Ten Year Old Cylinder Rule

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RobinC

10 year rule

Post by RobinC »

I think some rationale needs to drawn into this situation. This is a matter of rule interpretation, and there is a slight ambiguity in those rules. I suggest you consult your respective national bodies to raise the issue with the ISSF who ultimately will have to rule on this.

2009 rules are available as a PDF file on www.issfnews.com

Two rules are in conflict.

Rule. 6.4.2.2. Prior to competition each shooters gun and equipment must be examined by the equipment control section to ensure that it conforms to ISSF rules. It does continue, but not relevent this.

Rule 6.2.2.8 is the rule quoted by David L regarding shooters responsibility for the cylinder being safe and certification being valid.

Does rule 6.4.2.2 over rule 6.2.2.8? I'm not a lawyer but have spent half my working life dealing with law, I think not, other wise rule 6.2.2.8 would not refer to the shooter having responsibility and not be necessary, it would just refer to safety requirement of the cylinder and would then be the responsibility of the inspectors.

The ISSF rules allow local safety rules to be added, as I have already stated I believe this issue has arisen because a local Jobsworth started it, it is not a check criteria in the ISSF rules.
Now the can of worms are open the repercussions are massive and I doubt the ISSF is aware of how big the issue could become.
This should be raised at high level in each country and the delegates made aware it could effect the prosperity of the whole sport.
Best regards
Robin
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Richard H
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Post by Richard H »

The ISSF doesn't really look at it as becoming a big issue because they really only concern themselves with the elite of the the sport for which this is not so much of a burden. The problem will come at the local level for which the ISSF has really demonstrated they could care less about over the years.
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Post by jimsoars »

The only real answer can come from the governing bodies. I have sent the following email to the USAS competitions department hoping for an interpretation of what official policy should be for US competitions. I could not find an equivalent place to ask the same question for ISSF.




There has been a long thread on a shooting forum about this rule:
Rule 6.2.2.8
It is the shooter’s responsibility that any air or Co2 cylinder has been certified as safe and is still within the validity date.

Various manufacturers have varying policies, and some have no policies. For example FWB has a blanket suggestion of replacement at 10 years. Pardini and Morini have no published recommendations.

Does rule 6.2.2.8 indicate that checking the validity date and verifying against manufacturer’s published data is to be accomplished and enforced by equipment control for all ISSF events?
This effectively bans all older guns from competition.

Or does 6.2.2.8 simply remind shooters of their responsibility for safe maintenance of their guns. This means that this should not be an equipment control checked and disqualifying item.


I am looking for the official position of USA Shooting regarding the checking and disqualification of air guns affected by this rule at USAS events.
dennisk1

ten year old cylinder rule

Post by dennisk1 »

I am new to TargetTalk and reentering competition shooting. I am presently trying to find a used 5 shot air pistol and am very concerned by this subject of cylinder dating and testing and parts availability. I am an engineer with chemical, mechanical, materials and safety background. I have read all of the posts on this subject and feel the concern of the posters, as well as their feeling that they may be getting ripped off by the manufacturers and ISSF. Yes, my following comments will be going after both of them.

Richard H on Feb 11, 2009 stated that small cylinders are exempt. He is totally right. The US Code of Federal Regulations title 49, section 180.209 table 1 states: "Any cylinder not exceeding 2 inches outside diameter and less than 2 feet in length is excepted from volumetric expansion test". In the US these cylinders do not have to be tested or retested.

The following URL will take you to the text on the government site.

http://ecfr.gpoaccess.gov/cgi/t/text/te ... .5&idno=49

The comments quoted from FWB about cylinder design is exactly what I would expect from from careful German engineers. These cylinders are way over designed and even with some corrosion due to moisture presence in air and CO2, they should last the lifetime of the pistol or rifle.

