gianaameri
gian @ gian.ameri.name
I really want to avoid corrupting this thread with CE and UK Health and Safety Executive (HSE) discussion and also, as you have subsequently recognised in another post, this thread is not about BOVs. However to address one of your points, which might mislead members who teach professionally in the UK, if your BOV has been tested in accordance with CE Harmonised Standard EN250 (the design and test standard for open circuit regulators), so long as the rebreather is also CE marked, then as a professional diver at work, which a diving Instructor is classed as if he/she receives remuneration for that work, you are compliant with related legislation (modifications excluded). With regards to the HSE diving inspectorate, with whom I frequently interface with on behalf of my clients to address complex diving operations that fall out with the UK Diving at Work Regulations, HSE is there to help diving contractors follow good dive management practice and that they comply with their legal obligations as employers of divers and that divers and diving supervisors do likewise. Also in the event of a diving accident at work, HSE is there to investigate the incident in the same way as the HSE would investigate a builder falling off a roof on a building site or someone loosing an arm in a saw mill. Thankfully the days of the industrial revolution working environment are long gone and we expect to return home safely from a days work and that includes professional divers and diving students under training. In my experience I have found HSE Diving Inspectors, all of whom are ex professional civilian or military divers, to be reasonable, pragmatic people and whilst of course I can not speak on their behalf, any diver at work who uses a none CE marked BOV will be able to convincingly argue that good practice is being followed and they have enhanced diving safety by using the BOV. This argument will be further reinforced if a CE marked off board bailout first and second stage regulator is available to revert to once the initial use of the BOV has been initiated.
This is in my and many others opinion an important safety related thread that has the potential to save life. I'm sure therefore that the majority of the membership will feel the same, please no more HSE / CE talk on this thread, by all means start a new one if you want to but lets not put people off this topic by unnecessary discussion on unrelated bureaucracy that bores the pants of most, including myself. No more shooting from the hip, lets stay on topic. Rgds Paul
Paul,
you got it wrong, I believe.
Anyone modifying their rebreather with a non-manufacturer approved and non manufacturer/Notified Body CE tested BOV is breaching CE.
EN250 only refers to the OC part of the BOV.
The CC part of the BOV needs to be tested as a unit with the original rebreather it is intended to be sold with in accordance to the applicable standard (not EN250, but EN14143).
I have no issue replacing my DSV with a BOV (if ISC does not supply a CE approved BOV with the Meg), but anyone who does that, if the BOV is not from the same manufacturer of the rebreather and tested and CE approved by that manufacturer and Notified Body, you are breaking CE.
The manufacturer may argue, with good reason, that you modified the rebreather with a non-manufacturer approved and CE tested part, and that the manufacturer is not liable.
Furthermore, your unit as an instructor is no longer CE as it is modified with manufacturer unapproved parts (you put a Golem BOV on a Meg, you lost CE).
Ask the HSE, and let us know, but the user has to know they are breaking CE and understand the implications and take responsibility for it (whether you/anybody feel the topic is boring is irrelevant because, like it or not, it is the regulations which apply to us in EU land).
Of relevance to the topic, APD makes an extra wide mouthpiece which may improve WOB over other non APD mouthpieces... if you put a Draeger Crown Strap AND the mouthpiece opening is smaller than the original APD mouthpiece, I see a potential for a CE issue on such a simple modification (but I would prefer to believe this is a grey area... only APD could say if using non-APD mouthpieces is an issue).
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