Champagauri and Dipak Bhatt
PFD Report
All Responded
Ref: 2024-0677
All 8 responses received
· Deadline: 31 Jan 2025
Coroner's Concerns (AI summary)
Fires are caused by moisture ingress into condensate pumps. There's inadequate data sharing and analysis for white goods fires, poor manufacturing standards for components, and inconsistent risk assessment methodology.
View full coroner's concerns
During the inquest a London Fire Brigade witness made suggestions for more effective data sharing and use and It was apparent future deaths may occur unless action is taken.
(1) That ingress of moisture into condensate pumps may result in tracking faults causing resistive heating and fire.
(2) That changes in information management would result in better analysis of, and learning from, white goods fires.
(3) Manufacturers to give the and Office of Product Safety Standards (OPSS) as the regulator and London Fire Brigade (LFB) to support their fire prevention work data on parts replaced on warrantyee for condensate pumps and RFI filters.
(4) Working group CPL / 61 look at standards of manufacture of mains and sub mains operated condensate pumps and RFI filters, to improve standards.
(5) Manufacturers to share data on decisions and rationale behind recall / replacement of condense pumps and RFI filters Office of Product Safety Standards (OPSS) as the regulator and London Fire Brigade to support their fire prevention work.
(6) Companies investigating fires to notify Trading Standards and the Office of Product Safety Standards (OPSS) of the outcome of those investigations.
(7) Manufacturers to be required to use the OPSS risk assessment methodology, PRISM, when conducting risk assessments to account for persons in a property and their actions, i.e. sleeping whilst a product is taking advantage of lower electricity rates.
(8) Identification plates on appliances that will not be destroyed by fire akin to those on vehicles.
(1) That ingress of moisture into condensate pumps may result in tracking faults causing resistive heating and fire.
(2) That changes in information management would result in better analysis of, and learning from, white goods fires.
(3) Manufacturers to give the and Office of Product Safety Standards (OPSS) as the regulator and London Fire Brigade (LFB) to support their fire prevention work data on parts replaced on warrantyee for condensate pumps and RFI filters.
(4) Working group CPL / 61 look at standards of manufacture of mains and sub mains operated condensate pumps and RFI filters, to improve standards.
(5) Manufacturers to share data on decisions and rationale behind recall / replacement of condense pumps and RFI filters Office of Product Safety Standards (OPSS) as the regulator and London Fire Brigade to support their fire prevention work.
(6) Companies investigating fires to notify Trading Standards and the Office of Product Safety Standards (OPSS) of the outcome of those investigations.
(7) Manufacturers to be required to use the OPSS risk assessment methodology, PRISM, when conducting risk assessments to account for persons in a property and their actions, i.e. sleeping whilst a product is taking advantage of lower electricity rates.
(8) Identification plates on appliances that will not be destroyed by fire akin to those on vehicles.
Responses
Action Planned
Hotpoint states it will support the LFB/AMDEA initiative of digital identification and comply with any future industry-wide regulatory requirements. It will also work with government policy makers, regulators, fire services, manufacturers and other stakeholders to continue to raise the bar for appliance product safety in the UK. (AI summary)
Hotpoint states it will support the LFB/AMDEA initiative of digital identification and comply with any future industry-wide regulatory requirements. It will also work with government policy makers, regulators, fire services, manufacturers and other stakeholders to continue to raise the bar for appliance product safety in the UK. (AI summary)
View full response
Hotpoint UK Appliances Ltd. Morley Way Peterborough PE2 9JB Registered in London 106725 VAT No 513936740 HOTPOINT UK APPLIANCES LIMITED’S RESPONSE TO REGULATION 28 REPORT TO PREVENT FUTURE DEATHS DATED 6 DECEMBER 2024 This is the response of Hotpoint UK Appliances Limited (Hotpoint) to the Regulation28Reportto Prevent Future Deaths arising out of the Inquest into the deaths of Champaguri Bhatt and Dipak Bhatt. BeforeweaddresstheAssistantCoroner’sreportwewouldliketoexpressourdeepestcondolences to the Bhatt family and anyone affected by this tragedy. The matters of concern raised by the Assistant Coroner relate to industry-wide challenges. The response to those concerns should be considered in light ofthebroaderregulatoryframeworkthat underpins product safety in the UK together with an ongoing revision by the Government. Current Product Safety Legal Framework The UK hasacomprehensiveframeworkoflawscoveringproductsafety,derivedprimarilyfromEU law.TheoverarchinglegislationistheGeneralProductSafetyRegulation2005(“GPSR”),whichsets outgeneralsafetyrulesthatapplytoallproductsunlessthoseproductsaresubjecttosectorspecific legislation. In the case of electrical appliances, the applicable sector-specific legislation is the Electrical Equipment (Safety) Regulation 2016 (“EESR”). These product safety laws set out objectives and rules governing the safety of products. The underlyingtechnicalrulesthatensuretheseobjectivesaremetarecontainedintechnicalstandards. Designated Standards1 are technical standards, often based on international standards, that are officiallyrecognisedbytheGovernment.Thestandardssetoutaseriesoftechnicalrequirementsthat mustbemetinorderfortheproducttobedeclaredcompliant.Thesafetyofaproductthatcomplies with a technical standard is presumed. Designated Standards are written by a committee of technical experts including manufacturers, independentaccreditedtesthouses,enforcementauthoritiesandothersand,intheUK,publishedby the British Standards Institute. They are often subject to revision as newrisksarediscoveredover time.Thatprocessensuresthatthoroughtestingcanbeconductedbyindependenttechnicalexperts to determine whether any risk exists, and ifso,whetheritisappropriateinallthecircumstancesto revise the technical standards to address that risk. Additionally, the Governmentisabletodevelop additionalstandardswheretheyfeelappropriateandthereareexamplesinrecenttimeswhereOPSS has done exactly that. Weviewmeetingthestandardsastheminimumlevelofsafety. Inadditiontomeetingthestandards, we do additional testing to ensure, as much as is possible, that a product is safe. That includes putting faults on products and assessing the consequences. This is known as Failure Mode and Effect Analysis (FMEA). Theproductsafetyframeworkcontainschecksandbalancestoensurethatnewandemergingsafety risks are discovered and addressed. In particular, there are specific obligations placed on industry to: 1Called Harmonised Standards in the European Union.