Robin C on Feb 11, 2009 stated in point 6 that some manufactures test some of the cylinders and stamps all of them with a test date. If they stamp them, they better all have serial numbers any they better test every last one of them and they must keep all the test documents for government inspection. Some of them do not stamp them and will pose a problem for ISSF - how will they know how old they are? If they can not tell, they will have to disqualify all of that manufacturer's guns. Craig E on Feb 11, 2009 brings up the concern that ISSF and all ranges should have concern over reloaders, customized pistols, and old guns. I add, what about cracked frames and slides, guns used with +P and +P+ loads, bulged barrels, and Glocks fired with soft lead slugs and then used with hardball. Does this mean that the ISSF and every range is going to do a 100% inspection of every gun to certify that it is safe and, in the case of airguns, that in-date cylinders are not bulged or dented let alone be out of date. If they are concerned about safety, let them do it all, or else shut up and leave it to the competitors who are holding the guns to be responsible for safety, as they have always been in the past.

Some manufacturers seem to be playing the part of money grubbing opportunists who are crying fire in a crowded movie theater. "The cylinders are not safe after 10 year + one day." They seem to obsolete airguns with minor "improvements" with enough other changes to make parts no longer interchangeable - including cylinders. I am presently looking for a used air pistol and because of the eyeopening posts here, there are some manufacturers that I will no longer consider. Since when do you pay over $2000 for a pistol only to be told that you only have five to eight years left on a new 10 year cylinder and after a few years have to worry about availability of parts. To me, these pistols are not worth a tenth of their value, if that. I should be able to give a fine quality $2000 pistol to my children or grandchildren after I have carefully used it for many years. Maybe it is time we started to boycott manufacturers who fail to make parts available in the future and who will not build cylinders with the care, engineering, and pride to have them last the life of the pistol. With modern corrosion resistant coating on strong aluminum alloys, this would be simple to any good materials engineer.

Maybe it is time international governments include the threaded connections on all micro cylinders in one international standard size like they do on larger gas cylinders. If they did this, we could buy generic standard cylinders when gun manufacturers played their game of obsolesence for profit. This would also allow extra cylinders at match sites so we did not have the problem of only one cylinder allowed in checked baggage.

Hopefully I have given the manufacturers and the IEEF enough reason to clean up their act and realize that they have responsibilities to the people who contribute to their existence.

Enough of my venting, to everyone else, please let me have your thoughts.

Safe and happy shooting!

Dennis
Guest Twenty

Post by Guest Twenty »

Let's go back to the subject of the RULES. Does this mean that somehow our cylinders will be checked at a match? Mine are CO2.
Ken O
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Post by Ken O »

Well said Dennis!

I also want to know which manufactors to avoid, so would appreciate it if they could be listed here.

I usually buy used, and would hate to buy a NIB that was almost 10 years old and the cylinder would need replacing befoe I even got to use it.
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Post by pilkguns »

I am finally getting caught up after my trip to Germany, and here are my thoughts on the matter. Lots of interesting statements in this thread. Some thought provoking, some obviously said without any thought.

.

First, as someone else mentioned, different countries have different rules enforced by the GOVERMENTAL regulatory agencies. This applies to the end users in their respective countries, and the manufacturers in their respective countries. Basically we have guns made in Austria, England, Italy, Germany and Switzerland. Switzerland’s regulatory body has given Morini a 20 year validation for their cylinders. So Morini is standing by their cylinders with a 20 year limit. Steyr in Austria, also has different government regulatory body certifying their cylinders and is not enforcing the “10 year rule” in Austria, but they are in Germany, (which also happens to be their biggest market) because non-governmental body, a SPORT regulatory agency, the Duetsche Schützen Bund (DSB) has taken the stand for safety, after reviewing concerns about cylinder issues and recalls from various German manufacturers.

Second, several people have mentioned that the American regulatory agency for cylinders, the DOT, exempts cylinders that are under 2 inches from inspection. This is thrown about as a “proof” that inspections are foolish and unnecessary for small cylinders. Actually the opposite is true. When the DOT guidelines were written years ago, the concept of small cylinders was only conceived for temporary use, where they would soon be discarded. This is certainly not the case today where we are talking about 10 and 20 year life spans.

Third, airgun cylinders can and do have pitting in them that render them unsafe. I have seen and have one cut in half here that was only about 4 years old when we discovered the pitting and cut it open to better inspect it. The pitting can come from either moisture or galvanic corrosion.

