Functional Safety, Human Factors and General Safety Discussion (Moved from Mk VI)

[gianaameri]

Tell you what Gian. I'm more inclined to trust Paul who does this for a living ... and has a vested interest in not getting his ass sued...

Regards

You can then quote Paul on your Ph.D. thesis as reference.

I believe what Dr. Anthony of QinetiQ states quite clearly in the video presentation: "Diving re-breathing apparatus: Testing and standards, UK/EU Perspective."

He is very reputable as well.

Surely it is legal to sell rebreather as they are sold (they are indeed sold regularly as we all know), but I put it to you, is it moral and ethical not to clearly inform the user if the product does not meet Functional Safety (i.e. Clause 5.13.1 of the current rebreather standard EN14143:2003)?

 

[paulraymaekers]

Tell you what Gian. I'm more inclined to trust Paul who does this for a living ... and has a vested interest in not getting his ass sued...

Regards

no worries, it's just twisting words

if anyone is interested, just read the PPE directive, it's all there

it is not mandatory to follow EN14143:2003, in order to get a legally correct CE type approval of a rebreather


added: a summary of the parts in the PPE directive that explain the route of the 'technical file' approved by the Notified Body

 

[gianaameri]

no worries, it's just twisting words

if anyone is interested, just read the PPE directive, it's all there

it is not mandatory to follow EN14143:2003, in order to get a legally correct CE type approval of a rebreather

Sure it is not mandatory (you would not be able to sell rebreathers otherwise, but you do).

I fully agree.

That is what Dr. Anthony says in the video presentation: "Diving re-breathing apparatus: Testing and standards, UK/EU Perspective."

You can get a supermarket bag a CE mark, but it won't meet Functional Safety (i.e. Clause 5.13.1 of EN14143:2003).

The problem is that unless someone tells the user that the machine does not meet Functional Safety (and despite the marketing slant it ain't really as safe or safer than OC...), then the poor diver behaviour is predicated on the wrong information.

It is a question of ethics and morality.

 

[Mr Walker]

I answered your question and now you run because you are unable to put forward a counterargument.

You are shifting responsibility for the product and the manual on the instructor.

The instructor has no way of knowing what the SIL Level and probability of failure of the machine is, and is in no position to communicate it to the student.

My MOd 1. instructor at the end of the course he told me to "Dive Safe!"

What, on a rebreather???

I'm not running, you're imagining things... since way back...

It was just a simple statement that if you can't give the only intelligent answer to my question (YES) there is no way this discussion is going to do anybody any good. Best to end it now. That's all. Get that?

/nils

 

[gianaameri]

I'm not running, you're imagining things... since way back...

It was just a simple statement that if you can't give the only intelligent answer to my question (YES) there is no way this discussion is going to do anybody any good. Best to end it now. That's all. Get that?

/nils

It would be unethical for me to answer YES.

I must be stupid then, but I prefer it like that.

 

[Mr Walker]

It would be unethical for me to answer YES.

I must be stupid then, but I prefer it like that.

That could be the reason why counter arguments are such a waste on you, possibly...

Dive safe now!

/nils

 

[gianaameri]

That could be the reason why counter arguments are such a waste on you, possibly...

Dive safe now!

/nils

You have put forward no counterarguments to my arguments.

Dive safe!

 

[GLOC]

From the proceedings (which are a bloody good read for all technical divers): Technical Diving Conference Proceedings. and the section over which Gavin presided.

In 1989, the EU issued the PPE Directive 89/686/EEC, which over the next decade was amended by 93/95/EEC, 93/68/EEC, 96/58/EC and 98/37/EC. The outcome of the PPE directive, and the subsequent amendments, was to bring some clarity and classification to the requirements and performance of diving PPE. The generic requirements of diving PPE are to:

• Protect the diver from hazards of extreme environment e.g. Protect from drowning, temperature and provide ability to work
• Control and protect against inherent hazards with PPE e.g. With rebreathers protect against hypoxia, hyperoxia and hypercapnia
• Reduce hazards to So Far As Is Reasonably practical (SFAIR) e.g. Cost-effective in terms of providing PPE against cost of testing and certification.

