submatix EC approval organisation

**PhilSiswick** · 23rd February 2007, 09:57

Quote: (Originally Posted by Ben Field)

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?

Agree - I have my opinion and used that to inform my choice of a unit. I chose one that was certificated against EN14143:2003.

Anyone who certifies a unit against another standard, prints their own certification or bases their certification on only one component of their unit meeting CE, is misleading customers in a potentially illegal way.

I also agree strongly with Dave - if you buy a non-CE unit, you know you're buying something that is not CE certified. That's not bad in itself, as long as you know that.

Cheers,

guinderi · 1st March 2007, 20:43

ok I havent' talked about the story that I have certified a rebreather like a breather surface use!!!!that's very wrong.
I said that The rebreather is not certificable by a notified body because the rebreatrher is not on the list of the "MACHINERY DIRECTIVE".
So if youj want a Ce certification from a notified body, they test the machine according to all the rules applicable, also the EN 14403 2003, but they follow a path of certification like (similar OK) a surface-use breather (Like those that are in use for the fireman).
That's all.
So in this case the LOW(and nothing else), the Machine Directive, said that the manufacturer can Certificate CE the rebreather under his lonely responsibility acccording all the rules ,comprensive of EN 14403-2003.
But now, who can say if the manifacturer is goin on with the correct path of certification, we don't need a therth party like a notified body, like the LOW said.
So wwe have got a "certification CE PATH".
we have studied all the rules applicable.
we have controlled all the parts of which a rebreather consists, we have controlled the certification CE of all the parts and their safety and if they have a correct functioins according with all the rules under the supervision of us and very high specialized underwater personnel.
All these controlls took place in our site in Genoa.
Than we have tested the safety (CE CERTIFICATION IS FOR SAFETY CERTIFICATION and nothing else remember!!!!!!)
We also have tested the correct use of the rebreather only in underwater safety test in Genoa and in sardinia.
Than we have got all the test according also the EN 14403.
Than we have write a Technical handbook according the "MACHINERY DIRECTIVE" in which we have reported all "The Path of Certification"
Than we have write a "USER HANDBOOK"or a"OWNER MANUAL" (LIKE DO YOU LIKE) in copliance,EVER, with "MACHINERY DIRECTIVE" in which we described
"THE SAFE USE OF REBREATHER FOR UNDERWATER USE ONLY" and nothing else.
Than we have controlled ,together the manufacturer, all the steps we have got in safety.
Then only now IT WAS POSSIBLE TO CERTIFICATE THE REBREATHER" THE FAMOUS "CE CERTFICATION " .
The CE certification is always under the liability and under the responsibility of the manifacrurer, and the certificate is ONLY TO ENSURE THE SAFETY OF THE MACHINE.
NOTHING OF FAKE; NOTHING OF FALSE!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! !!!
DO NOT OFFEND THE ITALIANS, MY PERSON AND MY PROFESSIONALITY PLEASE.
WE ARE NOT MAFIA WE RESPECTTHE LOWS WE WORK ONLY FOR THE SAFETY OF HUMAN LIFE BEFORE ALL THE THINGS TO PREVENT THE ACCIDENTS AND IN ALLOWANCE CCOMPLIANCE AND ACCORDING ALL THE RULES LOW AND "EN RULES "APPLICABLE IN THE MACHINERY DIRECTIVE.

I GIVE TO YOU MY WORD OF HONOUR THAT WE HAVE WORKED IN PERFECT ALLOWANCE OF ALL THE LOWS AND WE HAVE NEVER DECLARED THE FALSE OR FAKE THINGS UNDER MY RESPONDIBILITY ONLY
With faithfull
Guido Guinderi
contact me by mail guidoguinderi@tiscali.it
mobile +39(0) 320 5697062

guinderi · 1st March 2007, 20:55

IN THE POST BEFORE PLS ERRATA CORRIGE READ EVER "EN 14143"
many thanks
guido

Ben Field · 1st March 2007, 21:21

Guinderi,

In your opinion is the CE mark you gave the Submatics exactly the same in value as that on (for example) the APD Inspiration?

