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Posted: Wed Nov 28, 2012 8:25 am
by taz
Please do not confuse the certificate of conformity with periodic inspection. What you mention is a different matter.
Posted: Wed Nov 28, 2012 8:53 am
by rmca
I has not referring the periodic inspection, only why there is a 10 year stamp on new cylinders.
For what I read is:
"Module G (EC unit verification)
1. This module describes the procedure whereby the manufacturer ensures and declares that transportable pressure equipment which has been issued with the certificate referred to in point 4.1 satisfies the requirements of the Directive which apply to it. The manufacturer, or his authorised representative established within the Community, must affix the Π marking to the equipment and draw up a declaration of conformity."
"4.1. The notified body must affix its identification number or have it affixed to the transportable pressure equipment and draw up a certificate of conformity for the tests carried out. This certificate must be kept for a period of 10 years."
taz, is this why they are marked ten tears?
I didn't found the periodic inspection... then again I not an expert in this area...
Posted: Wed Nov 28, 2012 10:52 am
by David N
..
Posted: Wed Nov 28, 2012 2:28 pm
by taz
Thank you.
You are either a careful reader or have relevant experience.
Posted: Wed Nov 28, 2012 2:53 pm
by taz
rmca wrote:I has not referring the periodic inspection, only why there is a 10 year stamp on new cylinders.
For what I read is:
"Module G (EC unit verification)
1. This module describes the procedure whereby the manufacturer ensures and declares that transportable pressure equipment which has been issued with the certificate referred to in point 4.1 satisfies the requirements of the Directive which apply to it. The manufacturer, or his authorised representative established within the Community, must affix the Π marking to the equipment and draw up a declaration of conformity."
"4.1. The notified body must affix its identification number or have it affixed to the transportable pressure equipment and draw up a certificate of conformity for the tests carried out. This certificate must be kept for a period of 10 years."
taz, is this why they are marked ten tears?
I didn't found the periodic inspection... then again I not an expert in this area...
What you wrote does not mean that the equipment has a valid certification only for 10 years. It just means that the certificate, as is the case with most EU directives, must be kept for a period of 10 years so if a member state required it (apart from the Declaration of Conformity issued by the manufacturer) it should be available. The same goes for example for Notified Bodies, we are required to keep copies of all certificates issued together with all relevant documentation for a period of 10 years.
Posted: Wed Nov 28, 2012 3:00 pm
by rmca
Got it.
Thanks taz and David N
Posted: Wed Nov 28, 2012 9:19 pm
by rmca
This EU directive has to be transposed to national law in each member state, right?
And about the penalties? Are they country specific or is there another directive?
And what are they in your countries taz and David N?
Sorry about all the questions but I really would like to know... it's not the first time I have this discussion (nor would it be the last!) and I would like to get a complete picture this time.
Thanks for your patience :)
Posted: Thu Nov 29, 2012 1:03 am
by mattswe
Hi All
Have anyone really seen a written statement that ISSF will impose a 10year rule for air tubes?
Its not in the ISSF general rules from 2009 (or technical rules from swedish shooting federation, translation from ISSF documentation) nor the upcoming 2013 rules.
If I missed some documents where (if) this is written in, can someone specify the exact location of this information?
I'm trying to get information from SvSF (Swedish shooting federation) but dead silence. And, everyone seems to be referring to either EU directives or rumors. So, very hard to verify what is correct and what is just smoke...
br
Matt
Posted: Thu Nov 29, 2012 2:25 am
by David Levene
mattswe wrote:Have anyone really seen a written statement that ISSF will impose a 10year rule for air tubes?
As far as I can see, and I might be wrong, the only sanction mentioned is that under 2013 rule 6.7.7.1d you will be given "advisory recommendations".
Posted: Thu Nov 29, 2012 3:05 am
by RobStubbs
David Levene wrote:mattswe wrote:Have anyone really seen a written statement that ISSF will impose a 10year rule for air tubes?
As far as I can see, and I might be wrong, the only sanction mentioned is that under 2013 rule 6.7.7.1d you will be given "advisory recommendations".
