submatix EC approval organisation

seppu · 22nd February 2007, 14:01

hi
sorry for me its the taste here.we can talk about the fake ce from seaway.thats a really fake,no problem.(the file comes from me)
but submatix work in germany so there must find a legal way to sell the breather.meg,revo and kiss sell the breather only for decoration to the eu or need third non eu contries(swisse).in my eyes is this more illegal than submatix.in germany we say"wer im glashaus sitzt der soll nicht mit steinen werfen"

the revodreamholder works brilliant with the shearwater.thanks for this piece of cake.also the revodream.
thanks sepp

paulraymaekers · 22nd February 2007, 14:24

Quote: (Originally Posted by seppu)

hi
in my eyes is this more illegal than submatix.in germany we say"wer im glashaus sitzt der soll nicht mit steinen werfen"
sepp

hello sepp, I don't agree at all!

as you can see on our website, we explicitely state that the unit is NOT CE, and can not be CE, and for that reason we do not sell it in the CE area!

I don't think there is a more correct way to do it, it is legal and PERFECTLY CLEAR for the customer/enduser! we don't tell the customer a lie, we tell him exactly what he has to expect and what the situation is.

telling the customer that he buys a unit that has a CE homologation, knowing that it is a fraud, for me that equals crime!

regards
paul

AD_ward9 · 22nd February 2007, 14:32

Quote: (Originally Posted by Dinspiration)

The CE is a pain for all engineers like Paul trying to develop a very good working rebreather. Instead of moving forward they are struggled with this CE feature fu***. At the end nobody of us cares about it. What we as users need are reliable, high quality very good working rebreathers.

CE is not a pain. Dying because some twit thought he could design a rebreather but has failure modes in it that kill people is a pain. To your family, to your friends. Read over the attachment to the post by CeeBee on "Always Know your PPO2 thread HERE so you know how much a pain that is, before you think of designing a rebreather.

Anyone competent designing a rebreather does a ton of testing. With those test results, if the thing is safe, it is easy getting a CE certificate.

Emphasis is on the phrase "if the thing is safe". Now, establishing that is not easy at all and involves a considerable amount of work. See the OR threads to see how much. Anyone who takes short cuts should not be selling rebreathers, because their economy kills people. That is, for the sake of a few pounds in their pocket, there will be a series of families deprived of their breadwinner.

Please do not whine about it being difficult to do things properly. CE standards are trying to protect users from incompetent companies, and we see many. If you think something particular in the standard is wrong, then post that and a solution, but frankly, I do not see much wrong with the safety level in the standard, especially as it requires compliance with EN61508 and EN12207.

Alex

paulraymaekers · 22nd February 2007, 14:43

Quote: (Originally Posted by AD_ward9)

CE is not a pain. Dying because some twit thought he could design a rebreather but has failure modes in it that kill people is a pain. To your family, to your friends. See the post by CeeBee on "Know your PPO2" thread so you know how much a pain that is.

Anyone competent designing a rebreather does a ton of testing. With those test results, if the thing is safe, it is easy getting a CE certificate.

Emphasis is on the phrase "if the thing is safe". Now, establishing that is not easy at all and involves a considerable amount of work. See the OR threads to see how much. Anyone who takes short cuts should not be selling rebreathers, because their economy kills people. That is, for the sake of a few pounds in their pocket, there will be a series of families deprived of their breadwinner.

Please do not whine about it being difficult to do things properly. CE standards are trying to protect users from incompetent companies, and we see many. If you think something particular in the standard is wrong, then post that and a solution, but frankly, I do not see much wrong with the safety level in the standard, especially as it requires compliance with EN61508 and EN12207.