Fourth, there has been much talk of the alleged financial hardship incurred by having to buy a cylinder every 10 years and the fact that SCUBA cylinders, which cost roughly the same, have an indefinite lifespan. But that really isn’t a fair comparison. First look at a SCUBA tank. It is basically a big solid bottle with a separate, externally sealed valve body on one end that is easily removable with a rubber hammer. Airgun cylinders are much different. They are essentially tubes with an internally sealed valve assembly on one end, and another sealed assembly with a pressure gauge installed on the other end, a much more complicated device to inspect and recertify. SCUBA tanks in the USA* are required to have a visual inspection annually and a hydrostatic test every 5 years. So lets compare the SCUBA tank inspections with a the 10 year life span as required by the DSB at this time. In ten years time, you would have to have two hydros and 8 visuals (the other two would be done in conjunction with the hydro. Visual inspections of a SCUBA tank usually cost $10** , and hydros run $ 25-35 so there’s $130-$150 out of pocket expense that you would outlay over a 10 year period. And let’s not forget shipping costs. Visual and hydro inspections require that you take the SCUBA tank to the dive store or some other location to be checked. Because of the much more complex nature of an airgun cylinder, it requires special tooling to disassemble and reassemble, as well as special knowledge of the individual valving systems and pressure gauges. The average SCUBA tank shop is not going to be doing these tests, so they will have to be mailed to a specialist shop. Shipping at a minimum will set you back about 6 bucks maybe more. So lets say $6 X 9 years. Or $54 dollars, but wait, that’s only shipping one way, they are going charge that for the return too… so double that $108 for shipping. Now we are looking at a 10 year cost of $238 - $258 at a minimum for a 10 year period.

Before we leave this cost analysis, did I mention that airgun cylinders are much more complicated than a SCUBA cylinder to disassemble and reassemble? I wouldn’t consider taking a cylinder apart for less than $25 for the time alone. And let us not forget that sometime in that 10 year period, you are going to need to get that airgun cylinder rebuilt with at least new seals put into it, if not replacing the whole gauge assembly. If you have been doing the math, we are already beyond the cost of a new cylinder at the end of 10 years.
Oh, finally on this subject, don’t forget you probably will be out of use the cylinder for at least two weeks each year as well as your sending these back and forth. All in all, it’s my opinion that buying a new cylinder every 10 years is pretty cheap just in the normal cycle of things,

Fifth, the obsoletion of guns as cylinders age. Yes, this is a concern to me as an individual, but I don’t think it is very big one for most people. I recently offered for sale a bunch of FWB parts for their 300 and 65s arguably r two guns that are more numerous and popular than probably all the CA guns combined. Was there any interest in stocking up on these parts, even parts with known limited lifespans? Very little sad to say. Most people are going to shoot what’s new, what’s hot, not what’s practical or “more than good enough”. Don’t believe me? How many people do you really see using CO2 or SSP guns at matches anymore? Need I say more?

Sixth, FWIW, I don’t believe any of the manufacturers promoted or endorsed the 10 year rule in the DSB for direct financial reasons. Come on people, do you really think that selling a cylinder every 10 years is going to keep these guys afloat or make a big difference on their bottom line? Most people with a 10 year old gun have long since relegated it to the closet. I doubt if one in fifty are still being used after 10 years. See my paragraph above. I believe that they did it for an indirect financial reason, that in 10 years time some idiot could have done something stupid with his/her cylinder and 10 years was a good cut-off to keep the liability legalities at bay.

Seventh, yes, I know it's a pity that the 10 year old rule does'nt take into account guns that may have only be shot a few times, but there is no way of verifying this. Just like a used car, it could have been used by a grandma who only drove it to chuch on Sunday, or it could have been used by the who took it to the dirt track every Friday night. And while somewhat comparying apples to oranges, There is no way I would get on the interstate and drive 70 mph on tires that were 10 years old, even if they did look brand new, and no race track owner is going let your car pass inspection with old tires either.

*I can’t comment about other countries rules, since I don’t know them all.
** Yes, I know you normally get a “courtesy” fill after a visual inspection, a $4-6 value but they had to fill your tank anyway to check for leaks after reassembling so why would they waste the air?
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Post by Spencer »

Scott,

you have just gone up another notch or two in my estimation - a voice of reason might not win you a lot of friends in this debate, but goodonya!