I only ask because the salesforce are giving the public the impression that they have been subjected to the same standards of testing- you've just stated that they haven't, apparently.

**Freef** · 1st March 2007, 21:43

The post about the same numbers on italian kit:

The CE markings on certain equipment must also give the notified body number-this is the organisation that passes the equipment as fit for use, and not a number for an individual design or test.

CE in general:

I have to deal with CE equipment all the time at work, and some of it can be genuinely crap. I did an inspection on a lift recently that was unsafe. As in seriously dangerous. It was also a month old. None of the mauals were in English either, and there was no CE marking in the car as is requred.

A month later I was called back to reinspect. The safety defects had been put right, and the CE mark was fitted. Well a piece of Dymo tape with the letters C and E was fitted.

CE marks are in theory preventing iffy goods from being sold. In practice a most industries comply, some don't, and if you import from China make sure it isn't something your life depends on.

I'd rather have something that worked than something that was CE marked anyway.

Ben Field · 2nd March 2007, 08:11

Quote: (Originally Posted by Freef)

I'd rather have something that worked than something that was CE marked anyway.

Agreed.

The issue at hand is that in the UK alot of people have banged on about CE approved rebreathers SO MUCH that some people (potential customers) really think CE=Good, No CE=spawn of satan.

Again, there is nothing actually wrong with that until you consider that CE marks are not all equal...

paulraymaekers · 2nd March 2007, 13:32

Quote: (Originally Posted by guinderi)

I said that The rebreather is not certificable by a notified body because the rebreatrher is not on the list of the "MACHINERY DIRECTIVE".
So if youj want a Ce certification from a notified body, they test the machine according to all the rules applicable, also the EN 14403 2003, but they follow a path of certification like (similar OK) a surface-use breather (Like those that are in use for the fireman).

hello, IMHO this is nonsense...

offcourse the rebreather for diving is not mentioned in the MD, that is the reason why dolphin etc were certified to this directive, because of the absense of a directive typically for diving AT THAT TIME

when the 14143:2003 appeared, specifically about rebreathers for diving, meaning sub-aqua, from that date this directive had to be followed, and not a 'special path' to get a unit certified

and for the 14143, only notified bodies are allowed to state conformacy!

now you say that any manufacturer can state conformacy to the 14143 ???

regards
paul

AD_ward9 · 2nd March 2007, 14:20

Quote: (Originally Posted by guinderi)

ok I havent' talked about the story that I have certified a rebreather like a breather surface use!!!!that's very wrong.
I said that The rebreather is not certificable by a notified body because the rebreatrher is not on the list of the "MACHINERY DIRECTIVE".

You have the wrong directive.

EN14143:2003 is on the list of the PPE Directive, not the Machinery Directive. PPE is much more onerous.

It gives you no choice but to use a Notified Body that is PPE accredited for respiritory equipment including diving equipment.

In the UK there is only one company accredited to do that, SGS Yardley, though either Isoquar and BSI may join them very shortly.

Across the rest of Europe, I cannot find a single company accredited to do this other than TUV. If you know of any, please post here.

I attach the list of UK PPE Accredited Notifed Bodies for reference.

Use of any other body does not comply with the law or regulations.

Alex

AD_ward9 · 2nd March 2007, 14:38

In other words you are saying you are not accredited to certify rebreathers and in doing so you misrepresented yourself. You are not lawfully permitted to issue any certification for any diving equipment, other than perhaps you have serviced it.

We understand you may have acted in good faith, ignorant of the legal requirements.
If that is the case, please post here a link to the Technical File for Compliance.