Alex

hello alex, it is clear that I can only agree half: the current 14143 is clearly written with a specific unit in mind, at the moment that there was only one unit around that was working towards the new 14143

for example, certain parameters in the CE testing, like the WOB in positions you never dive, are not safety-related, but unit-proctectionism.

also, the fact that mCCR excludes CE certification: reality shows that mCCR is not more dangerous for the user than eCCR...

paul

**PhilSiswick** · 22nd February 2007, 14:55

Quote: (Originally Posted by seppu)

hi
sorry for me its the taste here.we can talk about the fake ce from seaway.thats a really fake,no problem.(the file comes from me)
but submatix work in germany so there must find a legal way to sell the breather.meg,revo and kiss sell the breather only for decoration to the eu or need third non eu contries(swisse).in my eyes is this more illegal than submatix.in germany we say"wer im glashaus sitzt der soll nicht mit steinen werfen"

the revodreamholder works brilliant with the shearwater.thanks for this piece of cake.also the revodream.
thanks sepp

Hi Sepp,

If I've understood you correctly, you're saying that it may be more illegal (or at least morally questionable) to circumvent CE by selling a unit via a third country, or for non-diving purposes, than it is to have a misleading CE certificate (i.e one for the unit you are selling, but not for the way that most users will use it).

I don't agree with you at all. Anyone buying a non-CE unit that doesn't claim to be CE knows that they are buying a unit without CE. That's fine - caveat emptor.

Someone who buys a unit with a CE marking will assume that it has been tested to European standards as a rebreather for diving, when it hasn't. That is misrepresentation and therefore fraud in the most obvious form and not very much different to what Seaway have allegedly done.

Just my 0.2p worth.

Cheers,

Ben Field · 22nd February 2007, 15:26

Quote: (Originally Posted by seppu)

sorry for me its the taste here.we can talk about the fake ce from seaway.thats a really fake,no problem.(the file comes from me)
but submatix work in germany so there must find a legal way to sell the breather.meg,revo and kiss sell the breather only for decoration to the eu or need third non eu contries(swisse).in my eyes is this more illegal than submatix.in germany we say"wer im glashaus sitzt der soll nicht mit steinen werfen"

Hi Sepp,

The thing is not everyone reads Rebreather World....

If I ask a normal OC diving member of my club which rebreathers are CE rated and hand them the advertising material from all known manufacturers they will honestly reply- Inspiration, Evolution, Dolphin, Azimuth, Seaway, Voyager and Submatics.

Now the fact that this exclusive bunch are not all CE marked equally is not obvious and that, (IMVHO) is the crime.

Buying in the full knowledge of a units lack of 3rd party testing (Meg KISS etc) is fine, you accept that and move on.

Buying in the full knowledge of a units CE mark and testing only to find when/if something happens on your <insert questionably marked rebreather here> it was not tested properly as an underwater rebreather but something completely different... a cheese tray for example...

I think everyone will agree that having a standard is a good thing, yes it is tedious to make sure you comply, particularly as technology has moved on past the grounds the standard was set in (MCCR compliance debate) and perhaps it needs revision?

At the end of the day, to sell something alluding to equal compliance is as I aready suggested- dangerous and perhaps criminal?

BEN

**Dave Sutton** · 22nd February 2007, 16:06

This is in interestign discussion and is amusing to me, as I treat rebreathers like airplanes: Some are "Certificated" and some are "Experimental". When I fly a "Certificated" aircraft it means it's been tested in accordace with a standard (Think CE) and when I fly an Experimental there is no doubt because there is a 4 inch tall marking on the side in block letters "EXPERIMENTAL" and that means that I fly it at my own risk. Rebreathers ought to be handled the same way. Either can be freely sold, it's just that the pilots expectations are different in one case versus the other.

There ought to be plenty of leeway for a similar setup with rebreathers, the easy one being to do what homebuilt airlplane makers do, sell them in pieces. Wait... oh yes! That's *exactly* how the KISS is sold... even into Europe...

It is a shame that a correctly designed mCCR cannot be CE certified, and there is no reason that they ought to not be certified. Some hardware will kill the user if mishandled (see airplanes), and there is a huge difference between offering *idiot proof* designs and *designs that meet their criteria* but require skillful use to be used safely. It's the CE that has to change, not the rebreather design in the case of the mCCR.

Bottom line is that right now I'll just expect far more from a certified rebreather than an experimental, but I want access to both.

The fake CE stuff is also pretty amusing... "Not for use underwater" would be a nice marking to see.

Dave

AD_ward9 · 22nd February 2007, 17:27

Quote: (Originally Posted by paulraymaekers)

hello alex, it is clear that I can only agree half: the current 14143 is clearly written with a specific unit in mind, at the moment that there was only one unit around that was working towards the new 14143

for example, certain parameters in the CE testing, like the WOB in positions you never dive, are not safety-related, but unit-proctectionism.