● monitor and investigate safety risks; ● take corrective action (e.g. recalls) to address non-conformities; and ● report safety risks to Trading Standards If the UK authorities are investigating a safety issue, they can make an initial request for relevant informationtobesharedwillingly.Intheeventofarefusal,theyhavetools,includingRegulation28of theGPSR,torequirecompaniestoprovideinformationinrelationtoproductsafetyissues.Afailureto comply is a criminal offence. Upcoming Changes to Product Safety Legal Framework ThelegalframeworkintheUKislikelytobeupdatedthisyear.TheProductRegulationandMetrology Bill(the“Bill”)iscurrentlybeingdebatedintheHouseofLords.TheBillisintendedtobeanenabling Act with detailed regulations passed after it has been enacted, so theprecisescopeisnotknown. However,followingaconsultationbytheOfficeforProductSafetyandStandards(“OPSS”)inOctober 2023,2 itisclearthattheGovernmentisconsideringissuesrelevanttoanumberofthemattersraised by the Assistant Coroner. In particular: ● Proposal8:Facilitatearichsourceofdata,bycreatinganewlegaldatagateway–thiswould enable the Government to request that product safety data is shared by industry with the authorities, including the OPSS and Trading Standards. ● Proposal9:Allnotificationofrecallsandseriousproductsafetyincidentsandothercorrective action by a manufacturer or distributor is sent to OPSS, rather than the local authority, as soonastheeconomicoperatorhasknowledgeofanunsafeproduct–thiswouldstreamline the report of product safety incidents to the OPSS. These proposals have been subject to feedback from multiple stakeholders. In its response to the Consultation,3OPSS noted that: ● e. Better use of data: capturing high-quality product safety data in a central repository to identify product safety risks and allow targeted intervention and establishing a legal data gateway that integrates existing systems and allows sharing of intelligence e.g. between market surveillance authorities, to aid compliance and enforcement – over two thirds of responses were supportive, however, businesses suggested caution around how the data would be shared given the need to consider confidentiality. Matters of Concern (1) Thatingressofmoistureintocondensatepumpsmayresultintrackingfaultscausing resistive heating and fire 3 https://www.gov.uk/government/consultations/smarter-regulation-uk-product-safety-review/outcome/go vernment-response-to-the-product-safety-review-and-next-steps#appendix-b-summary-of-responses-t o-the-product-safety-review 2 https://assets.publishing.service.gov.uk/media/64ca51246ae44e001311b3e7/uk-product-safety-review -consultation-august-2023.pdf 2
Manufacturershaveanobligationtoonlyplaceproductsonthemarketthataresafe. Theymust ensure the products have been designed and manufactured in line with established safety objectives. Many manufacturers (includingHotpoint),demonstratethosesafetyobjectiveshave been met by testing their products against relevant safety standards as described above. Inadditiontotestingallourproductstotheappropriateindustrysafetystandards,alltheresultsof those tests are checked and approved by an independent accredited test facility. Onceaproductisplacedonthemarket,wearerequiredtomonitorthefieldtoidentifyanysafety relatedincidentsthatwillsubsequentlyfeedintoriskassessments. Wehavearobustprocessin placefordoingthis. HavinginterrogatedourdatafollowingthetragicdeathsofChampaguriBhatt and Dipak Bhatt, we cannot find any evidence of safety issues with the ingress of water into condensatepumpsinourproducts. However,thatdoesnotexcludethepossibilityoftherebeing a wider industry issue, and, if stakeholders involved in setting standards agree that there is a requirement to focus on potential risk with condensate pumps, we will of course actively participate in that process. (2) That changes in information management wouldresultinbetteranalysisof,andlearning from, white goods fires As outlined below, we regularly engage with other stakeholders to discuss how systems and processes can be changed to improve consumer safety. (3)ManufacturerstogivetheOPSSastheregulatorandLondonFireBrigade(LFB)tosupport their fire prevention workdataonpartsreplacedonwarrantyforcondensatepumpsandRFI filters (5) Manufacturers to share data on decisions and rationale behind recall / replacement of condensate pumps and RFI filters OPSS as the regulator and LFB to support their fire prevention work (6)CompaniesinvestigatingfirestonotifyTradingStandardsandtheOPSSoftheoutcomeof those investigations Thesemattersofconcernallrelatetothecollectionandsharingofinformationaroundproductsafety risks and incidents. Asnotedabove,theproductsafetylegalframeworkplacesresponsibilityonmanufacturersandother actors in the supply chain to monitor and investigate safety issues and report safety risks. The UK authorities have investigatory tools, including Regulation 28 of the GPSR, to require companies to provide information in relation to product safety issues where the information is not givenwillingly.Afailuretocomplyisacriminaloffence.Thatistheproperrouteforauthoritiesthatare minded to require manufacturers to disclose sensitive company information. We note that data sharing is within the scope of the Government’s ongoing product safetyreview, although the scope is not as broad as the matters recommended to the Assistant Coroner by the LFB. Hotpoint is a member of AMDEA, the white goods trade association, and actively participates in industrymeetings,includingonsafetyandstandards. WeregularlyengagewiththeLFB,OPSSand NGOssuchasElectricalSafetyFirst,boththroughindustrymeetingsanddirectly,toexplorehowall 3
stakeholderscanworktogetherwiththeaimofimprovingsafety. Wearealsoactivelyinvolvedwith BSI and European International Standards bodies in the development of safety and performance standards. We fully support the development of systems to improve productsafety,includingdata sharing and information management that can be adopted cross industry and supported by all stakeholders. (4)WorkinggroupCPL/61lookatstandardsofmanufactureofmainsandsubmainsoperated condensate pumps and RFI filters Hotpoint welcomes the role of standards bodies such as the British Standards Institute in the continuing improvement of safety standards. Hotpoint is an active participant in standards development,withitsrepresentativessittingontechnicalcommitteesonarangeofstandards,andis very supportive of all efforts to improve product safety where new and emerging risks have been discovered. (7)ManufacturerstoberequiredtousetheOPSSriskassessmentmethodology,PRISM,when conductingriskassessmentstoaccountforpersonsinapropertyandtheiractions,i.e.while sleeping whilst a product is taking advantage of lower electricity rates Manufacturers are already required to demonstrate that their appliances are safe, and, if it is subsequently found they are not safe, to risk assess to determine the level of risk. PRISMwasnotdevelopedwiththeintentionthatitwouldbeusedtoassessthesafetyofthedesign ofaproductpriortomanufacture.ItisamethodologydevelopedfromtheEU’sRAPEXmethodology fortheassessmentofunexpectedrisksthatmayoccurinproductsthatarealreadyonthemarket.In the OPSS’ guidance on PRISM, it states: “As noted above, this guidance is intended for use by marketsurveillanceofficers.Itisnotintendedtobeusedbybusinesseswhenundertakingpre-market risk assessment as part of the process of assessing the conformity of their products to relevant essential requirements or when considering the general safety requirement contained within the General Product Safety Regulations 2005 (GPSR).”4 That being said, there are elements of PRISM that can be applied usefully to a pre-market risk assessment process. For example, it is already common for foreseeable risks associated with sleeping to be taken into account when assessing the risks of electrical products that operate at night. (8) Identification plates on appliances that will not be destroyed by fire akin to those on vehicles We know that indelible marking is under consideration by the CPL / 61 Standards committee5. The committee has formed a working group to look at this issue, and as a company, we are members and actively involved in that working group. On 8 January 2024, the LFB wrote to the Senior Coroner. At point 6, the LFB refers to working with AMDEA on a means of identifying fire damaged white goods via the sharing of digital images between 5The CPL / 61 Standards Committee is a committee headed by BSI, which considers UK input to the international standard on household and similar electrical appliances, including tumble dryers. 4Section 1.2 of Guide for GB Market Surveillance Authorities and Enforcing Authorities Responsible for Regulating Consumer Product Safety, version 2.0, October 2024 (https://assets.publishing.service.gov.uk/media/66fd385ae84ae1fd8592ec93/prism-guidance-v02.pdf) 4
appliance manufacturers and FRS. The LFB notes thatif it does not show clear evidence of sustainable success, then the LFB would recommend an indelible marking scheme. Our understanding from AMDEA is that the trial is working well and is being rolled out to other Fire Services (outside the LFB). Additionally, indelible marking is only a benefit from the day it’s implemented, it does not help with the identification of any products produced before that date and already in the market. The AMDEA trial does address this challenge. As this issue is an industry-wide issue with national ramifications, any change would need to be implemented through updates to standards or regulation. We will obviously continue to support theLFB/AMDEA initiative of digital identification andcomplywithanyfutureindustrywideregulatory requirements. Hotpoint willworkwithgovernmentpolicymakers,regulators,fireservices,manufacturersandother stakeholderstoensurethatwecontinuetoraisethebarforapplianceproductsafetyintheUK. We are always available to discuss relevant topics at your disposal. Your Sincerely, Managing Director 5