In order to achieve this, PPE is classified at different levels according to the protection it is required to provide (Table 1) and the certification is based on either a ‘Technical File’ or by complying with a harmonised European Standard (EN - European Norm). In either case, a comprehensive series of tests need to be undertaken. The most pertinent PPE standards for diving equipment are open-circuit demand regulators EN 250 (4), nitrox regulators EN 13949 (5), buoyancy compensators EN 1809 (6) and diving bebreathers EN 14143 (7).

I am going to ask that a line is drawn under the discussion on CE markings, gradings, SIL and CE compliance because Gian you have your views which appears to be contrary to every one else. Furthermore, the continued discussions add nothing to the discussion on what lessons can be learned from this unfortunate incident.

Regards

 

[gianaameri]

"Reduce hazards to So Far As Is Reasonably practical (SFAIR) e.g. Cost-effective in terms of providing PPE against cost of testing and certification."

A feature in the machine which prevents it from being dived with no scrubber surely can't be that costly and fits the PPE Directive criteria above as well as the Functional Safety criteria.

It would kill two birds with one stone, for little cost.

If it has not been thought before this fatality, it can be implemented for the future - maybe this is a lesson to be learned.

 

[AD_Ward9]

Thanks for providing those figures for your theoretical rebreather, I say it this way because there is nothing on the market to buy and I do not want this thread to show that you can do something and bring it to market when nothing is actually there.

As you have nothing to market, there are likely to be additional costs to the ones above and the 2nd tranche of savings are only there if you have a second system to market and sell.

I don't want to get into the mud-slinging that will likely develop re: a PDF based CCR, but you do show the concept that by having additional markets it is possible to leverage savings across the certification requirements. Until the CCR is available, it is all theory.

Nothing to market? I don't know if you have been leant on or what, but have you seen the recent factory pictures in the OSEL gallery and Facebook, as well as reports of those with the basic rebreather over the past 2 years?

We are not aware of any issues with the commercial or military versions of the rebreather and we shipped all those orders on those units. OSEL shipped all original $995 Apoc orders, and most of the conversions (there is a backlog again due to us switching one supplier to ensure top quality, which we are working to clear).

The only model in the original set that has not shipped to end customers is the iCCR, for reasons related to the bail out actuator reliability - in the context of the present discussion, that is simply extra cost to that development.

You asked me for the costs. I gave you the costs. If you did not want to have the costs for an honest purpose you should not have chased me for them. The Apoc costs being presented openly may cause some who have spent a fraction on certification via less stringent Notified Bodies, but that is not a reason to lambast me for answering your question.

Alex

 

[Mr fish]

Nothing to market? I don't know if you have been leant on or what, but have you seen the recent factory pictures in the OSEL gallery and Facebook, as well as reports of those with the basic rebreather over the past 2 years?

We are not aware of any issues with the commercial or military versions of the rebreather and we shipped all those orders on those units. OSEL shipped all original $995 Apoc orders, and most of the conversions (there is a backlog again due to us switching one supplier to ensure top quality, which we are working to clear).

The only model in the original set that has not shipped to end customers is the iCCR, for reasons related to the bail out actuator reliability - in the context of the present discussion, that is simply extra cost to that development.

You asked me for the costs. I gave you the costs. If you did not want to have the costs for an honest purpose you should not have chased me for them. The Apoc costs being presented openly may cause some who have spent a fraction on certification via less stringent Notified Bodies, but that is not a reason to lambast me for answering your question.

Alex

Please dont start the same old shite ,
or do i need to speak to Lord Clarke once again :
as i seem to have lost my copy of his Delivery to you :nono:

 

[GLOC]

Alex,

I didn't mean to lambast you and I appreciate you providing the costs so that the community can see the sorts of costs involved. I haven't been leant on and am well aware of the PR saying what has been happening (I do follow the OSEL FB page). The 'theoretical' is because, as you say, the iCCR is not available and if you can provide evidence of the military and commercial units in use, it is the same thing. I know that the mil units might be harder to prove, but surely the commercial units, if they are the safest CCR out there, the information would be publicly available.

