[AD_ward9]

Quote: (Originally Posted by jmurba)

the fact that the submatix could get the marking where Paul was said it was not possible is unfair.

I think that we all should demand to our governements to clearly say that kiss style rebreather can be ec approuved !!!

then paul's rebreather would be EC markable...

Three points:

1. The Submatrix does not have a CE approval certificate: it is not a valid certificate. A valid certificate has to be issued by a PPE Notified Body accredited to EN14143, after the tests in the standard have been carried out. The Submatrix certificate is not that. I agree with you it is unfair, and the appropriate authority in Italy should be pressed to do something about this dangerous fraud.

2. To get KISS units approved, lobby the members of CEN SC7. We have already written to a SC7 member suggesting the KISS be approvable, even though our designs are non-KISS. Just now, a KISS unit can be approved as an SCR, by careful choice of orifice and gas.

3. If a KISS unit is approved, the monitoring electronics would still need to meet EN61508. The normal KISS electronics does not meet any SIL level, so this would have be resolved before the unit could be properly approved.

Alex

[caveseeker7]

I agree with you, Jean-Mi, but I think the situation is even worse.
That damn CE bs is written in the typical you-gotta-be-a-lawyer-to-read-it-without-getting-a-headache language, yet you gotta be an engineer to understand it. That's wrong, absolute bs.

There are plenty of fairly smart people here on the board, some with engineering backgrounds, and they can argue for pages wtf that pos standard says. And be nowhere closer to the truth by the time they're done.

If I understand Alex correctly there is some tosser missing to certify some substandandard mentioned somewhere hence so far none of the issued CE certifications are valid. Even though a lot of time and money has been spent on testing and certification by at least some companies.

Unless someone can proof otherwise I believe they did this in good faith, why in the world would anyone spend tens of thousands of whatever currency on CE certification knowing it wasn't valid? You could get that sticker printed for a few cents if fraud was the goal.

In light of this ridiculous situation it is mho that any company which sets up shop in Switzerland, some bazar in the middle east or anywhere else and says "screw CE" does the right thing.

"You need CE cert to sell inside the EC, but ... ooops, there is no one certified to certify.
For how long as that standard been around? A decade?
Someone give me a f***ing break.

[PhilSiswick]

Quote: (Originally Posted by jmurba)

Hi all,

I think that the discussion about EC certification is really important, it is a key point of the rebreather world.
I met paul a couple of years ago, and dived the rubis wreck a couple of years ago.
we met because paul was a member of the french draegerkiss rebrather mailing list I had created at this time.
at this time we were all making the first european kiss scr conversions, we all could have afford buddy insp but all chose to dive kiss style for personnal reasons, safety reasons .
Paul discoverered like all our group that kiss style diving was a good solution for us.
unlike most of us that only wanted to get means of diving, paul decided to spend time, money to design a kiss style rebrather and he did the job.

If I had not been interrested in electronics and microcontroler programing preferring making my own gauges, if Ihad not been really happy with my modified dolphin I would have bougth a revo

Discovering that a kiss style ccr rebreather had gained the EC marking (the submatix) paul like many of us here down tried to understand how come a kiss style rebreather could have gained the marking given that the EC standars forces the makers to design rebreather automaticaly maintening a breathable gas without diver control, what a kiss style rebreather can't do, even if some says that it can't ....

As paul certainenly did I tried to find the italian company that certified the submatix , not to blame the submatix , but just to understand....I got no reply to my questions and paul certainly did not get any reply either.....

I think all of that is unfair....

the fact that the submatix could get the marking where Paul was said it was not possible is unfair.

It is not acceptable not to be able to understand...

It is not acceptable that paul rebreather can't get the marking were the submatix got it.

As soon as we will have the answer to this questions this kind of thead will remind on the lists and foums....

I visited a couple of lists and read the same questions about the queer submatix certification.

the answers are not clear.

this is the problem

how come anyone can blame paul for beeing puzzled by this situation ?

I think that we all should demand to our governements to clearly say that kiss style rebreather can be ec approuved !!!


then paul's rebreather would be EC markable...


that's all

the fact that paul uses p ports and ray twin hoses is not a problem for EC... paul could machine anything....