● monitor and investigate safety risks; ● take corrective action (e.g. recalls) to address non-conformities; and ● report safety risks to Trading Standards If the UK authorities are investigating a safety issue, they can make an initial request for relevant informationtobesharedwillingly.Intheeventofarefusal,theyhavetools,includingRegulation28of theGPSR,torequirecompaniestoprovideinformationinrelationtoproductsafetyissues.Afailureto comply is a criminal offence. Upcoming Changes to Product Safety Legal Framework ThelegalframeworkintheUKislikelytobeupdatedthisyear.TheProductRegulationandMetrology Bill(the“Bill”)iscurrentlybeingdebatedintheHouseofLords.TheBillisintendedtobeanenabling Act with detailed regulations passed after it has been enacted, so theprecisescopeisnotknown. However,followingaconsultationbytheOfficeforProductSafetyandStandards(“OPSS”)inOctober 2023,2 itisclearthattheGovernmentisconsideringissuesrelevanttoanumberofthemattersraised by the Assistant Coroner. In particular: ● Proposal8:Facilitatearichsourceofdata,bycreatinganewlegaldatagateway–thiswould enable the Government to request that product safety data is shared by industry with the authorities, including the OPSS and Trading Standards. ● Proposal9:Allnotificationofrecallsandseriousproductsafetyincidentsandothercorrective action by a manufacturer or distributor is sent to OPSS, rather than the local authority, as soonastheeconomicoperatorhasknowledgeofanunsafeproduct–thiswouldstreamline the report of product safety incidents to the OPSS. These proposals have been subject to feedback from multiple stakeholders. In its response to the Consultation,3OPSS noted that: ● e. Better use of data: capturing high-quality product safety data in a central repository to identify product safety risks and allow targeted intervention and establishing a legal data gateway that integrates existing systems and allows sharing of intelligence e.g. between market surveillance authorities, to aid compliance and enforcement – over two thirds of responses were supportive, however, businesses suggested caution around how the data would be shared given the need to consider confidentiality. Matters of Concern (1) Thatingressofmoistureintocondensatepumpsmayresultintrackingfaultscausing resistive heating and fire 3 https://www.gov.uk/government/consultations/smarter-regulation-uk-product-safety-review/outcome/go vernment-response-to-the-product-safety-review-and-next-steps#appendix-b-summary-of-responses-t o-the-product-safety-review 2 https://assets.publishing.service.gov.uk/media/64ca51246ae44e001311b3e7/uk-product-safety-review -consultation-august-2023.pdf 2
Manufacturershaveanobligationtoonlyplaceproductsonthemarketthataresafe. Theymust ensure the products have been designed and manufactured in line with established safety objectives. Many manufacturers (includingHotpoint),demonstratethosesafetyobjectiveshave been met by testing their products against relevant safety standards as described above. Inadditiontotestingallourproductstotheappropriateindustrysafetystandards,alltheresultsof those tests are checked and approved by an independent accredited test facility. Onceaproductisplacedonthemarket,wearerequiredtomonitorthefieldtoidentifyanysafety relatedincidentsthatwillsubsequentlyfeedintoriskassessments. Wehavearobustprocessin placefordoingthis. HavinginterrogatedourdatafollowingthetragicdeathsofChampaguriBhatt and Dipak Bhatt, we cannot find any evidence of safety issues with the ingress of water into condensatepumpsinourproducts. However,thatdoesnotexcludethepossibilityoftherebeing a wider industry issue, and, if stakeholders involved in setting standards agree that there is a requirement to focus on potential risk with condensate pumps, we will of course actively participate in that process. (2) That changes in information management wouldresultinbetteranalysisof,andlearning from, white goods fires As outlined below, we regularly engage with other stakeholders to discuss how systems and processes can be changed to improve consumer safety. (3)ManufacturerstogivetheOPSSastheregulatorandLondonFireBrigade(LFB)tosupport their fire prevention workdataonpartsreplacedonwarrantyforcondensatepumpsandRFI filters (5) Manufacturers to share data on decisions and rationale behind recall / replacement of condensate pumps and RFI filters OPSS as the regulator and LFB to support their fire prevention work (6)CompaniesinvestigatingfirestonotifyTradingStandardsandtheOPSSoftheoutcomeof those investigations Thesemattersofconcernallrelatetothecollectionandsharingofinformationaroundproductsafety risks and incidents. Asnotedabove,theproductsafetylegalframeworkplacesresponsibilityonmanufacturersandother actors in the supply chain to monitor and investigate safety issues and report safety risks. The UK authorities have investigatory tools, including Regulation 28 of the GPSR, to require companies to provide information in relation to product safety issues where the information is not givenwillingly.Afailuretocomplyisacriminaloffence.Thatistheproperrouteforauthoritiesthatare minded to require manufacturers to disclose sensitive company information. We note that data sharing is within the scope of the Government’s ongoing product safetyreview, although the scope is not as broad as the matters recommended to the Assistant Coroner by the LFB. Hotpoint is a member of AMDEA, the white goods trade association, and actively participates in industrymeetings,includingonsafetyandstandards. WeregularlyengagewiththeLFB,OPSSand NGOssuchasElectricalSafetyFirst,boththroughindustrymeetingsanddirectly,toexplorehowall 3
stakeholderscanworktogetherwiththeaimofimprovingsafety. Wearealsoactivelyinvolvedwith BSI and European International Standards bodies in the development of safety and performance standards. We fully support the development of systems to improve productsafety,includingdata sharing and information management that can be adopted cross industry and supported by all stakeholders. (4)WorkinggroupCPL/61lookatstandardsofmanufactureofmainsandsubmainsoperated condensate pumps and RFI filters Hotpoint welcomes the role of standards bodies such as the British Standards Institute in the continuing improvement of safety standards. Hotpoint is an active participant in standards development,withitsrepresentativessittingontechnicalcommitteesonarangeofstandards,andis very supportive of all efforts to improve product safety where new and emerging risks have been discovered. (7)ManufacturerstoberequiredtousetheOPSSriskassessmentmethodology,PRISM,when conductingriskassessmentstoaccountforpersonsinapropertyandtheiractions,i.e.while sleeping whilst a product is taking advantage of lower electricity rates Manufacturers are already required to demonstrate that their appliances are safe, and, if it is subsequently found they are not safe, to risk assess to determine the level of risk. PRISMwasnotdevelopedwiththeintentionthatitwouldbeusedtoassessthesafetyofthedesign ofaproductpriortomanufacture.ItisamethodologydevelopedfromtheEU’sRAPEXmethodology fortheassessmentofunexpectedrisksthatmayoccurinproductsthatarealreadyonthemarket.In the OPSS’ guidance on PRISM, it states: “As noted above, this guidance is intended for use by marketsurveillanceofficers.Itisnotintendedtobeusedbybusinesseswhenundertakingpre-market risk assessment as part of the process of assessing the conformity of their products to relevant essential requirements or when considering the general safety requirement contained within the General Product Safety Regulations 2005 (GPSR).”4 That being said, there are elements of PRISM that can be applied usefully to a pre-market risk assessment process. For example, it is already common for foreseeable risks associated with sleeping to be taken into account when assessing the risks of electrical products that operate at night. (8) Identification plates on appliances that will not be destroyed by fire akin to those on vehicles We know that indelible marking is under consideration by the CPL / 61 Standards committee5. The committee has formed a working group to look at this issue, and as a company, we are members and actively involved in that working group. On 8 January 2024, the LFB wrote to the Senior Coroner. At point 6, the LFB refers to working with AMDEA on a means of identifying fire damaged white goods via the sharing of digital images between 5The CPL / 61 Standards Committee is a committee headed by BSI, which considers UK input to the international standard on household and similar electrical appliances, including tumble dryers. 4Section 1.2 of Guide for GB Market Surveillance Authorities and Enforcing Authorities Responsible for Regulating Consumer Product Safety, version 2.0, October 2024 (https://assets.publishing.service.gov.uk/media/66fd385ae84ae1fd8592ec93/prism-guidance-v02.pdf) 4
appliance manufacturers and FRS. The LFB notes thatif it does not show clear evidence of sustainable success, then the LFB would recommend an indelible marking scheme. Our understanding from AMDEA is that the trial is working well and is being rolled out to other Fire Services (outside the LFB). Additionally, indelible marking is only a benefit from the day it’s implemented, it does not help with the identification of any products produced before that date and already in the market. The AMDEA trial does address this challenge. As this issue is an industry-wide issue with national ramifications, any change would need to be implemented through updates to standards or regulation. We will obviously continue to support theLFB/AMDEA initiative of digital identification andcomplywithanyfutureindustrywideregulatory requirements. Hotpoint willworkwithgovernmentpolicymakers,regulators,fireservices,manufacturersandother stakeholderstoensurethatwecontinuetoraisethebarforapplianceproductsafetyintheUK. We are always available to discuss relevant topics at your disposal. Your Sincerely, Managing Director 5
Noted
AMDEA acknowledges the coroner's concerns and states its commitment to collaborating with stakeholders to enhance product safety. They also note that fire incident data for key appliances is collated annually to identify trends and inform safety improvements. (AI summary)
AMDEA acknowledges the coroner's concerns and states its commitment to collaborating with stakeholders to enhance product safety. They also note that fire incident data for key appliances is collated annually to identify trends and inform safety improvements. (AI summary)
View full response
Dear Mr Straker,
Thank you for your regulaƟon 28 report to prevent future deaths, dated 6 December 2024, concerning the fire incident involving a domesƟc appliance and resulƟng in the tragic deaths of Messrs and Mses Champagauri and Dipak BhaƩ. We appreciate the thorough invesƟgaƟon, and the concerns raised in your report.
We have carefully reviewed the content of the findings and address below each point of concern in turn. AMDEA remains commiƩed to collaboraƟng with industry stakeholders to enhance product safety and will conƟnue to share insights at naƟonal and internaƟonal standards development commiƩee meeƟngs. These ongoing efforts aim to drive conƟnuous improvement, enhancing informaƟon management, sharing best pracƟces, and upholding the highest safety standards across our sector. We value the opportunity to contribute to the prevenƟon of future deaths and are commiƩed to working closely with the Office of Product Safety Standards (OPSS), the London Fire Brigade (LFB), and other relevant bodies to implement effecƟve soluƟons. Please do not hesitate to reach out if further clarificaƟon is required.
Thank you for your regulaƟon 28 report to prevent future deaths, dated 6 December 2024, concerning the fire incident involving a domesƟc appliance and resulƟng in the tragic deaths of Messrs and Mses Champagauri and Dipak BhaƩ. We appreciate the thorough invesƟgaƟon, and the concerns raised in your report.