There has been at least one fatalitybecause counterlungs were not fixed down on a unit properly, floated above the diver in a certain position, with the result that the diver died. Based on that fact, I disagree with you: it is necessary to test the unit in each position. To do so is very simple and requires minimal investment: it is done with the unit only just submerged.

You do not need 3rd party testing. You just need a 3rd party audit of your testing. If you test things properly and report the results properly, the audit is very straight forward. Lack of accredited auditors is another topic ...

I understand EN14143:2003 is to have a new version come out soon ("soon" is a relative word, when it comes to standards). If you post here your specific proposals for a better standard, i.e. what exactly is not right with the present standard, then they may find their way to the people on the committee.

On the mCCR, why not propose exactly what is needed? Send it to the committee working on the next revision of EN14143:2003, framed in terms of what clauses of EN14143:2003 should change.

Dave's point below is smack on the nail. Designing something and building it, is usually only 20% of the way to finishing it. Uncertified rebreathers are experimental, unfinished projects. Fake CE certs do mean "We are defrauding you. This equipment is not fit for the purpose for which it is sold, namely underwater use."

Alex

Dinspiration · 23rd February 2007, 07:43

Hi

After all the discussions - Is it a fake CE? All the postings here in this forum are just personal opinions/statements from other rebreather users. The only evidence I would accept is a legal judgement on this. And this should be done for all manufacturers selling rebreathers with CE.

Quote: (Originally Posted by AD_ward9)

Fake CE certs do mean "We are defrauding you. This equipment is not fit for the purpose for which it is sold, namely underwater use."

Ben Field · 23rd February 2007, 08:43

Quote: (Originally Posted by Dinspiration)

After all the discussions - Is it a fake CE? All the postings here in this forum are just personal opinions/statements from other rebreather users. The only evidence I would accept is a legal judgement on this. And this should be done for all manufacturers selling rebreathers with CE.

Ok we are all entitled to an opinion, but you know what opinions are like? ar*eholes everyones got one...

I don't need a judge to tell me what is right and wrong, I can make that call based on facts, there is one rebreather CE mark, its- EN14143:2003

Do the units in question have EN14143:2003?

Without it, where are you left when things go wrong?

22nd February 2007, 14:01	#41 (permalink)
seppu i ko nix dafüa Current Rebreather/s: Other CCR Home Build Other Rebreather/s: Inspiration Classic Other CCR Home Build Join Date: Feb 2006 Location: bayern Posts: 196	Re: submatix EC approval organisation hi sorry for me its the taste here.we can talk about the fake ce from seaway.thats a really fake,no problem.(the file comes from me) but submatix work in germany so there must find a legal way to sell the breather.meg,revo and kiss sell the breather only for decoration to the eu or need third non eu contries(swisse).in my eyes is this more illegal than submatix.in germany we say"wer im glashaus sitzt der soll nicht mit steinen werfen" the revodreamholder works brilliant with the shearwater.thanks for this piece of cake.also the revodream. thanks sepp
(Online)

22nd February 2007, 14:24	#42 (permalink)
paulraymaekers rEvo's daddy Current Rebreather/s: rEvo Other CCR Home Build Other Rebreather/s: rEvo Other CCR Home Build Join Date: May 2005 Location: belgium Posts: 1,498	Re: submatix EC approval organisation Quote: (Originally Posted by seppu) hi in my eyes is this more illegal than submatix.in germany we say"wer im glashaus sitzt der soll nicht mit steinen werfen" sepp hello sepp, I don't agree at all! as you can see on our website, we explicitely state that the unit is NOT CE, and can not be CE, and for that reason we do not sell it in the CE area! I don't think there is a more correct way to do it, it is legal and PERFECTLY CLEAR for the customer/enduser! we don't tell the customer a lie, we tell him exactly what he has to expect and what the situation is. telling the customer that he buys a unit that has a CE homologation, knowing that it is a fraud, for me that equals crime! regards paul __________________ www.rEvo-rebreathers.com .... the earth is flat, Elvis is alive, and radial scrubbers give longer dwell time than axials...
(Offline)

