have those charged with responsibility for the supervision Gas Industry in relation to the following?

Gas Standards and directions issued from Standards Setting Board


Operating procedures of Emergency Service Provider

Where or how does HSENI engage with the coal face Gas Engineers in NI to understand the hazards and problem encountered everyday and to make the industry safer? Please provide details and examples of engagement.

Given clear examples of HSENI ignoring the Standards Setting board guidance on gas safety, placing engineers in impossible positions to execute the duties HSENI say they must execute under the NI gas order would this not be stressful and could lead to mental health issues and be seen as bullying and in conflict with HSENI guidance for mental health?
Has the HSENI declined invites from Phoenix Natural Gas NINGA group for meetings? If so why?

Why when there is a Gas Safety working group of transporters, Council representatives, Consumers Council, Gas Safe are the 2nd largest stake holder in the gas industry after customers excluded, the Gas Safe Registered businesses who work in homes and businesses every day?

How by excluding the coal face trade does this improve safety?

Why are some contractors are invited who are not Gas Transporters? Are some contractors more equal than others and given special status?

How many times have HSENI attended or engaged with the following organisations in event or conferences? Please detail each body below separately.
Ulster Farmers Union
NFU (mutual) NFUM
Young Farmers Club of Ulster

Has the engagement and domination of the HSENI website delivered a significant reduction is serious and fatal accidents in farming in NI?

What are HSENI plans for the next 5 years in their corperate plan as they have not responded in the 28 day period which is one of their own standards?

Can you please provide the following schedules of the HSENI / CGRAS contract for operating the register in NI? HSEGB have provided us a copy of the GB contract so there is no reason HSENI cannot provide the NI version or to claim commercial sensitivity.

Schedule 1: Concession Services
Schedule 2: Additional and Ancillary Services
Schedule 3: Service Levels
Schedule 4: Charges
Schedule 5: Benchmarking
Schedule 6: Change Control Procedure
Schedule 7: HSE Policies
Schedule 9: Staff and Staff Transfer
Schedule 10: Contract Management

Can you please provide the details of CGRAS performance of the contract in NI for the nine years as required in Benchmarking schedule 5?

Can we have copies of minutes of all meetings between CGRAS and HSENI pre appointment and post appointment? If minutes where not recorded why not?

Copies of Minutes of meeting held between HSENI employees including Mr Jim King HSENI employee and HSEGB pre and post contract appointment? If minutes where not recorded why not?

Can we have copies of minutes, notes, correspondence etc taken during consultations with stake holders prior to the appointment of CGRAS? If minutes where not recorded why not?

Which party suggested the removal of the pre registration interview of new operatives prior to placing them on the register, HSENI or CGRAS? If minutes where not recorded why not?

Was HSENI aware of CGRAS policy to rapidly expand the register with a flood the register with poorly trained engineers by the changes proposed simply to maximise profit over safety as the greater number of engineers on the register the greater profit for CGRAS? Did HSENI miss CGRAS possible objective of as priority of maximum profit?

Why at recent hotel events organised by CGRAS where engineers are lectured and then given a written paper in which some described as dimly illuminated and cramped does the correspondence those who attended received indicate that their competence was assessed at their work place rather than at a mass event at a hotel? Is this to make it look like Gas Safe have been doing their auditing and travelling to justify their profit or just manipulation of data which could be an offence under the ICO regulations of incorrect data and a possible form of fraud given its in relation to a public contract.

As NI Gas work is excluded for the website paid from NI licence fees to CGRAS can HSENI provide details for the last 9 years of unsafe gas work in NI by postcode e.g.BT1, BT2 and category of ID and any injuries to fulfil the role of public awareness due to the sub standard contract?

Yours faithfully,

Robert King

DfE HSENI FOI, Health and Safety Executive for Northern Ireland


Dear Mr King,




Reference: FOI/142/2018



I refer to your email dated 22 August 2018 to HSENI in which you pose a
series of questions under the above named act.


I acknowledge receipt of your request.  HSENI is currently working on this
and will be in touch with you once our response is complete.



If you have any queries regarding this email or your request please
contact HSENI by email to [1][HSENI request email] and remember to quote our
reference, FOI/142/2018, on any future correspondence.


Yours sincerely,




Information Management Unit




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DfE HSENI FOI, Health and Safety Executive for Northern Ireland

Dear Mr King,


I refer to 2 separate requests for information received by HSENI through the 'whatdotheyknow' website.

The subject of the requests is 'CGRAS performance on operating Gas Safe Register in NI, appointment and public awareness' and ‘Alleged Carbon Monoxide Incident Portadown 2/8/18’.

Although the requests are from a ‘Mr Robert King’, HSENI has previously been in correspondence with a Mr A King (not Robert) regarding the same topics and I am writing to you to ascertain if Mr Robert King and Mr A King are the same person? Both requestors adopt a very similar style and each email contains numerous separate requests.

On this basis and before we can process your requests, I would ask that you provide confirmation of your identity and of any other names you may have used when corresponding with HSENI.