We have carefully reviewed the content of the findings and address below each point of concern in turn. AMDEA remains commiƩed to collaboraƟng with industry stakeholders to enhance product safety and will conƟnue to share insights at naƟonal and internaƟonal standards development commiƩee meeƟngs. These ongoing efforts aim to drive conƟnuous improvement, enhancing informaƟon management, sharing best pracƟces, and upholding the highest safety standards across our sector. We value the opportunity to contribute to the prevenƟon of future deaths and are commiƩed to working closely with the Office of Product Safety Standards (OPSS), the London Fire Brigade (LFB), and other relevant bodies to implement effecƟve soluƟons. Please do not hesitate to reach out if further clarificaƟon is required.
Noted
BSI acknowledges the coroner's concerns and explains its role in standardization. The CPL/61 committee considered the request to improve standards for condensate pumps and filters but needs more information regarding the fire investigation before a decision can be made. (AI summary)
BSI acknowledges the coroner's concerns and explains its role in standardization. The CPL/61 committee considered the request to improve standards for condensate pumps and filters but needs more information regarding the fire investigation before a decision can be made. (AI summary)
View full response
Dear Sir,
Champaguri and Dipak Bhatt : Prevention of future deaths report
Introduction
1. We write in response to your Regulation 28 report of 06 December 2024 concerning the deaths of Champaguri and Dipak Bhatt (“the Report”).
2. BSI would like at the outset to express its deepest sympathy and condolences for the family of the victims.
3. We are responding in particular to No.5 (Coroner’s Concerns) Item 4 in the Report: “Working group CPL / 61 look at standards of manufacture of mains and sub mains operated condensate pumps and RFI filters, to improve standards.”
© 2024 BSI. All rights reserved.
2 BSI’s role
4. BSI’s role as the NSB is established by Royal Charter. BSI has several governing documents (available online):
a. BSI’s Royal Charter and Bye-laws 1981;
b. A Memorandum of Understanding (MoU) of 16 September 2024 between HM Government and BSI in respect of BSI’s activities as the United Kingdom’s NSB;
c. BS 0: 2021 ‘A standard for standards – Principles of standardization’ (BS 0)
5. Article 1.2 of the MoU provides that BSI’s role as the NSB includes:
a) the management, co-ordination and understanding of British Standards and BSI standardisation products; b) participation by BSI in European and international standards bodies, and other international activity undertaken in the interests of BSI as the United Kingdom’s NSB; c) publication, promotion, marketing, distribution and information activities concerned with British Standards, BSI’s other standardisation products, and standardisation generally; d) support any corporate infrastructure activities intended, wholly or in part, to enable paragraph 12(a) to (c) above. The Director of Standards has the primary responsibility for the activities set out above. BSI’s present Director of Standards is Dr Scott Steedman (the role is incorporated within his responsibilities as Director-General, Standards).
6. BSI develops and distributes standards in response to the needs of UK stakeholders, which include HM Government and business. Standards are technical documents representing good industry practice. They are voluntary documents drafted by independent experts, as distinct from legislation or regulation from government.
© 2024 BSI. All rights reserved.
3
7. BSI’s role as the National Standards Body is to facilitate expert committees to achieve consensus on industry standards and best practice and to act as the publisher of standards. BSI does not retain in-house expertise on the subject matter of standards. Further, BSI is not a regulatory body and is therefore unable to advise on regulatory matters, which are a matter for HM Government.
8. Each individual standard is the responsibility of one committee. It is the committee who is responsible for the technical content of the standard, not BSI. The committees are composed of:
a. An independent chair,
b. External experts, who are responsible for the technical content of national standards, and for contributing the UK’s technical input into European and international standards, and
c. BSI staff, who are responsible for the management of the committee, editorial input and ensuring the committee follows BSI’s processes.
9. Each committee has a defined scope, and develops standards within that scope. For European and international standards the committee acts as a local (British) ‘mirror committee’.
10. The responsible UK committee in this instance is entitled CPL/61: Safety of household and similar electrical appliances. Its scope is:
“Under the direction of the Standards Policy and Strategy Committee, is responsible for providing UK input into IEC TC 61, SC 61C and CENELEC TC 61 on matters relating to IEC/EN 60335-1 and Part 2s in the following areas: safety of home laundry and dishwashing machines together with IEC/EN 61770 for electrical appliances connected to the water mains, avoidance of backsiphonage and failure of hose-sets, (formerly within the scope of CPL/61/14, now disbanded), safety standards for motor
© 2024 BSI. All rights reserved.
4 compressors, refrigerating appliances and similar appliances for household and commercial use (formerly within the scope of CPL/61/3, now disbanded), safety standards for electrical commercial catering equipment (formerly within the scope of CPL/61/5, now disbanded) and requirements for gas, oil and solid-fuel burning appliances having electrical connections (formerly within the scope of CPL/61/35, now disbanded”). (see https://standardsdevelopment.bsigroup.com/committees/50001507).
Committee’s Response
11. BSI convened a meeting of CPL/61 on 21 January 2025 to discuss the Report.
12. The members present represented the following organizations:
• Agricultural Engineers Association (AEA)
• Association of Manufacturers of Domestic Appliances (AMDEA)
• Vending and Automated Retail Association (AVA)
• BEAMA Installation Ltd
• British and Irish Spa and Hot Tub Association (BISHTA)
• British Home Enhancement Trade Association
• BSI Consumer and Public Interest Network
• Department for Business and Trade
• Electrical Safety First
• Hot Water Association
• London Fire Brigade (LFB)
• Portable Electric Tool Manufacturers Association
© 2024 BSI. All rights reserved.
5
• Vending and Automated Retail Association (AVA)
• Which?
13. The responsible BSI committee manager, Mrs Geraldine Salt, recorded the following note of the meeting:
a. The Coroner’s report stated that the fire had been caused by an electrical fault in the tumble dryer and that there was a 10% chance the EMI filter had caused the fire and a 90% chance the condensate pump had caused the fire.
b. The Coroner asked CPL/61 to look at standards of manufacture of mains and sub mains operated condensate pumps and filters, to consider if the.
c. The Committee considered this request and decided that in order to be able to reach an informed engineering decision regarding making an appropriate amendment to the standard, more specific information regarding the fire investigation and its conclusions was needed. In particular:
a) The LFB representative reported at the CPL/61 meeting that its experts had considered that the fire had been caused by a fault within the door switch mechanism and CPL/61 would like to understand the reasoning as to why this consideration has been discounted.
b) The committee asks whether it is possible for the expert reporting which took place during this Court case to be made available to the committee.
c) The committee also asks if it could be provided with details of the appliance itself, including its age and whether it had ever been subject to a recall.
© 2024 BSI. All rights reserved.
6
d. CPL/61 considers that without the above information, it is not in a position to make a decision on how best the standard can be amended to address the cause of the fire.
e. CPL/61 is therefore unable to respond in full to the Coroner’s letter at present but it will be holding a further meeting on 6 February 2025. Should the above information be available to the committee at that point, then it will be able to look further into the matter with a view to deciding how the cause of the fire can be best addressed in the relevant standards.
Champaguri and Dipak Bhatt : Prevention of future deaths report
Introduction
1. We write in response to your Regulation 28 report of 06 December 2024 concerning the deaths of Champaguri and Dipak Bhatt (“the Report”).
2. BSI would like at the outset to express its deepest sympathy and condolences for the family of the victims.
3. We are responding in particular to No.5 (Coroner’s Concerns) Item 4 in the Report: “Working group CPL / 61 look at standards of manufacture of mains and sub mains operated condensate pumps and RFI filters, to improve standards.”
© 2024 BSI. All rights reserved.
2 BSI’s role
4. BSI’s role as the NSB is established by Royal Charter. BSI has several governing documents (available online):
a. BSI’s Royal Charter and Bye-laws 1981;
b. A Memorandum of Understanding (MoU) of 16 September 2024 between HM Government and BSI in respect of BSI’s activities as the United Kingdom’s NSB;
c. BS 0: 2021 ‘A standard for standards – Principles of standardization’ (BS 0)
5. Article 1.2 of the MoU provides that BSI’s role as the NSB includes:
a) the management, co-ordination and understanding of British Standards and BSI standardisation products; b) participation by BSI in European and international standards bodies, and other international activity undertaken in the interests of BSI as the United Kingdom’s NSB; c) publication, promotion, marketing, distribution and information activities concerned with British Standards, BSI’s other standardisation products, and standardisation generally; d) support any corporate infrastructure activities intended, wholly or in part, to enable paragraph 12(a) to (c) above. The Director of Standards has the primary responsibility for the activities set out above. BSI’s present Director of Standards is Dr Scott Steedman (the role is incorporated within his responsibilities as Director-General, Standards).
6. BSI develops and distributes standards in response to the needs of UK stakeholders, which include HM Government and business. Standards are technical documents representing good industry practice. They are voluntary documents drafted by independent experts, as distinct from legislation or regulation from government.
© 2024 BSI. All rights reserved.