22nd February 2007, 14:32	#43 (permalink)
AD_ward9 So much more to learn Current Rebreather/s: Other CCR Other Rebreather/s: Other CCR Join Date: Jun 2005 Location: Scotland Posts: 1,856	Re: submatix EC approval organisation Quote: (Originally Posted by Dinspiration) The CE is a pain for all engineers like Paul trying to develop a very good working rebreather. Instead of moving forward they are struggled with this CE feature fu*. At the end nobody of us cares about it. What we as users need are reliable, high quality very good working rebreathers. CE is not a pain. Dying because some twit thought he could design a rebreather but has failure modes in it that kill people is a pain. To your family, to your friends. Read over the attachment to the post by CeeBee on "Always Know your PPO2 thread HERE** so you know how much a pain that is, before you think of designing a rebreather. Anyone competent designing a rebreather does a ton of testing. With those test results, if the thing is safe, it is easy getting a CE certificate. Emphasis is on the phrase "if the thing is safe". Now, establishing that is not easy at all and involves a considerable amount of work. See the OR threads to see how much. Anyone who takes short cuts should not be selling rebreathers, because their economy kills people. That is, for the sake of a few pounds in their pocket, there will be a series of families deprived of their breadwinner. Please do not whine about it being difficult to do things properly. CE standards are trying to protect users from incompetent companies, and we see many. If you think something particular in the standard is wrong, then post that and a solution, but frankly, I do not see much wrong with the safety level in the standard, especially as it requires compliance with EN61508 and EN12207. Alex Last edited by AD_ward9 : 22nd February 2007 at 17:40.
(Offline)

22nd February 2007, 14:43	#44 (permalink)
paulraymaekers rEvo's daddy Current Rebreather/s: rEvo Other CCR Home Build Other Rebreather/s: rEvo Other CCR Home Build Join Date: May 2005 Location: belgium Posts: 1,498	Re: submatix EC approval organisation Quote: (Originally Posted by AD_ward9) CE is not a pain. Dying because some twit thought he could design a rebreather but has failure modes in it that kill people is a pain. To your family, to your friends. See the post by CeeBee on "Know your PPO2" thread so you know how much a pain that is. Anyone competent designing a rebreather does a ton of testing. With those test results, if the thing is safe, it is easy getting a CE certificate. Emphasis is on the phrase "if the thing is safe". Now, establishing that is not easy at all and involves a considerable amount of work. See the OR threads to see how much. Anyone who takes short cuts should not be selling rebreathers, because their economy kills people. That is, for the sake of a few pounds in their pocket, there will be a series of families deprived of their breadwinner. Please do not whine about it being difficult to do things properly. CE standards are trying to protect users from incompetent companies, and we see many. If you think something particular in the standard is wrong, then post that and a solution, but frankly, I do not see much wrong with the safety level in the standard, especially as it requires compliance with EN61508 and EN12207. Alex hello alex, it is clear that I can only agree half: the current 14143 is clearly written with a specific unit in mind, at the moment that there was only one unit around that was working towards the new 14143 for example, certain parameters in the CE testing, like the WOB in positions you never dive, are not safety-related, but unit-proctectionism. also, the fact that mCCR excludes CE certification: reality shows that mCCR is not more dangerous for the user than eCCR... paul __________________ www.rEvo-rebreathers.com .... the earth is flat, Elvis is alive, and radial scrubbers give longer dwell time than axials...
(Offline)

22nd February 2007, 14:55	#45 (permalink)
PhilSiswick Phil Siswick, Tango Current Rebreather/s: Evolution Other Rebreather/s: Inspiration Vision Join Date: Apr 2006 Location: Oxford, UK Posts: 991	Re: submatix EC approval organisation Quote: (Originally Posted by seppu) hi sorry for me its the taste here.we can talk about the fake ce from seaway.thats a really fake,no problem.(the file comes from me) but submatix work in germany so there must find a legal way to sell the breather.meg,revo and kiss sell the breather only for decoration to the eu or need third non eu contries(swisse).in my eyes is this more illegal than submatix.in germany we say"wer im glashaus sitzt der soll nicht mit steinen werfen" the revodreamholder works brilliant with the shearwater.thanks for this piece of cake.also the revodream. thanks sepp Hi Sepp, If I've understood you correctly, you're saying that it may be more illegal (or at least morally questionable) to circumvent CE by selling a unit via a third country, or for non-diving purposes, than it is to have a misleading CE certificate (i.e one for the unit you are selling, but not for the way that most users will use it). I don't agree with you at all. Anyone buying a non-CE unit that doesn't claim to be CE knows that they are buying a unit without CE. That's fine - caveat emptor. Someone who buys a unit with a CE marking will assume that it has been tested to European standards as a rebreather for diving, when it hasn't. That is misrepresentation and therefore fraud in the most obvious form and not very much different to what Seaway have allegedly done. Just my 0.2p worth. Cheers, __________________ Phil (WSKD 0001) I have always felt that the dive I am on is not nearly important as the dives I plan to be on the rest of my life. Tom Rose, 2007 The person who gets the farthest is generally the one who is willing to do and dare. The sure thing boat never gets far from shore. Charles A. Lindbergh www.hugsac.org.uk
(Online)