I think that rebreather world and all the other european rebreather lists could cooperate to make a big pétition to defend the kiss

regards

jean mi

Hear, hear on all counts.

Cheers,

[PhilSiswick]

Quote: (Originally Posted by caveseeker7)

I agree with you, Jean-Mi, but I think the situation is even worse.
That damn CE bs is written in the typical you-gotta-be-a-lawyer-to-read-it-without-getting-a-headache language, yet you gotta be an engineer to understand it. That's wrong, absolute bs.

There are plenty of fairly smart people here on the board, some with engineering backgrounds, and they can argue for pages wtf that pos standard says. And be nowhere closer to the truth by the time they're done.

If I understand Alex correctly there is some tosser missing to certify some substandandard mentioned somewhere hence so far none of the issued CE certifications are valid. Even though a lot of time and money has been spent on testing and certification by at least some companies.

Unless someone can proof otherwise I believe they did this in good faith, why in the world would anyone spend tens of thousands of whatever currency on CE certification knowing it wasn't valid? You could get that sticker printed for a few cents if fraud was the goal.

In light of this ridiculous situation it is mho that any company which sets up shop in Switzerland, some bazar in the middle east or anywhere else and says "screw CE" does the right thing.

"You need CE cert to sell inside the EC, but ... ooops, there is no one certified to certify.
For how long as that standard been around? A decade?
Someone give me a f***ing break.

Stefan,

You're right. It could be error, it could be fraud. It doesn't matter if it isn't possible for anyone to comply anyway.

OK, do we (as RBW) want to get together to do something? I'd suggest attack on several fronts:

- Getting confirmation whether KISS units can meet the standard
- Getting confirmation that anyone exists who can fully certify a unit to the applicable standards (and what those standards actually are ;-)
- Getting some action on those units that don't meet or haven't been certified to the above

Alex seems to have done a lot of the ground work. There are a lot of European rebreather divers on here - if we work together, something could change (if only that people really understand what these standards mean).

Cheers,

[schford]

Quote: (Originally Posted by caveseeker7)

If I understand Alex correctly there is some tosser missing to certify some substandandard mentioned somewhere hence so far none of the issued CE certifications are valid. Even though a lot of time and money has been spent on testing and certification by at least some companies.

The point Alex made here was that the people that gave the Submatix their CE certificate are not authorisied to do so by the EU and so it is not valid.

The CE certificate for the Inspiration & the Ouroboros were issued by a PPE notified body and are completely valid.

[jmurba]

Quote: (Originally Posted by schford)

The point Alex made here was that the people that gave the Submatix their CE certificate are not authorisied to do so by the EU and so it is not valid.

The CE certificate for the Inspiration & the Ouroboros were issued by a PPE notified body and are completely valid.

Dear Schford,

I think that the validity of the submatix EC certificate is something interresting to discuss, but on the other hand something more important would be to act together to try to make things change, to obtain a clarification of the situation, a modification of the standard that states that the mccr are admitted in the european rebreatherworld (((-:

regards

jean mi

[schford]

Quote: (Originally Posted by PhilSiswick)

OK, do we (as RBW) want to get together to do something? I'd suggest attack on several fronts:

- Getting confirmation whether KISS units can meet the standard
- Getting confirmation that anyone exists who can fully certify a unit to the applicable standards (and what those standards actually are ;-)
- Getting some action on those units that don't meet or haven't been certified to the above

Alex seems to have done a lot of the ground work. There are a lot of European rebreather divers on here - if we work together, something could change (if only that people really understand what these standards mean).

Cheers,

I made a few phone calls and here is what I discovered - the view is standards are straight forward and the only thing that should matter is whether a unit is approved by a PPE notified body or not - if it is, it is CE approved.

Alex has his view about one aspect of the testing needing additional certification but it is not shared by the SC7 committee who set the standard or the PPE notified bodies that test against the standard.

If a company is currently a PPE notified body then they are approved to certify a Rebreather.

No one has currently tried to certify a KISS style rebreather(in CCR mode) but there was some doubt as to how it would maintain a breathable set point at depth and during ascent as the needed o2 injection rates differ drastically. If a change in standards is required then representations should be made to your countries representatives via the appropriate route for discussion in the SC7 committee.

Looking at the SC7 committee there is huge huge amounts of experience and skills there and I doubt if you can get much more of a professional opinion...