3
7. BSI’s role as the National Standards Body is to facilitate expert committees to achieve consensus on industry standards and best practice and to act as the publisher of standards. BSI does not retain in-house expertise on the subject matter of standards. Further, BSI is not a regulatory body and is therefore unable to advise on regulatory matters, which are a matter for HM Government.
8. Each individual standard is the responsibility of one committee. It is the committee who is responsible for the technical content of the standard, not BSI. The committees are composed of:
a. An independent chair,
b. External experts, who are responsible for the technical content of national standards, and for contributing the UK’s technical input into European and international standards, and
c. BSI staff, who are responsible for the management of the committee, editorial input and ensuring the committee follows BSI’s processes.
9. Each committee has a defined scope, and develops standards within that scope. For European and international standards the committee acts as a local (British) ‘mirror committee’.
10. The responsible UK committee in this instance is entitled CPL/61: Safety of household and similar electrical appliances. Its scope is:
“Under the direction of the Standards Policy and Strategy Committee, is responsible for providing UK input into IEC TC 61, SC 61C and CENELEC TC 61 on matters relating to IEC/EN 60335-1 and Part 2s in the following areas: safety of home laundry and dishwashing machines together with IEC/EN 61770 for electrical appliances connected to the water mains, avoidance of backsiphonage and failure of hose-sets, (formerly within the scope of CPL/61/14, now disbanded), safety standards for motor
© 2024 BSI. All rights reserved.
4 compressors, refrigerating appliances and similar appliances for household and commercial use (formerly within the scope of CPL/61/3, now disbanded), safety standards for electrical commercial catering equipment (formerly within the scope of CPL/61/5, now disbanded) and requirements for gas, oil and solid-fuel burning appliances having electrical connections (formerly within the scope of CPL/61/35, now disbanded”). (see https://standardsdevelopment.bsigroup.com/committees/50001507).
Committee’s Response
11. BSI convened a meeting of CPL/61 on 21 January 2025 to discuss the Report.
12. The members present represented the following organizations:
• Agricultural Engineers Association (AEA)
• Association of Manufacturers of Domestic Appliances (AMDEA)
• Vending and Automated Retail Association (AVA)
• BEAMA Installation Ltd
• British and Irish Spa and Hot Tub Association (BISHTA)
• British Home Enhancement Trade Association
• BSI Consumer and Public Interest Network
• Department for Business and Trade
• Electrical Safety First
• Hot Water Association
• London Fire Brigade (LFB)
• Portable Electric Tool Manufacturers Association
© 2024 BSI. All rights reserved.
5
• Vending and Automated Retail Association (AVA)
• Which?
13. The responsible BSI committee manager, Mrs Geraldine Salt, recorded the following note of the meeting:
a. The Coroner’s report stated that the fire had been caused by an electrical fault in the tumble dryer and that there was a 10% chance the EMI filter had caused the fire and a 90% chance the condensate pump had caused the fire.
b. The Coroner asked CPL/61 to look at standards of manufacture of mains and sub mains operated condensate pumps and filters, to consider if the.
c. The Committee considered this request and decided that in order to be able to reach an informed engineering decision regarding making an appropriate amendment to the standard, more specific information regarding the fire investigation and its conclusions was needed. In particular:
a) The LFB representative reported at the CPL/61 meeting that its experts had considered that the fire had been caused by a fault within the door switch mechanism and CPL/61 would like to understand the reasoning as to why this consideration has been discounted.
b) The committee asks whether it is possible for the expert reporting which took place during this Court case to be made available to the committee.
c) The committee also asks if it could be provided with details of the appliance itself, including its age and whether it had ever been subject to a recall.
© 2024 BSI. All rights reserved.
6
d. CPL/61 considers that without the above information, it is not in a position to make a decision on how best the standard can be amended to address the cause of the fire.
e. CPL/61 is therefore unable to respond in full to the Coroner’s letter at present but it will be holding a further meeting on 6 February 2025. Should the above information be available to the committee at that point, then it will be able to look further into the matter with a view to deciding how the cause of the fire can be best addressed in the relevant standards.
Noted
North Yorkshire Council, as primary authority for Hotpoint, states that testing was conducted on the part in question and that it passed all tests. They have arranged for further testing and state Hotpoint will comply with any changes in the law. (AI summary)
North Yorkshire Council, as primary authority for Hotpoint, states that testing was conducted on the part in question and that it passed all tests. They have arranged for further testing and state Hotpoint will comply with any changes in the law. (AI summary)
View full response
Dear Sir,
Regulation 28 Report to Prevent Future Deaths
Thank you for providing a copy of your report to North Yorkshire Council as the primary authority for Hotpoint UK Appliances Ltd.
The primary authority agreement that the council’s trading standards service has with Hotpoint UK Appliances Ltd is a limited one involving a monthly review of the complaints received by the Citizens Advice Consumer Service and trading standards services around the country.
Neither this service nor Hotpoint UK Appliances Ltd has received any other complaint about the identified parts overheating or causing a fire. Since the receipt of the Prevention of Future Deaths report, the company has conducted forced failure testing going beyond that required by the Standard. The testing was conducted at an in-house facility in Italy so could not be observed by a trading standards officer, however, it was overseen by , of the Beko Europe Safety team. is a member of the IEC TC89 Committee reviewing safety standards for Fire Hazard, and it has been confirmed that she was fully aware of the Bhatt case and the verdict. The filters and pumps passed all the tests.
The company has conducted a risk assessment taking into account the absence of other complaints and the test outcomes. This indicates that a recall is not necessary and does not identify any improvements to the components.
There is a model of the tumble dryer containing the condensate pump referred to in your report which is no longer manufactured but is still available on the market. I have asked the trading standards service to arrange for testing against the Standard of a test purchase of the model as an additional check on the company’s findings.
Chief Executive North Yorkshire Council County Hall Northallerton North Yorkshire DL7 8AD Tel: 01609 532444 Email:
Mr P Straker Assistant Coroner (Northern District of Greater London) North London Coroner’s Service Barnet, Brent, Enfield, Haringey and Harrow Barnet Coroner’s Court 29 Wood Street London EN5 4BE
OFFICIAL Hotpoint UK Appliances Ltd has confirmed that it will comply with any changes in the law introduced as a result of your recommendations, and officers will review such compliance as part of future primary authority meetings.
Chief Executive
Regulation 28 Report to Prevent Future Deaths
Thank you for providing a copy of your report to North Yorkshire Council as the primary authority for Hotpoint UK Appliances Ltd.
The primary authority agreement that the council’s trading standards service has with Hotpoint UK Appliances Ltd is a limited one involving a monthly review of the complaints received by the Citizens Advice Consumer Service and trading standards services around the country.
Neither this service nor Hotpoint UK Appliances Ltd has received any other complaint about the identified parts overheating or causing a fire. Since the receipt of the Prevention of Future Deaths report, the company has conducted forced failure testing going beyond that required by the Standard. The testing was conducted at an in-house facility in Italy so could not be observed by a trading standards officer, however, it was overseen by , of the Beko Europe Safety team. is a member of the IEC TC89 Committee reviewing safety standards for Fire Hazard, and it has been confirmed that she was fully aware of the Bhatt case and the verdict. The filters and pumps passed all the tests.
The company has conducted a risk assessment taking into account the absence of other complaints and the test outcomes. This indicates that a recall is not necessary and does not identify any improvements to the components.
There is a model of the tumble dryer containing the condensate pump referred to in your report which is no longer manufactured but is still available on the market. I have asked the trading standards service to arrange for testing against the Standard of a test purchase of the model as an additional check on the company’s findings.
Chief Executive North Yorkshire Council County Hall Northallerton North Yorkshire DL7 8AD Tel: 01609 532444 Email:
Mr P Straker Assistant Coroner (Northern District of Greater London) North London Coroner’s Service Barnet, Brent, Enfield, Haringey and Harrow Barnet Coroner’s Court 29 Wood Street London EN5 4BE
OFFICIAL Hotpoint UK Appliances Ltd has confirmed that it will comply with any changes in the law introduced as a result of your recommendations, and officers will review such compliance as part of future primary authority meetings.