I can easily understand how that can happen, as even some Notified Bodies are not informed properly. See the discussion between Brent and I on advice from BSI (which they now rescind), on the "Always Know Your PPO2 Thread". EN14143 is definitely on the PPE Directive list: Brent was correct on that issue, despite being a Machinery Directive Notified Body himself and not a PPE Man

.

Our technical file for Compliance is 450 pages long currently and it will be published in full.

Alex

Quote: (Originally Posted by guinderi)

Good evening to all
I am Mr guido Guinderi and i am Naval and mechanical engeneer I have Master degree in Naval Engineering and marine Architecture fro 1987 I was officer in the Italian Military Navy. I explain that the Re-breither Ce certification is in compliance with CE Machinery Directive
and I am enrolled to thr List of Order of Professional Engineer Of Latina District at number 742 from 1988 ,it's a pu bblic Register and also to The register of Shipbuilder for projecting of gaeta Harbour Master at Nr 57. I have passed the Italian State exam for Profissional Engineering and now I can project and certificate in this fields enviromental, concrete, information tecnology ,plants and machinery.

**PhilSiswick** · 2nd March 2007, 14:51

Quote: (Originally Posted by fireman)

Who Cares...Lets see CE= very expensive, excludes the safest technology (eg KISS). And appears to be somewhat corrupt--fake stamps, not for diving etc.
Has anybody ever died on a CE unit?

I understand that for all of you in the good old US of A, this is probably very funny. For those of us in the EU, this is more important. There is a very significant legal issue under discussion here, so please leave us to it.

Everyone knows the arguments about the KISS and the mortality rate on pretty much the only completely CE certified unit. Stop banging on about those.

Cheers,

23rd February 2007, 09:57	#51 (permalink)
PhilSiswick Phil Siswick, Tango Current Rebreather/s: Evolution Other Rebreather/s: Inspiration Vision Join Date: Apr 2006 Location: Oxford, UK Posts: 996	Re: submatix EC approval organisation Quote: (Originally Posted by Ben Field) 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? Agree - I have my opinion and used that to inform my choice of a unit. I chose one that was certificated against EN14143:2003. Anyone who certifies a unit against another standard, prints their own certification or bases their certification on only one component of their unit meeting CE, is misleading customers in a potentially illegal way. I also agree strongly with Dave - if you buy a non-CE unit, you know you're buying something that is not CE certified. That's not bad in itself, as long as you know that. 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
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1st March 2007, 20:43	#52 (permalink)
guinderi New Member Current Rebreather/s: Not Bought Yet Other Rebreather/s: Not Bought Yet Join Date: Feb 2007 Location: Italy Posts: 6	Re: submatix EC approval organisation ok I havent' talked about the story that I have certified a rebreather like a breather surface use!!!!that's very wrong. I said that The rebreather is not certificable by a notified body because the rebreatrher is not on the list of the "MACHINERY DIRECTIVE". So if youj want a Ce certification from a notified body, they test the machine according to all the rules applicable, also the EN 14403 2003, but they follow a path of certification like (similar OK) a surface-use breather (Like those that are in use for the fireman). That's all. So in this case the LOW(and nothing else), the Machine Directive, said that the manufacturer can Certificate CE the rebreather under his lonely responsibility acccording all the rules ,comprensive of EN 14403-2003. But now, who can say if the manifacturer is goin on with the correct path of certification, we don't need a therth party like a notified body, like the LOW said. So wwe have got a "certification CE PATH". we have studied all the rules applicable. we have controlled all the parts of which a rebreather consists, we have controlled the certification CE of all the parts and their safety and if they have a correct functioins according with all the rules under the supervision of us and very high specialized underwater personnel. All these controlls took place in our site in Genoa. Than we have tested the safety (CE CERTIFICATION IS FOR SAFETY CERTIFICATION and nothing else remember!!!!!!) We also have tested the correct use of the rebreather only in underwater safety test in Genoa and in sardinia. Than we have got all the test according also the EN 14403. Than we have write a Technical handbook according the "MACHINERY DIRECTIVE" in which we have reported all "The Path of Certification" Than we have write a "USER HANDBOOK"or a"OWNER MANUAL" (LIKE DO YOU LIKE) in copliance,EVER, with "MACHINERY DIRECTIVE" in which we described "THE SAFE USE OF REBREATHER FOR UNDERWATER USE ONLY" and nothing else. Than we have controlled ,together the manufacturer, all the steps we have got in safety. Then only now IT WAS POSSIBLE TO CERTIFICATE THE REBREATHER" THE FAMOUS "CE CERTFICATION " . The CE certification is always under the liability and under the responsibility of the manifacrurer, and the certificate is ONLY TO ENSURE THE SAFETY OF THE MACHINE. NOTHING OF FAKE; NOTHING OF FALSE!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! !!! DO NOT OFFEND THE ITALIANS, MY PERSON AND MY PROFESSIONALITY PLEASE. WE ARE NOT MAFIA WE RESPECTTHE LOWS WE WORK ONLY FOR THE SAFETY OF HUMAN LIFE BEFORE ALL THE THINGS TO PREVENT THE ACCIDENTS AND IN ALLOWANCE CCOMPLIANCE AND ACCORDING ALL THE RULES LOW AND "EN RULES "APPLICABLE IN THE MACHINERY DIRECTIVE. I GIVE TO YOU MY WORD OF HONOUR THAT WE HAVE WORKED IN PERFECT ALLOWANCE OF ALL THE LOWS AND WE HAVE NEVER DECLARED THE FALSE OR FAKE THINGS UNDER MY RESPONDIBILITY ONLY With faithfull Guido Guinderi contact me by mail guidoguinderi@tiscali.it mobile +39(0) 320 5697062
(Offline)