Whilst David is correct, as far as I can see, countries can of course apply their own local laws on top of ISSF rulings, which may mean you will not pass EQ with a cylinder over 10 years old. It could also be considered a safety issue and again you could be refused.
I don't know what an advisory recommendation means in reality but you'd be asking for trouble putting it to the test (IMHO).
Rob.
Posted: Thu Nov 29, 2012 6:23 am
by taz
rmca wrote:This EU directive has to be transposed to national law in each member state, right?
Correct.
And about the penalties? Are they country specific or is there another directive?
I guess country specific. I can't help you any more though since I am an engineer and not a lawyer and my knowledge concerning penalties and such is limited.
And what are they in your countries taz and David N?
Sorry about all the questions but I really would like to know... it's not the first time I have this discussion (nor would it be the last!) and I would like to get a complete picture this time.
Thanks for your patience :)
Posted: Thu Nov 29, 2012 7:43 am
by Rover
Let's see if I've got it:
No one has heard of a problem with the cylinders.
The manufacturers are dating the cylinders to cover their ass.
Some silly bureaucrats are writing and enforcing rules over this.
SOME of us are spending hundreds of dollars for unneeded new cylinders.
SOME of us are wetting their pants.
Did I miss anything?
Posted: Thu Nov 29, 2012 7:58 am
by taz
That is one way to put it.
What would you suggest?
Pressure vessels
Posted: Thu Nov 29, 2012 9:04 am
by RobinC
Rover
I love it! Sensibly, you got it in one!
Sadly I live in the land of the Jobsworth
(explanation:- quote from official, sharp intake of breath followed by "can't pass that, its more than my jobs worth".)
So this situation arose a few years back, officials took it up with glee, after a while common sense then over came the officialdom and it faded into obscurity which is where it belongs, now its reared again, and we in the UK just know that however un neccessary this is, if its enforced any were it will be here!
I'm now even hearing of clubs that are enforcing this ruling, quoting insurance surrounded by a good quota of "jobsworth".
This silliness is because its applying regulations to sporting equipment which it was never intended to do, and still is not, and to protect from a problem that does not exist.
Technically the rules they are applying are not for air pressure vessels which I still believe for gun cylinders are exempt due to volume, but to transportable pressure equipment which again those regulations were never intended, if we are going to continue to split hairs those regs also include the pressure containg aspects of the gun as well.
Where will it end, interval pressure tests on firearms? They are not retested after proof, surely the same principle applies?
Rover, sadly your logic is correct, we will eventualy regulate ourselves out of a sport.
Robin
Posted: Thu Nov 29, 2012 10:17 am
by sparky
Richard H wrote:Seeing as the only failures that have actually occurred are due to manufacturing defects and failed long before 10 years maybe the ISSF should focus their attention on manufacturing and testing methods. If this is done truly for safety and to ensure we are self policed that would make far more sense then arbitrary times picked out of thin are which have no basis in evidence or science. If there is evidence or science then publish it so we can all see it.
It's a pretty crappy way to cover ones own ass too, now when one fails at let's say 7 years I can guarantee you a lawyer will stand there and say the ISSF, the highest body in shooting says that these cylinders are good for ten years. The cylinders have gone through the EC many times and were checked that they had not expired, yet my client was horribly maimed.
Yes I know that's bull but all the lawyer has to do is sway a jury that a big bad entity who has money and resources should have known, and indeed did know that there was a possibility of these failing they even anticipated it by writing a rule about it. Then explore how the hell they came up with ten years, not 7 or 5.
Bingo. By stepping in and taking responsibility for setting a standard rather than leaving it up to the individual competitor to worry about his own equipment, it looks like ISSF is also stepping in and assuming the liability from the individual competitor. I think this was a very poor decision and if an incident as you describe ever happens, could lead to some costly lawsuits for the ISSF and/or national governing bodies who adopt and enforce this rule.
Posted: Thu Nov 29, 2012 1:59 pm
by Rover
Taz. In reply to your question:
Stop putting dates on the cylinders; then there is nothing to enforce.
Since a defective cylinder would almost certainly burst while being filled and not on the firing line, that takes the stress off all but the owner.