Chief Executive
Action Planned
OPSS is seeking an update from BSI on the progress of a pilot project trialing a fire-resistant marking approach to enable identification of fire-damaged appliances and supporting their traceability. (AI summary)
OPSS is seeking an update from BSI on the progress of a pilot project trialing a fire-resistant marking approach to enable identification of fire-damaged appliances and supporting their traceability. (AI summary)
View full response
Dear Mr Straker, Thank you for sharing your Regulation 28 Report to Prevent Future Deaths, dated 6 December 2024, following your investigation and inquest into the deaths of Ms Champagauri Bhatt and Mr Dipak Bhatt, from inhalation injuries sustained due to a fire caused by an electrical fault in a tumble dryer. I was very sorry to hear of Champagauri and Dipak’s deaths. If you have the opportunity, please do pass on my deepest sympathies to their family and friends. The Office for Product Safety and Standards (OPSS), within the Department for Business and Trade, is the UK’s national product regulator, responsible for the regulation of most consumer goods, including electrical appliances. OPSS was made aware of this incident by London Fire Brigade on 31 March 2023, and took the following steps - we made contact with the manufacturer of the tumble dryer, Hotpoint UK Appliances Ltd, and with the relevant local authority that leads the regulation of the business through Primary Authority, North Yorkshire County Council. Following OPSS’ evaluation of the early information in this incident, it was agreed with North Yorkshire County Council that they would lead the investigation in this case. OPSS remains in regular contact with the Council and continues to offer them any necessary support. I understand that they also received a copy of your report and will be responding to you directly. You may be aware that in 2018-2019, OPSS was the lead regulator overseeing a national recall affecting up to 5 million tumble dryers, sold under the Hotpoint, Indesit, Swan, Creda and ProLine brands. That recall was instigated to address a risk of fire caused by fluff coming into contact with heating elements within the dryers. We have no evidence to suggest that the model in this incident was involved in the earlier recall.
Office for Product Safety and Standards Cannon House 18 The Priory Queensway Birmingham B4 6BS General enquiries: +44 (0)121 345 1201
The Office for Product Safety and Standards (OPSS) delivers consumer protection and supports business confidence, productivity and growth. It is part of the Department for Business and Trade. gov.uk/opss
I would like to address the matters of concern in your report which OPSS is best placed to consider. You have raised the issue of data and information sharing between manufacturers and regulators, particularly when manufacturers are investigating potential safety issues with their products. Under the Electrical Equipment (Safety) Regulations 2016, manufacturers of electrical goods are already required to notify regulators when they become aware of a safety issue with a product they have placed on the market. The Regulations also provide regulators with powers to require information from manufacturers or other persons in the supply chain regarding product safety issues, and to require corrective actions to ensure they are addressed. OPSS has also established a process of information sharing with London Fire Brigade (LFB) and other Fire and Rescue Services (FRS) to collect information about product- related fires, known as Product-related Fire Notifications (PFNs). In more serious cases, including those involving serious injuries or fatalities, fire investigators can undertake detailed investigations to determine the cause, defect or failure that led to a product- related fire breaking out. OPSS has been gathering this information in partnership with LFB since 2020, and other FRS since February 2023, when OPSS published guidance Product-Related Fire Incident Notifications - GOV.UK to assist and support FRS to report product-related fires. This approach helps OPSS in identifying products that may be putting people at risk, so we can consider and take any action necessary. As an example, OPSS were notified of reports from several FRS of fires in the UK caused by the same UPP brand of e-bike battery. OPSS was able to carry out enforcement action to prohibit online marketplaces, online sellers and the manufacturer from supplying the battery in the UK. OPSS continues to actively promote the value of reporting product-related fires to individual FRS and fire investigation teams, and the role it can play in dealing with unsafe products.
The Government has introduced a new Product Regulation and Metrology Bill, which is currently going through Parliament. The Bill includes provisions that will facilitate, among other things, information exchange on product safety issues and includes powers to make regulations for information sharing and co-operation with, for example, emergency services in future. It also includes powers to amend our existing product regulations to strengthen notification requirements, should that be necessary in future.
Office for Product Safety and Standards Cannon House 18 The Priory Queensway Birmingham B4 6BS General enquiries: +44 (0)121 345 1201
The Office for Product Safety and Standards (OPSS) delivers consumer protection and supports business confidence, productivity and growth. It is part of the Department for Business and Trade. gov.uk/opss
You have raised the issue of manufacturer risk assessments. Those supplying electrical equipment such as tumble dryers are already required to carry out pre-market risk assessments when assessing the overall conformity of their products to the requirements in the regulations, and document these actions. This includes risks that might arise from the product’s use in instances of predictable human behaviour, such as when people are asleep. OPSS’ PRISM tool is a post-market risk assessment methodology for product regulators to use across the broad spectrum of consumer products. While businesses can consider the use of PRISM, it is their responsibility to determine how to fully identify and mitigate risks that might arise in their specific products before they are placed on the market, and fulfil their safety obligations in the regulations. I know that you have also addressed your report to the British Standards Institution (BSI) regarding your recommendation that BSI Committee CPL/61 should review the voluntary standards concerning the manufacture of mains and sub mains operated condensate pumps and RFI filters, to consider whether they should be improved. I would like to reassure you that OPSS is committed to supporting any changes to product standards that could help raise safety levels further. Representatives from OPSS attend this Committee, and we will work with BSI to update and improve the standard wherever necessary. You also raised the issue of product identification plates. The Electrical Equipment (Safety) Regulations 2016 require that before placing electrical equipment on the market, a manufacturer must ensure that it bears a type, batch or serial number or other element allowing its identification, and is marked with the contact details at which the manufacturer can be contacted. BSI have previously been asked by Ministers to consider the feasibility for fire resistant identification marking for large electrical appliances to be included in international standards. In response, BSI commissioned a working group to explore how a requirement for fire-resistant marking could work in practice. This working group is currently trialing a pilot approach to enabling the identification of fire-damaged appliances and supporting their traceability. We are seeking an update from BSI on the progress of this pilot project. I hope that Champagauri and Dipak’s family are reassured that this tragic incident is already being considered by product regulators. While North Yorkshire County Council is taking the lead in investigating this case, OPSS will continue to engage with them and other stakeholders, so that we can provide any support needed and can learn from any
Office for Product Safety and Standards Cannon House 18 The Priory Queensway Birmingham B4 6BS General enquiries: +44 (0)121 345 1201
The Office for Product Safety and Standards (OPSS) delivers consumer protection and supports business confidence, productivity and growth. It is part of the Department for Business and Trade. gov.uk/opss
lessons that may have wider implications for the safety of this or other similar products in future. Thank you again for writing to OPSS on this matter. I would be grateful if you could share a copy of this letter with colleagues who may find it useful.
Kind regards,
Chief Executive OPSS
Office for Product Safety and Standards Cannon House 18 The Priory Queensway Birmingham B4 6BS General enquiries: +44 (0)121 345 1201
The Office for Product Safety and Standards (OPSS) delivers consumer protection and supports business confidence, productivity and growth. It is part of the Department for Business and Trade. gov.uk/opss
I would like to address the matters of concern in your report which OPSS is best placed to consider. You have raised the issue of data and information sharing between manufacturers and regulators, particularly when manufacturers are investigating potential safety issues with their products. Under the Electrical Equipment (Safety) Regulations 2016, manufacturers of electrical goods are already required to notify regulators when they become aware of a safety issue with a product they have placed on the market. The Regulations also provide regulators with powers to require information from manufacturers or other persons in the supply chain regarding product safety issues, and to require corrective actions to ensure they are addressed. OPSS has also established a process of information sharing with London Fire Brigade (LFB) and other Fire and Rescue Services (FRS) to collect information about product- related fires, known as Product-related Fire Notifications (PFNs). In more serious cases, including those involving serious injuries or fatalities, fire investigators can undertake detailed investigations to determine the cause, defect or failure that led to a product- related fire breaking out. OPSS has been gathering this information in partnership with LFB since 2020, and other FRS since February 2023, when OPSS published guidance Product-Related Fire Incident Notifications - GOV.UK to assist and support FRS to report product-related fires. This approach helps OPSS in identifying products that may be putting people at risk, so we can consider and take any action necessary. As an example, OPSS were notified of reports from several FRS of fires in the UK caused by the same UPP brand of e-bike battery. OPSS was able to carry out enforcement action to prohibit online marketplaces, online sellers and the manufacturer from supplying the battery in the UK. OPSS continues to actively promote the value of reporting product-related fires to individual FRS and fire investigation teams, and the role it can play in dealing with unsafe products.
The Government has introduced a new Product Regulation and Metrology Bill, which is currently going through Parliament. The Bill includes provisions that will facilitate, among other things, information exchange on product safety issues and includes powers to make regulations for information sharing and co-operation with, for example, emergency services in future. It also includes powers to amend our existing product regulations to strengthen notification requirements, should that be necessary in future.
