--- title: LPG Gas Safety for Holiday Lets and Off-Grid Premises description: An LPG gas safety certificate is only one record. Holiday lets may need landlord and workplace records, plus supplier tank evidence, to prove each duty. source: Duty Room source_url: https://dutyroom.com published_on: '2026-09-24' updated_on: '2026-09-24' market: uk jurisdiction: Gas Safety (Installation and Use) Regulations 1998 duties apply across Great Britain. The carbon monoxide alarm regulations cited are England-only; Scotland's short-term-let licensing carries its own carbon monoxide guest-information duty, and Wales and Northern Ireland have separate rules. The Glenmark Cottage case was prosecuted in Scotland. sectors: - all canonical_url: https://dutyroom.com/uk/briefings/lpg-gas-safety-holiday-accommodation --- # LPG Gas Safety for Holiday Lets and Off-Grid Premises An LPG gas safety certificate is only one record. Holiday lets may need landlord and workplace records, plus supplier tank evidence, to prove each duty. Gas Safety (Installation and Use) Regulations 1998 duties apply across Great Britain. The carbon monoxide alarm regulations cited are England-only; Scotland's short-term-let licensing carries its own carbon monoxide guest-information duty, and Wales and Northern Ireland have separate rules. The Glenmark Cottage case was prosecuted in Scotland. Put a holiday let or a static caravan on LPG and the paperwork gets harder than on mains gas. The same cabinet heater answers to landlord law in a let bedroom, workplace law in the kitchen, and a third regime out at the bulk tank. Which gas record you need depends on which duty applies. ## Why LPG is its own problem The complications start with the gas itself, and with who's allowed to work on it. LPG is heavier than air: a leak pools low and can reach ignition some distance off, which is why bulk storage and cylinders stay out of cellars and pits. Gas Safe registration is category-specific too: an engineer qualified on domestic mains boilers may hold nothing for LPG or the setting, and the relevant categories include commercial catering, "LAV" for leisure accommodation vehicles, and "RPH" for park homes. ## Reg 35, reg 36, or both? The law adds another layer on top of that, and it's just as specific. LPG runs on the same hard law as mains gas: the [Gas Safety (Installation and Use) Regulations 1998](https://www.legislation.gov.uk/uksi/1998/2451/contents). Reg 36, the landlord duty, covers let accommodation and requires an annual gas check and a Landlord Gas Safety Record. HSE treats rented holiday accommodation like a flat, so let cottages, static caravans and narrowboats sit inside reg 36. Reg 35, the workplace duty, covers the gas staff use, the kitchen range and the boiler, and requires they be kept safe. There's no official "gas safety certificate" document: the law sets out what the record needs to contain, not what it has to look like, and "CP12", "CP42" and "CP44" are industry templates from the old CORGI scheme. For a let unit, the reg 36 record is the one the law names. A commercial kitchen's CP42 evidences the reg 35 duty instead; a lapsed one is the sort of gap an [insurer leans on after a fire](https://dutyroom.com/uk/briefings/gas-safety-insurance-cp42). Calling it a "landlord certificate" gets the regime wrong, because reg 36 is residential. ## Who owns the bulk tank, you or the supplier? Reg 35 and reg 36 cover the appliances and the people using them. The tank that feeds those appliances answers to a different regime again. Off-grid sites run on a bulk tank, and the tank is rarely the operator's. [HSE puts it plainly](https://www.hse.gov.uk/gas/lpg/storagetank.htm): "in the vast majority of cases the tank will be owned by the company that supplies the gas", Calor, Flogas or AvantiGas. The vessel is a pressure system under the Pressure Systems Safety Regulations 2000, and where the supplier leases it and agrees in writing to examine it, that duty stays with the supplier. The operator stays responsible for everything around and downstream of the tank: siting, tanker access, security, and the separation distance that keeps the smallest tanks at least 2.5 metres from any building, boundary or ignition source. That responsibility extends to the service pipework running from the tank to the building. [HSE is explicit](https://www.hse.gov.uk/gas/lpg/servicepipework.htm) that the pipe is "most likely to be owned by whoever owns the premises", the landlord where they are let, even when the supplier laid it, and that inspecting and maintaining it falls to that owner, not the supplier. ## Carbon monoxide: the alarm law that misses holiday lets Alarms are covered by a separate set of regulations. The [Smoke and Carbon Monoxide Alarm (England) Regulations 2015](https://www.legislation.gov.uk/uksi/2015/1693/contents), tightened in 2022, require a CO alarm in any room used as living accommodation with a fixed combustion appliance other than a gas cooker, with a £5,000 penalty per breach. But they apply only to a "specified tenancy", a tenant's only or main home, and exclude hotels and vessels, so a week in a cabin or a touring pitch falls outside. Reg 36 still requires the annual appliance check, and many site licences and insurers require CO alarms outright, to BS EN 50291; operators commonly fit them in every unit with a gas appliance regardless. After a death in a Scottish holiday cottage, Scotland's [short-term-let licensing](https://www.legislation.gov.uk/ssi/2024/227/contents/made) now requires hosts to give guests carbon monoxide and gas-heater guidance. A UK [petition to make CO alarms mandatory in all holiday accommodation](https://petition.parliament.uk/petitions/768395) drew its Government response in July 2026, and the response concedes the gap: the 2015 regulations "do not generally apply to holiday accommodation occupied under a licence". No new duty followed, only a commitment to consider one. ## The Glenmark Cottage prosecution That's the gap between what the law requires and what a stay in a cabin actually needs, and it's where the worst outcomes happen. In October 2015, Thomas Hill, 18, was fatally poisoned by carbon monoxide in the bathroom of a let holiday cottage at Glenmark Cottage, Tarfside, in Angus. The source was a flue-less LPG cabinet heater with cracked burner plaques in a bathroom too small to take it; the cottage had no annual gas-safety regime. At Dundee Sheriff Court in 2021, the cottage owner Burghill Farms was fined [£120,000](https://www.copfs.gov.uk/about-copfs/news/holiday-cottage-owner-and-landlord-failed-to-maintain-gas-heaters/) under the Gas Safety Regulations and the Health and Safety at Work Act, and the sub-letting tenant £2,000. In England and Wales a case like this would usually be brought by the council, not the HSE; in Scotland every prosecution runs through the Crown Office. The prosecutors charged the gas-safety failings and said they were not proven to have caused the death; a fatal accident inquiry found it avoidable and caused by the heater. In 2025 a coroner's [Prevention of Future Deaths report](https://www.judiciary.uk/prevention-of-future-death-reports/thomas-hill-prevention-of-future-deaths-report/) went to the Office for Product Safety and Standards over the missing warning that the heater was unsafe for a room that small. The £120,000 turned on the landlord gas-safety duty: the check that was never done, the record that never existed. ## Building the record That missing record is also the easiest thing to put right before it's ever tested. The inspection and the certificate are the engineer's work, and a site's gas safety stays between the operator and their Gas Safe engineer. The record is different: it lapses between visits, covering which appliance is in which unit, the Gas Safe number that signed it off, the next due date, the alarm locations. Duty Room keeps [that record straight, organised per site, unit by unit](https://dutyroom.com/uk/gas-safety). --- Published by [Duty Room](https://dutyroom.com/uk/), software for organizing, tracking, and evidencing operational compliance.