As I said, I don't want this thread to turn into a pdf fest or an argument over whether the units exist 'in the wild' as that is not what the thread is about.

Regards

 

[MeRodent]

6. No company/person/third-party should claim that a life-support rebreather product for recreational purposes meets "EN14143:2003" when it does not (i.e. if it lacks of all things Functional Safety).
7. If a product lacks the Functional Safety prescribed by the current standard, then it should state clearly so on the product, and user informed consent ought to be obtained prior to the sale and/or use.

So does anyone claim to meet EN14143:2003? Or are you claiming that because they meet CE that they must have gone the EN14143:2003 route?

Ie it seems that it is actually possible to receive CE certification without needing to meet EN14143:2003.

 

[Clare]

Gian. You have had several users ask you to back off a bit. I'll add my voice to them. Give it a rest please.

 

[GLOC]

I've moved the previous 2 posts to a new thread 'Ways to improve CCR (system wide)' in General Diving.

Regards

 

[gianaameri]

So does anyone claim to meet EN14143:2003? Or are you claiming that because they meet CE that they must have gone the EN14143:2003 route?

Ie it seems that it is actually possible to receive CE certification without needing to meet EN14143:2003.

Yes, it is possible to achieve CE including for a supermarket bag. Dr. Anthony explains it very well in the video presentation.

Whichever route you take, a Technical File is still required.

That is not the point.

The issue is that once you have obtained CE using a route which allows you to circumvent the Functional Safety requirement of the current rebreather standard (i.e. what most manufacturers have done), what do you do?

A. You tell your clients or potential clients.
B. You keep quiet about it.
C. You claim that it meets "EN14143:2003" when it does not (i.e. you have taken a shortcut and circumvented the requirement so it cannot meet EN14143:2003, but yet you claim it does)

The ethical and morally correct thing to do is to inform your client and potential clients.

As to A. - no rebreather manufacturer that I know of informs their clients and potential clients that they have taken the short-cut AND the product lacks Functional Safety (i.e. not meeting Clause 5.13.1 of EN14143:2003).

As to B., all keep quiet about it, including HSE who sits on the TC79 UK Rebreather Standard Making Committee and is responsible for Health and Safety in the UK.

As to C., if I am not mistaken, GLOC has posted links (refer to those links) to claims of products meeting EN14143:2003 which would not be entirely true unless those who make the claim can show a SIRA/TUV Certificate of Conformity to EN61508 (i.e. Functional Safety to a level of at least SIL 1 to conform to Clause 5.13.1 of EN14143:2003).

It is about morality, ethics, disclosure, and proper information to give to users in respect of a seriously dangerous product.

 

[Simon Mitchell]

Nothing to market? I don't know if you have been leant on or what, but have you seen the recent factory pictures in the OSEL gallery and Facebook, as well as reports of those with the basic rebreather over the past 2 years?

We are not aware of any issues with the commercial or military versions of the rebreather and we shipped all those orders on those units. OSEL shipped all original $995 Apoc orders, and most of the conversions (there is a backlog again due to us switching one supplier to ensure top quality, which we are working to clear).

The only model in the original set that has not shipped to end customers is the iCCR, for reasons related to the bail out actuator reliability - in the context of the present discussion, that is simply extra cost to that development.

You asked me for the costs. I gave you the costs. If you did not want to have the costs for an honest purpose you should not have chased me for them. The Apoc costs being presented openly may cause some who have spent a fraction on certification via less stringent Notified Bodies, but that is not a reason to lambast me for answering your question.

Alex

Oh for God's sake Alex,

I don't know where to start with this post. Perhaps with the irony of you questioning Gareth's honesty?