Office for Product Safety and Standards Cannon House 18 The Priory Queensway Birmingham B4 6BS General enquiries: +44 (0)121 345 1201
The Office for Product Safety and Standards (OPSS) delivers consumer protection and supports business confidence, productivity and growth. It is part of the Department for Business and Trade. gov.uk/opss
You have raised the issue of manufacturer risk assessments. Those supplying electrical equipment such as tumble dryers are already required to carry out pre-market risk assessments when assessing the overall conformity of their products to the requirements in the regulations, and document these actions. This includes risks that might arise from the product’s use in instances of predictable human behaviour, such as when people are asleep. OPSS’ PRISM tool is a post-market risk assessment methodology for product regulators to use across the broad spectrum of consumer products. While businesses can consider the use of PRISM, it is their responsibility to determine how to fully identify and mitigate risks that might arise in their specific products before they are placed on the market, and fulfil their safety obligations in the regulations. I know that you have also addressed your report to the British Standards Institution (BSI) regarding your recommendation that BSI Committee CPL/61 should review the voluntary standards concerning the manufacture of mains and sub mains operated condensate pumps and RFI filters, to consider whether they should be improved. I would like to reassure you that OPSS is committed to supporting any changes to product standards that could help raise safety levels further. Representatives from OPSS attend this Committee, and we will work with BSI to update and improve the standard wherever necessary. You also raised the issue of product identification plates. The Electrical Equipment (Safety) Regulations 2016 require that before placing electrical equipment on the market, a manufacturer must ensure that it bears a type, batch or serial number or other element allowing its identification, and is marked with the contact details at which the manufacturer can be contacted. BSI have previously been asked by Ministers to consider the feasibility for fire resistant identification marking for large electrical appliances to be included in international standards. In response, BSI commissioned a working group to explore how a requirement for fire-resistant marking could work in practice. This working group is currently trialing a pilot approach to enabling the identification of fire-damaged appliances and supporting their traceability. We are seeking an update from BSI on the progress of this pilot project. I hope that Champagauri and Dipak’s family are reassured that this tragic incident is already being considered by product regulators. While North Yorkshire County Council is taking the lead in investigating this case, OPSS will continue to engage with them and other stakeholders, so that we can provide any support needed and can learn from any
Office for Product Safety and Standards Cannon House 18 The Priory Queensway Birmingham B4 6BS General enquiries: +44 (0)121 345 1201
The Office for Product Safety and Standards (OPSS) delivers consumer protection and supports business confidence, productivity and growth. It is part of the Department for Business and Trade. gov.uk/opss
lessons that may have wider implications for the safety of this or other similar products in future. Thank you again for writing to OPSS on this matter. I would be grateful if you could share a copy of this letter with colleagues who may find it useful.
Kind regards,
Chief Executive OPSS
Noted
The National Fire Chiefs Council states that receiving information from manufacturers on replaced or recalled parts is not within their remit. They support the single recall register and advocate for manufacturers to share risk assessments when patterns of faults are found. (AI summary)
The National Fire Chiefs Council states that receiving information from manufacturers on replaced or recalled parts is not within their remit. They support the single recall register and advocate for manufacturers to share risk assessments when patterns of faults are found. (AI summary)
View full response
Dear Mr Straker, Thank you for raising the concern in relation to the deaths of Champagauri and Dipak Bhatt on 29 March 2023. It is with great sadness that I read about the circumstances of their deaths. The National Fire Chiefs Council (NFCC) is committed to a culture of learning and improvement and seeks to support fire and rescue services (FRSs) to embed a learning culture. We actively track Prevention of Future Deaths Reports and share them with our members to ensure all opportunities to improve are taken. In your report you have identified NFCC as an organisation that has the power to take action to prevent future fire deaths by receiving information from manufacturers on condensate pumps and RFI filters that are replaced on warranty, or that have been recalled. The purpose for this is so NFCC has a better understanding of where such parts are having problems. Unfortunately, this is not currently within the remit of NFCC. However, we do support the single recall register, which was a key output of the Total Recalls campaign initiated by London Fire Brigade and rolled out nationally. This was created as a consumer-facing initiative and focused on products rather than parts that could be causing issues across multiple appliances. This is recorded on a national register which can be found here: Product Safety Alerts, Reports and Recalls - GOV.UK In our shared experience, it can be extremely challenging to persuade manufacturers to recall products with known risks and there is a reluctance to share information on potential issues. In the past we have seen manufacturers only issue recalls after significant events and following public and political pressure, and in some cases the threat of legal action from Trading Standards (as part of the Primary Authority arrangement). FRSs play a critical role in reporting products that lead to fires. However, determining the make and model of appliances involved in fires can be extremely difficult for Fire Investigators, let alone the component parts that may have been at fault. This is because the products are often so badly damaged, and owners do not always have this information. A key ask of London Fire Brigade’s campaign was for manufacturers to have the make and model on each appliance in a material that couldn’t be destroyed by fire (e.g. a metal plate)
Registered office: National Fire Chiefs Council Limited, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ. Registered in England as Limited Company No. 03677186. Registered in England as Charity No. 1074071. VAT Registration No. 902 1954 46
but not all manufacturers are doing this. See more here: Model and serial number identification | London Fire Brigade. There is currently no obligation on manufacturers to share information when a fault is found in components in appliances with FRSs, and we would welcome support for manufacturers to share their risk assessments, or at least key elements of the risk assessment on request (including details of components), when patterns of faults are found that may present a risk to the public. In response to the recommendations made, NFCC notes that there is currently a Product Safety and Metrology Bill, which is at the Report Stage in the Lords – following feedback from FRSs. There are powers outlined in section 7 of the Bill, which should enable sharing of information with emergency services (including FRSs). We believe it is important that this part of the bill clearly sets out a duty for manufacturers or commercial enterprises to share information on product/component safety faults (on request) that present a safety risk (of fire), to help prevent loss of life, safeguard our communities and homes. The OPSS currently gather data regarding product safety issues and seek to share information on product safety risks with FRSs and with NFCC Fire Investigation Strategic Steering Group. However, NFCC believe that it is important that the Product Safety and Metrology Bill does not lose this particular clause during its passage through parliament.
Registered office: National Fire Chiefs Council Limited, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ. Registered in England as Limited Company No. 03677186. Registered in England as Charity No. 1074071. VAT Registration No. 902 1954 46
but not all manufacturers are doing this. See more here: Model and serial number identification | London Fire Brigade. There is currently no obligation on manufacturers to share information when a fault is found in components in appliances with FRSs, and we would welcome support for manufacturers to share their risk assessments, or at least key elements of the risk assessment on request (including details of components), when patterns of faults are found that may present a risk to the public. In response to the recommendations made, NFCC notes that there is currently a Product Safety and Metrology Bill, which is at the Report Stage in the Lords – following feedback from FRSs. There are powers outlined in section 7 of the Bill, which should enable sharing of information with emergency services (including FRSs). We believe it is important that this part of the bill clearly sets out a duty for manufacturers or commercial enterprises to share information on product/component safety faults (on request) that present a safety risk (of fire), to help prevent loss of life, safeguard our communities and homes. The OPSS currently gather data regarding product safety issues and seek to share information on product safety risks with FRSs and with NFCC Fire Investigation Strategic Steering Group. However, NFCC believe that it is important that the Product Safety and Metrology Bill does not lose this particular clause during its passage through parliament.
Noted
The Home Office acknowledges the report but states it cannot provide a specific response due to a lack of detail regarding which aspects of information management need to change. (AI summary)
The Home Office acknowledges the report but states it cannot provide a specific response due to a lack of detail regarding which aspects of information management need to change. (AI summary)
View full response
Dear Mr Staker, I refer to your report dated 18 December 2024 provided in accordance with your duty under paragraph 7, Schedule 5 of the Coroners and Justice Act 2009, and Regulations 28 and 29 of the Coroners (Investigations) Regulations 2013. Please accept my sincere apologies for not getting this to you by the deadline of 31 January 2025. I offer my sincerest condolences to the family and friends of Champagauri and Dipak Bhatt. I understand from your report that the inquest concluded that Champagauri and Dipak Bhatt died from inhalation injuries following a fire caused by an electrical fault in a tumble dryer. You have suggested that changes in information management would result in better analysis of, and learning from, white goods fires, but there is no explanation in your report as to which aspects of information management need to change. In the absence of more information, it is not possible to provide a specific response to your recommendation. However, it may be helpful to note that as soon as a fatal fire is confirmed a suitably qualified Fire Investigation Officer is asked to attend and a Tier 2 Fire Investigation is undertaken. These investigations are led by the police who produce a forensic investigation plan. The Fire Investigation Officer undertakes their own inspection as part of this process and produces a report of their findings which they submit to the Police. In addition, Fire and Rescue Services undertake their own fatal fire reviews, usually chaired by the Director or Assistant Director with responsibility for fire prevention. A fatal fire review report is then produced which includes any learning that can be taken from the incident. Where appropriate, this will be shared with other Fire and Rescue Services and relevant information may also be shared with external stakeholders (e.g. Safeguarding Boards, the Health and Safety Executive and Trading Standards) as part of the fire investigation process.