Until such time as this is provided, HSENI will not progress your requests as it considers the provisions of Section 8(1)(b) of the FOIA 2000 have not been met and as such does not consider this a valid request under the legislation.

Yours faithfully

Liam O’Neill


Robert King is one of my given Christian names on my birth certificate.

It appears HSENI wishes to target individuals to be victimised for highlight their failures.

Yours sincerely,

Robert King

DfE HSENI FOI, Health and Safety Executive for Northern Ireland

Dear Mr King,

Thank you for the information regarding your Christian name.

In order for HSENI to process your request/s can you please advise us of any other names you may have used to correspond with HSENI?

Yours faithfully

Liam O'Neill
Information Manager

83 Ladas Drive
Belfast, BT6 9FR
Tel: 028 9054 7088 (ext: 47088)
[mobile number]
Textphone: 028 9052 9304

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It’s clear you are dragging your feet as usual.

Where do I send a DNA to speed up your response?

I have answered your previous request so now process or don’t and I place it with the ICO and PSNI.

Yours sincerely,

Robert King

O'Neill, Liam, Health and Safety Executive for Northern Ireland

1 Attachment

  • Attachment

    vexatious complaints enquiries unreasonable and abusive behaviour policy....pdf

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Dear Mr King,




I refer to your requests for information under the general topic headings


1.   ‘CGRAS performance on operating Gas Safe Register in NI, appointment
and public awareness’ (received on 22/08/2018);

2.   ‘Alleged Carbon Monoxide Incident Portadown 2/8/18’ (received on
10/09/2018); and

3.   ‘Response to Corporate Plan 2018-2013’ (received on 15/10/2018).


Your combined emails (3) contain 87 separate requests for information and
the requests are a mix of line of business requests and requests under the


Following on from your visit to HSENI offices on 06/12/2018 where you
provided proof of identity and confirmed you have previously corresponded
with HSENI using another name, I am now in a position to respond to your


Taking into consideration the history of your requests (under both names)
I can advise you Section 14(1) of the Freedom of Information Act 2000 does
not oblige a public authority to comply with a request for information if
the request is vexatious. After careful consideration of your request
HSENI considers it to be vexatious and we will not be responding.


I also note the contents of (a) your email of 14 November 2018 in which
you make the reference to the ‘laziness of staff’ in HSENI and (b) your
accusations within your requests of fraudulent behaviour on behalf of
HSENI. These accusations are totally unfounded, unreasonable and deemed to
be vexatious in themselves.


Furthermore, I would refer you to the ICO guidance on vexatious requests
and the identifying conditions which can be applied. The following set of
conditions apply to your requests (in addition to that noted above).


Abusive or aggressive language   The tone or language of the requester’s
correspondence goes beyond the level of criticism that a public authority
or its employees should reasonably expect to receive.


Burden on the authority       The effort required to meet the request will
be so grossly oppressive in terms of the strain on time and resources,
that the authority cannot reasonably be expected to comply, no matter how
legitimate the subject matter or valid the intentions of the requester.


Unreasonable persistence    The requester is attempting to reopen an issue
which has already been comprehensively addressed by the public authority,
or otherwise subjected to some form of independent scrutiny.


Unfounded accusations        The requester makes completely
unsubstantiated accusations against the public authority or specific


Frequent or overlapping requests The requester submits frequent
correspondence about the same issue or sends in new requests before the
public authority has had an opportunity to address their earlier


With regard to your request at item (3) above, I would refer you to the
ICO guidance (copied below for ease of reference) with regard to a
requestor who submits numerous requests. I consider this to clearly
demonstrate the situation with yourself and hence this vexatious condition
also applies.


58. A request which would not normally be regarded as vexatious in
isolation may assume that quality once considered in context. An example
of this would be where an individual is placing a significant strain on an
authority’s resources by submitting a long and frequent series of
requests, and the most recent request, although not obviously vexatious in
itself, is contributing to that aggregated burden.


59. The requester’s past pattern of behaviour may also be a relevant
consideration. For instance, if the authority’s experience of dealing with
his previous requests suggests that he won’t be satisfied with any
response and will submit numerous follow up enquiries no matter what
information is supplied, then this evidence could strengthen any argument
that responding to the current request will impose a disproportionate
burden on the authority.


I can also advise you that some of your requests fall to be considered
against our line of business regime (LOB). HSENI has invoked it’s policy
in relation to “Vexatious complaints, enquiries, unreasonable and abusive
behaviour policy” (copy attached) with regard to those requests which fall
to be answered under this regime and subsequently we will not be
corresponding with you further on this matter.


If you have any queries about this email, please contact me. Please
remember to quote the reference number above in any future communications.


I hope you find this information useful, but if you are dissatisfied with
the way in which HSENI has handled your request, please go to
[1] which explains
the actions that are available to you.


Yours sincerely




Liam O'Neill

Information Manager

83 Ladas Drive
Belfast, BT6 9FR
Tel: 028 9054 7088 (ext: 47088)
[mobile number]
Textphone: 028 9052 9304
Web: [2]
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