1st March 2007, 20:55	#53 (permalink)
guinderi New Member Current Rebreather/s: Not Bought Yet Other Rebreather/s: Not Bought Yet Join Date: Feb 2007 Location: Italy Posts: 6	Re: submatix EC approval organisation IN THE POST BEFORE PLS ERRATA CORRIGE READ EVER "EN 14143" many thanks guido
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1st March 2007, 21:21	#54 (permalink)
Ben Field CK+Shearwater Current Rebreather/s: Classic Kiss Other Rebreather/s: Sport Kiss Join Date: Aug 2005 Location: London, England Posts: 1,621	Re: submatix EC approval organisation Guinderi, In your opinion is the CE mark you gave the Submatics exactly the same in value as that on (for example) the APD Inspiration? I only ask because the salesforce are giving the public the impression that they have been subjected to the same standards of testing- you've just stated that they haven't, apparently. __________________ 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
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1st March 2007, 21:43	#55 (permalink)
Freef Custom Title Disallowed! Current Rebreather/s: Dolphin Other Rebreather/s: Dolphin Join Date: Jan 2006 Location: Land of the Freef, UK. Posts: 1,353	Re: submatix EC approval organisation The post about the same numbers on italian kit: The CE markings on certain equipment must also give the notified body number-this is the organisation that passes the equipment as fit for use, and not a number for an individual design or test. CE in general: I have to deal with CE equipment all the time at work, and some of it can be genuinely crap. I did an inspection on a lift recently that was unsafe. As in seriously dangerous. It was also a month old. None of the mauals were in English either, and there was no CE marking in the car as is requred. A month later I was called back to reinspect. The safety defects had been put right, and the CE mark was fitted. Well a piece of Dymo tape with the letters C and E was fitted. CE marks are in theory preventing iffy goods from being sold. In practice a most industries comply, some don't, and if you import from China make sure it isn't something your life depends on. I'd rather have something that worked than something that was CE marked anyway. __________________ David. Currently owner of two differently sized ankles.
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2nd March 2007, 08:11	#56 (permalink)
Ben Field CK+Shearwater Current Rebreather/s: Classic Kiss Other Rebreather/s: Sport Kiss Join Date: Aug 2005 Location: London, England Posts: 1,621	Re: submatix EC approval organisation Quote: (Originally Posted by Freef) I'd rather have something that worked than something that was CE marked anyway. Agreed. The issue at hand is that in the UK alot of people have banged on about CE approved rebreathers SO MUCH that some people (potential customers) really think CE=Good, No CE=spawn of satan. Again, there is nothing actually wrong with that until you consider that CE marks are not all equal... __________________ 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
(Offline)