From a recreational rebreather point of view the iCCR was the product designed to revolutionise rebreather safety and it is not currently on the market. "Nothing (meaningful) to market" is therefore a very apt description for those of us diving rebreathers for fun. Your basic loop chassis that you have been flogging for divers to modify is completely irrelevant to your campaign for safety. A homebuilder's chassis is not and never was what the "open revolution" safety project was all about (indeed, it is probably the antithesis of it)! When the iCCR works and it is being sold then you will have every right to behave petulantly when someone suggests that your flagship product is still not available. Until then....

As for: "...not aware of any issues with the commercial or military versions of the rebreather and we shipped all those orders on those units....". If we unravel the spin, don't you mean we developed a few prototypes and sent them to the company that commissioned the project? You seem to be trying to make it sound like you manufacture these products and sell them to end users who order them. In fact, I can find no evidence that the company (which isn't you) who plan to manufacture the umbilical rebreather actually has them for sale yet. Not saying they aren't coming, or that they won't be any good.... but the reality is not quite as you portrayed it.

Gareth wasn't "lambasting" anyone, or asking dishonest questions. I think his "not to market comment" puts useful perspective on your claims around the cost of producing a "safe" rebreather. Specifically, you don't currently offer that rebreather for sale because it is not working (and that has been the case for a variety of reasons for over 5 years now), and we therefore don't have any idea how safe it will actually be in the real world. It thus remains difficult to evaluate the benefit of all that expenditure.

Simon M

 

[Ben Field]

You are writing non-sense, but YES people use "suicide-pact rope" and do all sort of stupid things and get away with it - often not.

Sorry but I am NOT writing nonsense

You simply cannot say "often not", often implys greater than 50% IMO, so you are saying dangerous activities lead to death/injury more than half the time!

Clearly thats wrong, this weekend millions of people will go Diving, hangliding, climbing, mountainbiking, solo freeclimbing, wingsuit proximity flying etc etc and only a very small percentage will get hurt.

All are activities where you are one tiny mistake from injury or death- QED Skill, Prep and Luck works "most" of the time, even if the activity is lethal.

Diving badly designed (In Your Opinion) rebreathers works "most" of the time too.

You have a very poor impression of instructors knowledge if you believe that none of them know the weaknesses of the units they teach- FWIW many of them are on here reading your thoughts!
Frankly if my instructor hadn't know his facts and figures I wouldn't been happy paying for his training- you did interview your instructor before just handing over the cash didn't you?

 

[gianaameri]

You have a very poor impression of instructors knowledge if you believe that none of them know the weaknesses of the units they teach- FWIW many of them are on here reading your thoughts!

They are reading my thoughts because these great experts of yours are DEAD.

I believe generally instructors and students do not fully appreciate the risk they are actually taking.

There is a gap between perceived risk and actual risk.

This leads amongst other things to excessive risk taking and bad decisions and Human Error.

If you are lead to believe a rebreather is safer or as safe as OC, then you will just dive it same as OC, with that frame of mind.

If you realise how much more risky is than OC, then maybe on a 10 - 12 meter dive - as this one we discuss appears to be - you will not dive it at all, and leave it for dives where as a tool is more appropriate (long cave penetrations, deeper than 50 meter dives...).

But you are right, people don't always die and sometimes get away doing really senseless things.

On this one, the result was a fatality.

 

[Ben Field]

They are reading my thoughts because these great experts of yours are DEAD.

So now the dead are reading CCRX? (Might explain the increase in members Randy? ;-)

I believe generally instructors and students do not fully appreciate the risk they are actually taking.

Then it is the instructors you should be speaking to but do you have anything to tell them they should not already know.... No, nothing you've mentioned recently isn't public knowledge.

If you choose cheap instruction from the first person you find on Google you deserve what you get. The choice of instruction is as critical as that of rebreather.

On this one, the result was a fatality.

On this ONE, one death is terrible obviously but one doesn't make a statistic! We've got pages of discussion and conjecture because One person may have left the scrubber out. We've had rebreathers for 100years with the last 25-30 they've been available "recreationally" and so far (statistically) one person left the scrubber out.... lets all beat ourselves over the danger of rebreathers, thats a productive reaction :deadhorse