22nd February 2007, 15:26	#46 (permalink)
Ben Field CK+Shearwater Current Rebreather/s: Classic Kiss Other Rebreather/s: Sport Kiss Join Date: Aug 2005 Location: London, England Posts: 1,634	Re: submatix EC approval organisation Quote: (Originally Posted by seppu) sorry for me its the taste here.we can talk about the fake ce from seaway.thats a really fake,no problem.(the file comes from me) but submatix work in germany so there must find a legal way to sell the breather.meg,revo and kiss sell the breather only for decoration to the eu or need third non eu contries(swisse).in my eyes is this more illegal than submatix.in germany we say"wer im glashaus sitzt der soll nicht mit steinen werfen" Hi Sepp, The thing is not everyone reads Rebreather World.... If I ask a normal OC diving member of my club which rebreathers are CE rated and hand them the advertising material from all known manufacturers they will honestly reply- Inspiration, Evolution, Dolphin, Azimuth, Seaway, Voyager and Submatics. Now the fact that this exclusive bunch are not all CE marked equally is not obvious and that, (IMVHO) is the crime. Buying in the full knowledge of a units lack of 3rd party testing (Meg KISS etc) is fine, you accept that and move on. Buying in the full knowledge of a units CE mark and testing only to find when/if something happens on your <insert questionably marked rebreather here> it was not tested properly as an underwater rebreather but something completely different... a cheese tray for example... I think everyone will agree that having a standard is a good thing, yes it is tedious to make sure you comply, particularly as technology has moved on past the grounds the standard was set in (MCCR compliance debate) and perhaps it needs revision? At the end of the day, to sell something alluding to equal compliance is as I aready suggested- dangerous and perhaps criminal? BEN __________________ Know your PPO2, Pre-breath, Use checklists, Validate cells at 6mtrs, Use pure O2 at or near surface, Use a BOV, Don't dive Solo, Change Slime and Cells as recommended by Manufacturer and RTFM! Beware Fridge Suck! www.hugsac.org.uk
(Online)

22nd February 2007, 16:06	#47 (permalink)
Dave Sutton Diveshop of Horrors Current Rebreather/s: Sport Kiss MK 15.X rEvo Other CCR Azimuth Home Build Other Rebreather/s: Classic Kiss rEvo Other CCR Azimuth Home Build Join Date: Jun 2006 Location: Narragansett, Rhode Island and Hackettstown, New Jersey Posts: 2,689	Re: submatix EC approval organisation This is in interestign discussion and is amusing to me, as I treat rebreathers like airplanes: Some are "Certificated" and some are "Experimental". When I fly a "Certificated" aircraft it means it's been tested in accordace with a standard (Think CE) and when I fly an Experimental there is no doubt because there is a 4 inch tall marking on the side in block letters "EXPERIMENTAL" and that means that I fly it at my own risk. Rebreathers ought to be handled the same way. Either can be freely sold, it's just that the pilots expectations are different in one case versus the other. There ought to be plenty of leeway for a similar setup with rebreathers, the easy one being to do what homebuilt airlplane makers do, sell them in pieces. Wait... oh yes! That's exactly how the KISS is sold... even into Europe... It is a shame that a correctly designed mCCR cannot be CE certified, and there is no reason that they ought to not be certified. Some hardware will kill the user if mishandled (see airplanes), and there is a huge difference between offering idiot proof designs and designs that meet their criteria but require skillful use to be used safely. It's the CE that has to change, not the rebreather design in the case of the mCCR. Bottom line is that right now I'll just expect far more from a certified rebreather than an experimental, but I want access to both. The fake CE stuff is also pretty amusing... "Not for use underwater" would be a nice marking to see. Dave __________________ "Changes in Lattitudes, Changes in Attitudes, Nothing remains quite the same".... www.nobubblediving.com Last edited by Dave Sutton : 22nd February 2007 at 16:10.
(Offline)