2nd March 2007, 13:32	#57 (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: 1,500	Re: submatix EC approval organisation Quote: (Originally Posted by guinderi) I said that The rebreather is not certificable by a notified body because the rebreatrher is not on the list of the "MACHINERY DIRECTIVE". So if youj want a Ce certification from a notified body, they test the machine according to all the rules applicable, also the EN 14403 2003, but they follow a path of certification like (similar OK) a surface-use breather (Like those that are in use for the fireman). hello, IMHO this is nonsense... offcourse the rebreather for diving is not mentioned in the MD, that is the reason why dolphin etc were certified to this directive, because of the absense of a directive typically for diving AT THAT TIME when the 14143:2003 appeared, specifically about rebreathers for diving, meaning sub-aqua, from that date this directive had to be followed, and not a 'special path' to get a unit certified and for the 14143, only notified bodies are allowed to state conformacy! now you say that any manufacturer can state conformacy to the 14143 ??? regards paul __________________ www.rEvo-rebreathers.com .... the earth is flat, Elvis is alive, and radial scrubbers give longer dwell time than axials...
(Online)

2nd March 2007, 14:38	#59 (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: 1,862	Re: submatix EC approval organisation In other words you are saying you are not accredited to certify rebreathers and in doing so you misrepresented yourself. You are not lawfully permitted to issue any certification for any diving equipment, other than perhaps you have serviced it. We understand you may have acted in good faith, ignorant of the legal requirements. If that is the case, please post here a link to the Technical File for Compliance. I can easily understand how that can happen, as even some Notified Bodies are not informed properly. See the discussion between Brent and I on advice from BSI (which they now rescind), on the "Always Know Your PPO2 Thread". EN14143 is definitely on the PPE Directive list: Brent was correct on that issue, despite being a Machinery Directive Notified Body himself and not a PPE Man . Our technical file for Compliance is 450 pages long currently and it will be published in full. Alex Quote: (Originally Posted by guinderi) Good evening to all I am Mr guido Guinderi and i am Naval and mechanical engeneer I have Master degree in Naval Engineering and marine Architecture fro 1987 I was officer in the Italian Military Navy. I explain that the Re-breither Ce certification is in compliance with CE Machinery Directive and I am enrolled to thr List of Order of Professional Engineer Of Latina District at number 742 from 1988 ,it's a pu bblic Register and also to The register of Shipbuilder for projecting of gaeta Harbour Master at Nr 57. I have passed the Italian State exam for Profissional Engineering and now I can project and certificate in this fields enviromental, concrete, information tecnology ,plants and machinery. Last edited by AD_ward9 : 2nd March 2007 at 16:48.
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2nd March 2007, 14:51	#60 (permalink)
PhilSiswick Phil Siswick, Tango Current Rebreather/s: Evolution Other Rebreather/s: Inspiration Vision Join Date: Apr 2006 Location: Oxford, UK Posts: 996	Re: submatix EC approval organisation Quote: (Originally Posted by fireman) Who Cares...Lets see CE= very expensive, excludes the safest technology (eg KISS). And appears to be somewhat corrupt--fake stamps, not for diving etc. Has anybody ever died on a CE unit? I understand that for all of you in the good old US of A, this is probably very funny. For those of us in the EU, this is more important. There is a very significant legal issue under discussion here, so please leave us to it. Everyone knows the arguments about the KISS and the mortality rate on pretty much the only completely CE certified unit. Stop banging on about those. 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
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