Spencer.
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bruce
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Post by bruce »

Thanks Scott, well said.
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Post by RobStubbs »

Scott, nice reply but there are still a couple of issues. I have never bought a new gun with a cylinder that was made the same year I bought it. One year old is the norm but pretty sure my other gun cames with 2 year old cylinders. So that makes a 10 year rule into an 8 or 9 year rule. I wonder, are dealers only ever going to sell guns with new cylinders, i.e. made that year ? As a customer I wouldn't now accept anything over a year old - so they would need to be scrapped.

Second point, is still why can't cylinders be retested ? All well and good saying one cylinder - 100 $ / pounds to replace - but I have 5 of them so would rather pay half that amount for them to be retested.

As an aside, I have yet to have my cylinders checked; Not at intershoot in Holland, or our British Championships, and all were ISSF comps.

I will probably replace one or two next year anyway as they are 10 years old then and the old ones without a gauge.

Rob.
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j-team
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Post by j-team »

j-team wrote:
pilkguns wrote: I am also familiar with cylinder incidents from all major manufacturers.
OK

Let's get ALL the fact out here. Of the recorded failures, how many were due to corrosion or age?

And, how many were in relatively new cylinder (under 10 years) that were due to material/manufacturing flaws?
Scott,

I would still like an answer to this question...
jipe
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Post by jipe »

I have the same experience as Rob: newly bought cylinders (delivered with a pistol or sold separate) stamped with a pretty old date. The new rule will make these cylinders unaccepatble => the shop (you Scott) will have to sell "fresh" cylinders... at its own costs since manufacturers will probably not carry any replacement costs themselves.

About the number of people still using CO2 pistols (I cannot speak for rifles, I only shoot pistol), I see quite a lot of people using old top CO2 pistols like FWB C20, C25 and Steyr LP1. The new rule is less an issue for Steyr LP1 owners (CO2 or air) since there are new replacements cylinders available (CO2 owner can convert their pistol to air for a "reasonnable" cost). For FWB owners its much more a problem since there are no "fresh" cylinders available anymore, the only chance is to check the cylinders for the second 10 years period but for many of them, the 20 years (10+10) will soon be reached (1991 or 1992 pistols). Also, as already stated, many of these old CO2 pistols were recycled as club pistols for beginners/young shooters and many clubs do not have budget to buy new AP's.

About the costs of inspection/retest: is it really that expensive ? I doubt that of it I see that FWB (prices written in the FWB document from their official web site) can test steel cylinders for 40Euros (CO2) or 60Euros (air) including the corrosion check but do not allow the re-test/re-certification of aluminium cylinders. I do not see any reason why the re-test of an aluminium air cylinder would be much more expensive that the re-test + corrosion check of a steel air cylinder (I do not compare with CO2 cylinders that are indeed operating at a much lower pressure).

About the different rules in different countries: if the local rule is longer than 10 years, the ISSF+manufacturer new rule will overrule it for ISSF competitions. Another point, Steyr for instance doesn't make any country dependent difference: an Austrian owner with a local rule of 20 years will anyway have to replace its cylinders after 10 years since the document of Steyr says 10 years without any reference to a particular country.

About DSB rule: strange enough, Tesro not member of JSM, seems not to have a new 10 year rule (yet ?) !

There is still an un-answered question, safety: for at least for AP/AR cylinders, the wear is linked to the number of pressure cycles, not time and the difference in number of cycles undergone by a cylinder can vary in a factor of 30 to 1 between a top competitor (shoots once per day) and an occasional shooter (shoots once in a month => how can safety be garanteed with a cylinder validity rule defined in term of time since manufacturing ?

Finally, if a summarize the post of Scott: the bulk of AP/AR owner do not use their pistol/rifle during 10 years, after 10 years, the pistol/rifle is since a long time forgotten somewhere in one or another drawer => the 10 years ruie is not a problem ! It is only a problem for that (very) small percentage of shooter who... really shoot !
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Post by David Levene »

RobStubbs wrote:As an aside, I have yet to have my cylinders checked; Not at intershoot in Holland, or our British Championships, and all were ISSF comps.
The British Championships this year were held under ISSF 2005 rules. The 2009 rules had not been published when the programme and entry forms were issued so it would not have been possible to include any required rule deviations.

