Rebreather World - View Single Post - Discussion on How to get a CE Mark for a Rebreather

divetheworld · 3rd March 2007, 13:44

Quote: (Originally Posted by schford)

So I think what you are saying it that the wording in EN14143 is such that 61058 can never fully apply - so could not possibly be certified to apply?

Personal opinion.
Lets take a simple example of the scrubber. If you apply 61508 to the whole system as has been suggested, then how can a granule based single scrubber comply? In short, it can not. Ever. Remember that stuff about failure rates, SIL levels and MTTF that Alex talked about? Try applying that in mathematical form to a granule scrubber with repeatable results. Turns to faecies real quick. Hence the design of the DL rebreather.

So in order to certify, we have to take our own interpretation, document this and make it comply with what we can demonstrate is safe enough. Then be prepared to justify this in court should we need to. If a part of the Standard is impossible to comply with, then dont comply with it. Use due dilligence and risk assessments in the Technical Construction File but then you can not declare compliance with that Standard on the Declaration of Conformity. In essence, you can not pick and choose parts you want to comply with, then put the Standard number on your Declaration.

This is an overly simplified example to which you can argue for months over technicalities should someone wish to, but the spirit of what I am saying should get through.

Brent
normal guy, dives quite often

Up front note to all.
There are many aspects of this thread that I will not be able to make comment upon due to my profession and various Non Disclosure agreements that I am bound to, including those to Deep Life.
I also will not engage in bun fights either.

3rd March 2007, 13:44	#4 (permalink)
divetheworld Dive porn pimp Current Rebreather/s: Inspiration Classic Other CCR Other Rebreather/s: Not Bought Yet Inspiration Classic Inspiration Vision Classic Kiss Other CCR Join Date: Mar 2005 Location: Leeds, England Posts: 1,636	Re: Discussion on How to get a CE Mark for a Rebreather Quote: (Originally Posted by schford) So I think what you are saying it that the wording in EN14143 is such that 61058 can never fully apply - so could not possibly be certified to apply? Personal opinion. Lets take a simple example of the scrubber. If you apply 61508 to the whole system as has been suggested, then how can a granule based single scrubber comply? In short, it can not. Ever. Remember that stuff about failure rates, SIL levels and MTTF that Alex talked about? Try applying that in mathematical form to a granule scrubber with repeatable results. Turns to faecies real quick. Hence the design of the DL rebreather. So in order to certify, we have to take our own interpretation, document this and make it comply with what we can demonstrate is safe enough. Then be prepared to justify this in court should we need to. If a part of the Standard is impossible to comply with, then dont comply with it. Use due dilligence and risk assessments in the Technical Construction File but then you can not declare compliance with that Standard on the Declaration of Conformity. In essence, you can not pick and choose parts you want to comply with, then put the Standard number on your Declaration. This is an overly simplified example to which you can argue for months over technicalities should someone wish to, but the spirit of what I am saying should get through. Brent normal guy, dives quite often Up front note to all. There are many aspects of this thread that I will not be able to make comment upon due to my profession and various Non Disclosure agreements that I am bound to, including those to Deep Life. I also will not engage in bun fights either. __________________ Attitude and self praise is no reccomendation. Dont try to be a great man, just be a man and let history be the judge of you. *WWW.NARKEDAT90.CO.UK* *http://www.grpservices.com/pursuit/* Supporting Shearwater Research Products in Europe Last edited by divetheworld : 3rd March 2007 at 13:52.
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