Noted
CTSI acknowledges the coroner's concerns and describes its role in consumer protection and its support for OPSS. It highlights the need for a national approach to product safety and consumer reporting mechanisms. (AI summary)
CTSI acknowledges the coroner's concerns and describes its role in consumer protection and its support for OPSS. It highlights the need for a national approach to product safety and consumer reporting mechanisms. (AI summary)
View full response
- SENSITIVE Chartered Trading Standards Institute’s response to the Coroners Service Regulation 28 report to prevent future deaths CTSI was deeply saddened to hear of the deaths of Champagauri and Dipak Bhatt. We welcome the opportunity to respond to the findings in the coroner’s report, and we fully support the call for further action to be taken to prevent future deaths. CTSI has long campaigned about the safety of appliances in consumers homes and that there must be mechanisms in place to ensure that when issues are identified with certain makes and models that these are addressed as urgently, eƯectively and eƯiciently as possible. When dealing with a recall of possibly thousands of appliances, across diƯering makes and models, supplied at diƯering times by multiple retailers, this is not something that one local authority Trading Standards has the resources or mechanisms to deal with. CTSI called for the creation of a Government body to be responsible for national product safety issues and the OƯice for Product Safety and Standards (OPSS) was set up in 2018 with a specific remit to deal with national product safety issues and recalls.
About CTSI The Chartered Trading Standards Institute (CTSI) is one of the world’s longest- established organisations dedicated to the field of Trading Standards and Consumer Protection. At CTSI, and through the Trading Standards profession, we aim to promote good trading practices and to protect consumers. We strive to foster a strong vibrant economy by safeguarding the health, safety and wellbeing of citizens through empowering consumers, encouraging honest business, and targeting rogue practices. We provide information, guidance and develop evidence-based policies and campaigns to support local and national stakeholders including central and devolved governments. CTSI also provides the secretariat to the All-Party Parliamentary Group on Consumer Protection and campaigns on range of topics including product safety issues. CTSI is responsible for business advice and education in the area of Trading Standards and consumer protection legislation, including running the Business Companion service to provide clear guidance to businesses on how to meet their legal and regulatory obligations.
Response to findings We note that the coroner’s report in this case has ruled that there was a 10% chance the EMI filter in the appliance caused the fire and a 90% chance the condensate pump caused the fire.
OFFICIAL - SENSITIVE
CTSI understands that Hotpoint UK Appliances Ltd has a Primary Authority agreement with North Yorkshire Council Trading Standards, and in regard to this incident the Trading Standards team are leading the activity with Hotpoint UK Appliances Ltd directly. CTSI believes the correct action in this case is for Hotpoint UK Appliances Ltd to work closely with North Yorkshire Council Trading Standards to further investigate the safety of the product, and if an issue is identified to take appropriate steps, including to instigate a product recall if necessary. CTSI recognises that OPSS as the National Regulator for product safety continues to support North Yorkshire Council Trading Standards to understand the true scale and risk of the problem, agree the actions needed to prevent any further harm or injury occurring, and the timescales in which this should happen. This must be done to ensure that consumers are being protected from any unsafe appliances in their homes. If OPSS find that appropriate action is not being taken by Hotpoint UK Appliances Ltd, or have concerns that the actions are not being taken with enough speed to protect consumers, they can use their powers to start corrective action. CTSI, along with local authority Trading Standards OƯicers, can work with OPSS to ensure the message around any such safety issue and recalls are implemented eƯectively and have the greatest impact. CTSI would also like to see OPSS look at the wider recommendations made in the report as we believe these require a national approach to address national issues. In the EU and Northern Ireland, it is now mandatory for manufacturers to report dangerous products on the safety business gateway and there is a consumer gateway where consumers can report dangerous products. To ensure that all consumers are protected this should be an option available to GB consumers. In conclusion, CTSI remains committed to ensuring that electrical products are safe, and that processes for keeping consumers informed of risks and dangers are robust to ensure that preventable deaths or deaths injuries are avoided.
About CTSI The Chartered Trading Standards Institute (CTSI) is one of the world’s longest- established organisations dedicated to the field of Trading Standards and Consumer Protection. At CTSI, and through the Trading Standards profession, we aim to promote good trading practices and to protect consumers. We strive to foster a strong vibrant economy by safeguarding the health, safety and wellbeing of citizens through empowering consumers, encouraging honest business, and targeting rogue practices. We provide information, guidance and develop evidence-based policies and campaigns to support local and national stakeholders including central and devolved governments. CTSI also provides the secretariat to the All-Party Parliamentary Group on Consumer Protection and campaigns on range of topics including product safety issues. CTSI is responsible for business advice and education in the area of Trading Standards and consumer protection legislation, including running the Business Companion service to provide clear guidance to businesses on how to meet their legal and regulatory obligations.
Response to findings We note that the coroner’s report in this case has ruled that there was a 10% chance the EMI filter in the appliance caused the fire and a 90% chance the condensate pump caused the fire.
OFFICIAL - SENSITIVE
CTSI understands that Hotpoint UK Appliances Ltd has a Primary Authority agreement with North Yorkshire Council Trading Standards, and in regard to this incident the Trading Standards team are leading the activity with Hotpoint UK Appliances Ltd directly. CTSI believes the correct action in this case is for Hotpoint UK Appliances Ltd to work closely with North Yorkshire Council Trading Standards to further investigate the safety of the product, and if an issue is identified to take appropriate steps, including to instigate a product recall if necessary. CTSI recognises that OPSS as the National Regulator for product safety continues to support North Yorkshire Council Trading Standards to understand the true scale and risk of the problem, agree the actions needed to prevent any further harm or injury occurring, and the timescales in which this should happen. This must be done to ensure that consumers are being protected from any unsafe appliances in their homes. If OPSS find that appropriate action is not being taken by Hotpoint UK Appliances Ltd, or have concerns that the actions are not being taken with enough speed to protect consumers, they can use their powers to start corrective action. CTSI, along with local authority Trading Standards OƯicers, can work with OPSS to ensure the message around any such safety issue and recalls are implemented eƯectively and have the greatest impact. CTSI would also like to see OPSS look at the wider recommendations made in the report as we believe these require a national approach to address national issues. In the EU and Northern Ireland, it is now mandatory for manufacturers to report dangerous products on the safety business gateway and there is a consumer gateway where consumers can report dangerous products. To ensure that all consumers are protected this should be an option available to GB consumers. In conclusion, CTSI remains committed to ensuring that electrical products are safe, and that processes for keeping consumers informed of risks and dangers are robust to ensure that preventable deaths or deaths injuries are avoided.
Sent To
- British Standards Institute
- National Fire Chief’s Council
- North Yorkshire Council
- Office of Product Safety Standards
- Home Office
Response Status
Linked responses
8 of 7
56-Day Deadline
31 Jan 2025
All responses received
About PFD responses
Organisations named in PFD reports must respond within 56 days explaining what actions they are taking.
Source: Courts and Tribunals Judiciary
Report Sections
Investigation and Inquest
On the 17th of May 2023 I commenced investigations into the deaths of Champagauri and Dipak Bhatt. The investigations concluded on the 15th of November 2024 after inquests held over the 6th, 7th and 8th of November 2024. The inquests had the following short narrative conclusions: (a) Following a fire caused by an electrical fault in the tumble dryer, Champagauri Bhatt died from the resulting inhalation injury. (b) Following a fire caused by an electrical fault in the tumble dryer, Dipak Bhatt died from the resulting inhalation injury.
Circumstances of the Death
On the evening of 29th of March 2023 a fire caused by an electrical fault in the tumble dryer at Edgware caused Champagauri and Dipak Bhatt to die from inhalation injuries. There was a 10% chance the EMI filter caused the fire and a 90% chance the condensate pump caused the fire.
Copies Sent To
2. London Fire Brigade
3. Hotpoint Date: 06/12/2024
Similar PFD Reports
Reports sharing organisations, categories, or themes
Related Inquiry Recommendations
Public inquiry recommendations addressing similar themes
Consolidate and update emergency preparedness guidance
Grenfell Tower Inquiry
Outdated Emergency Preparedness Guidance
GM Resilience Forum tri-service plan reviews
Manchester Arena Inquiry
Outdated Emergency Preparedness Guidance
Guidance on Major Incident plan review frequency
Manchester Arena Inquiry
Outdated Emergency Preparedness Guidance
Review licensing guidance on event healthcare
Manchester Arena Inquiry
Outdated Emergency Preparedness Guidance
Department of Health to review Circular 71, clarifying Major Incident declaration terms
Hidden Inquiry
Outdated Emergency Preparedness Guidance
Data sourced from Courts and Tribunals Judiciary under the Open Government Licence.