The SC7 Chair (convener) is Stefan Wiegand an engineer at Draegor we have 4 representative from the UK these are:

Martin Parker from AP
Gavin Anthony from Quinetiq (ex UK MOD labs)
Ian Himmens from ANSTI
Ian Maxwell form Interspiro

These guys all report back into the British Standards Committee (input from HSE, SITA trade associations etc)

The other names I could dig up were

Kore Segedal a physiologist from Norway.

The French and Italian delegates work for their respective test houses.

Two from Sweden representing the Navy and Interspiro.

If your in the UK then the place to feed ideas into is the BSI committee just like industry eg Kevin Gurr!

For those of you who dive Inspirations or Evolutions then it is worth knowing that if any unit should pass it would be yours as the European Norm came about when Martin Parker proposed that the Brits create a British Standard (Which later became the EU Norm). Which AP then drafted. I guess it was in their own interest to do this so they could actually sell the Inspiration!

[Nad]

Quote: (Originally Posted by seppu)

Personally I think Paul is the most honest of the European manufacturer not CE approved because he clearly say and write it.

Note: I'm not a rEvo owner!

Nad

personally i think matthias pfister,holger berghäuser and a handfull other have the same level."most honest"maybe you musst look a little bit more around.
note.i`m not a ron,tr300 or habanero owner![/quote]

Yeah ok, I forgot to write "one"of the most honest...

Nad

[PhilSiswick]

Quote: (Originally Posted by schford)

I made a few phone calls and here is what I discovered - the view is standards are straight forward and the only thing that should matter is whether a unit is approved by a PPE notified body or not - if it is, it is CE approved.

Many thanks for doing this leg work.

Quote:

Alex has his view about one aspect of the testing needing additional certification but it is not shared by the SC7 committee who set the standard or the PPE notified bodies that test against the standard.

OK, so although Alex's approach may be 'better' it's not correct or applicable in the strict definition of the approval process. That's nice and clear.

Quote:

If a company is currently a PPE notified body then they are approved to certify a Rebreather.

That's also nice and clear.

Quote:

No one has currently tried to certify a KISS style rebreather(in CCR mode) but there was some doubt as to how it would maintain a breathable set point at depth and during ascent as the needed o2 injection rates differ drastically. If a change in standards is required then representations should be made to your countries representatives via the appropriate route for discussion in the SC7 committee.

Looking at the SC7 committee there is huge huge amounts of experience and skills there and I doubt if you can get much more of a professional opinion...

The SC7 Chair (convener) is Stefan Wiegand an engineer at Draegor we have 4 representative from the UK these are:

Martin Parker from AP
Gavin Anthony from Quinetiq (ex UK MOD labs)
Ian Himmens from ANSTI
Ian Maxwell form Interspiro

These guys all report back into the British Standards Committee (input from HSE, SITA trade associations etc)

The other names I could dig up were

Kore Segedal a physiologist from Norway.

The French and Italian delegates work for their respective test houses.

Two from Sweden representing the Navy and Interspiro.

If your in the UK then the place to feed ideas into is the BSI committee just like industry eg Kevin Gurr!

That's very interesting. Does that mean that Kevin is on the BSI committee? Neither he nor Martin would be particularly interesting in sponsoring a rule change for KISS rebreathers, but maybe the manufacturers could get together to make that request.

Quote:

For those of you who dive Inspirations or Evolutions then it is worth knowing that if any unit should pass it would be yours as the European Norm came about when Martin Parker proposed that the Brits create a British Standard (Which later became the EU Norm). Which AP then drafted. I guess it was in their own interest to do this so they could actually sell the Inspiration!

My thinking exactly....

Thanks again for following this up.

Cheers,

[Ben Field]

Quote: (Originally Posted by PhilSiswick)

Neither he nor Martin would be particularly interesting in sponsoring a rule change for KISS rebreathers, but maybe the manufacturers could get together to make that request.

Maybe... but Jetsam KISS units are way behind APD and way ahead of Boris in numbers, I'm not sure they compete direclty with either.
Would CE'd Jetsam, rEvo, Submatics, Aquatek and anything else together add up to more than a pile of beans to APD? I think not.

Could someone publish the details of how to contact the UK BSI/CE committee?