Out of interest, I bough 2 Steyr cylinders at the weekend for £70 each (normally £103). Both were under a year old, but only because I insisted. Most of the ones that were on sale were 3-4 years old.
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Post by SteveR »

David Levene wrote: Out of interest, I bough 2 Steyr cylinders at the weekend for £70 each (normally £103). Both were under a year old, but only because I insisted. Most of the ones that were on sale were 3-4 years old.
I'd taken a look at these too, as I have two LP5 cylinders that have 1 year left (bought second hand). You must have been either lucky or very persuasive as when I checked they were all around 4 years old... in the end I decided to hold off buying until things are more clear with the new rules.

I'm not sure if it was sound logic to hold off, as I guess the prices are only going to go up!
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Post by jipe »

David Levene wrote:Out of interest, I bough 2 Steyr cylinders at the weekend for £70 each (normally £103). Both were under a year old, but only because I insisted. Most of the ones that were on sale were 3-4 years old.
This is a real shame: Steyr (and almost all German/Austrian manufacturers) published/enforced this new rule... but to avoid to loose money, still try to sell their old cylinders to customers hoping that these people are not aware of the new rule !

All customers should look at the manufacturing date and refuse to buy not "fresh" manufactured cylinders just like they do when they buy fresh food.

Manufacturers will then soon discover that their new rule is a major problem for them too !
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Post by David Levene »

jipe wrote:
David Levene wrote:Out of interest, I bough 2 Steyr cylinders at the weekend for £70 each (normally £103). Both were under a year old, but only because I insisted. Most of the ones that were on sale were 3-4 years old.
This is a real shame: Steyr (and almost all German/Austrian manufacturers) published/enforced this new rule... but to avoid to loose money, still try to sell their old cylinders to customers hoping that these people are not aware of the new rule !
I think this was the retailer trying to sell old stock rather than the manufacturer.

I had already arranged to buy two 2 month old cylinders from Steyr's UK agent (Harry Preston) for the full price. When I saw him he suggested that I should see if I could get reasonably dated cylinders from the other retailer at the reduced price. That's what I call service; he lost a sale by suggesting I could buy cheaper elsewhere.
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Post by jackh »

This might ruin the used AP market.

My 2 cylinders for 480k2 are 1996 and 1997. Dang!
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Post by jipe »

jackh wrote:This might ruin the used AP market.

My 2 cylinders for 480k2 are 1996 and 1997. Dang!
Indeed: if you cannot find any newly manufactured cylinders for the Hammerli 480 (do not know if the cylinders of the current AP40 fits on it), then the value of all Hammerli 480 has suddenly dropped close to zero.
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Post by Richard H »

Thanks Scott for shedding light on the issue.

It's not that big of a problem you just divide the cylinder replacement cost by 10 and reduce the price accordingly for cylinders that are not new.

If the cylinder is 3 years old $175-(($175/10) x3)=$122.50. ($17.50/yr/cylinder or $1.45/month/cylinder)

I guess all cylinders will now be prorated. I assume this will effect the supply of pistol as dealers probably won't stock as many pistol or rifles that devalues just sitting on the shelf.
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Richard H
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Post by Richard H »

jipe wrote:
jackh wrote:This might ruin the used AP market.

My 2 cylinders for 480k2 are 1996 and 1997. Dang!
Indeed: if you cannot find any newly manufactured cylinders for the Hammerli 480 (do not know if the cylinders of the current AP40 fits on it), then the value of all Hammerli 480 has suddenly dropped close to zero.
Yes and no, the vast majority of people who shoot airguns don't shoot in sanction ISSF events, so this rule won't effect them, so they probably wouldn't care as long as the cylinder are still in good shape and hold air (yes some will so the market will be smaller).

As Scott pointed out the problem is the cost of examining the cylinders, its cheaper to get new than inspect old cylinders. Now if there aren't new cylinders available that cost changes, it would be worth having someone take them apart examine the cylinder and rebuild it. I guess they could certify the cylinder in writing. Maybe Scott can comment on this.

Hammerli was Swiss back then and it seems the Swiss are ok with 20yr life spans so it looks like you have another 10 years.
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