kip i'm not sure if i misread your post or your have picked up some info wrongly
anyone undertaking CEN1 and/or HTR1 after feb 2010 needs to have CPA1 included in their course, anyone already holding CEN1 and/or HTR1 will have until April 2012, or when the tickets run out if before this date to get the qualification, not sure exactly how it is going to be structured yet as we are looking at it at the moment, but it will include training/assessment on a flueless fire,
the need to use a FGA on an appliance is dependant on MI, some demand via service and or maintenance tasks that a FGA is used to confirm CO/CO2 ratio, or CO ppm, so it wont be date dependant whether you use one or not, that requirement has not/will not change. the prob arises on appliances that require it and it is done by someone who has not proved competance on using a FGA, (ie taking CPA1) these are the rules as i understand them, not my opinion, there are thousands of commercial guys who know far more about using a FGA than i ever will, but i am qualified to teach/assess CPA1 and therein is the problem the industry has, it is seen by many as a money making scheme rather than a safety thing, (why are cookers not included springs to mind if it is safety based)