22nd February 2007, 17:27	#48 (permalink)
AD_ward9 So much more to learn Current Rebreather/s: Other CCR Other Rebreather/s: Other CCR Join Date: Jun 2005 Location: Scotland Posts: 1,856	Re: submatix EC approval organisation Quote: (Originally Posted by paulraymaekers) hello alex, it is clear that I can only agree half: the current 14143 is clearly written with a specific unit in mind, at the moment that there was only one unit around that was working towards the new 14143 for example, certain parameters in the CE testing, like the WOB in positions you never dive, are not safety-related, but unit-proctectionism. There has been at least one fatalitybecause counterlungs were not fixed down on a unit properly, floated above the diver in a certain position, with the result that the diver died. Based on that fact, I disagree with you: it is necessary to test the unit in each position. To do so is very simple and requires minimal investment: it is done with the unit only just submerged. You do not need 3rd party testing. You just need a 3rd party audit of your testing. If you test things properly and report the results properly, the audit is very straight forward. Lack of accredited auditors is another topic ... I understand EN14143:2003 is to have a new version come out soon ("soon" is a relative word, when it comes to standards). If you post here your specific proposals for a better standard, i.e. what exactly is not right with the present standard, then they may find their way to the people on the committee. On the mCCR, why not propose exactly what is needed? Send it to the committee working on the next revision of EN14143:2003, framed in terms of what clauses of EN14143:2003 should change. Dave's point below is smack on the nail. Designing something and building it, is usually only 20% of the way to finishing it. Uncertified rebreathers are experimental, unfinished projects. Fake CE certs do mean "We are defrauding you. This equipment is not fit for the purpose for which it is sold, namely underwater use." Alex Last edited by AD_ward9 : 22nd February 2007 at 17:37.
(Offline)

23rd February 2007, 07:43	#49 (permalink)
Dinspiration Custom Title Allowed! Current Rebreather/s: Inspiration Classic Other CCR Other Rebreather/s: Not Bought Yet Other CCR Join Date: Dec 2005 Location: Switzerland Posts: 213	Re: submatix EC approval organisation Hi After all the discussions - Is it a fake CE? All the postings here in this forum are just personal opinions/statements from other rebreather users. The only evidence I would accept is a legal judgement on this. And this should be done for all manufacturers selling rebreathers with CE. Quote: (Originally Posted by AD_ward9) Fake CE certs do mean "We are defrauding you. This equipment is not fit for the purpose for which it is sold, namely underwater use." Last edited by Dinspiration : 23rd February 2007 at 07:47.
(Offline)

23rd February 2007, 08:43	#50 (permalink)
Ben Field CK+Shearwater Current Rebreather/s: Classic Kiss Other Rebreather/s: Sport Kiss Join Date: Aug 2005 Location: London, England Posts: 1,634	Re: submatix EC approval organisation Quote: (Originally Posted by Dinspiration) After all the discussions - Is it a fake CE? All the postings here in this forum are just personal opinions/statements from other rebreather users. The only evidence I would accept is a legal judgement on this. And this should be done for all manufacturers selling rebreathers with CE. Ok we are all entitled to an opinion, but you know what opinions are like? areholes everyones got one... I don't need a judge to tell me what is right and wrong, I can make that call based on facts, there is one rebreather CE mark, its- EN14143:2003 Do the units in question have EN14143:2003? Without it, where are you left when things go wrong? __________________ Know your PPO2, Pre-breath, Use checklists, Validate cells at 6mtrs, Use pure O2 at or near surface, Use a BOV, Don't dive Solo, Change Slime and Cells as recommended by Manufacturer and RTFM!* Beware Fridge Suck! www.hugsac.org.uk
(Online)

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