what about FAKE CE declarations???

paulraymaekers · 1st February 2007, 08:02

hello all, what can we do abouth fake CE declarations??? they seem to spread all over now!
another one has seen the light, dated 19/01/2007
also issued by an italian company..

to put it clear: I'm not bashing other rebreathers, but I hate false competition, meaning fraud!

regards
paul

Boris The Builder · 1st February 2007, 08:15

Does anyone know exactly how many different manufacturers do have a legitimate CE marking? I know the Ouroboros does and I know the amount of work, time and money goes in to getting the CE testing done.

The legalities of selling a unit marked with one illegally, or gained through sub standard testing with a back hander in some far eastern remote island assembly unit by small unskilled children, wearing fake clothes for 4pence a day does not bear thinking about! Can anyone with a legal brain enlighten?

IMHO I would'nt get in the bath with half the units out there and would hope that the divers using ANY life support equipment would have enough grey matter to thoroughly understand the mechanics, electronics and potential problems and subsequent bail outs of any unit prior to purchasing or diving!

AD_ward9 · 1st February 2007, 08:31

There are two different things:
1. A legitimate marking
2. Equipment that meets the CE standard.

Not a single eCCR out there meets the CE standards.

Meeting the standard means there are no lines saying "it meets EN14143:2003, except for XYZ", and also means it must meet EN61508 and ISO 12207. None come close. They have a marking because the Notified Body does not look at any normative standard: he just files the case. The auditors used are not even accreddited to do EN61508 audits.

Alex

paulraymaekers · 1st February 2007, 08:44

Quote: (Originally Posted by AD_ward9)

There are two different things:
1. A legitimate marking
2. Equipment that meets the CE standard.

Not a single eCCR out there meets the CE standards.

Meeting the standard means there are no lines saying "it meets EN14143:2003, except for XYZ", and also means it must meet EN61508 and ISO 12207. None come close. They have a marking because the Notified Body does not look at any normative standard: he just files the case. The auditors used are not even accreddited to do EN61508 audits.

Alex

hello all, I didn't even mean to go that far

I simply ment company's that make up a paper without doing the proper testing, testing company's that are not accreddited to perform EN14143
So I was even just only talking abouth the 'legitimate marking'

I mean everything besides the boris and the inspi
both seem to have done proper testing by accreddited companys
the others.....

regards

paul

AD_ward9 · 1st February 2007, 10:09

Hi Paul,
You cannot sit on a fence. Either a unit meets a standard or it does not. You cannot say that product XYZ meets EN14143, if you exclude the requirements of Section 2, Section 5.abc etc.

The fact is no eCCR currently meets the standard. Period.

The fact is, several have a Notified Body who has confirmed the unit meets EN14143 without any audit of any ofl the onerous requirements: I know this because the Notified Body they used is not accredited at all to audit those requirements (61508, 12207), and is in fact, ignorant of what those requirements are. This means the kit should not be CE marked.

If you want to do things properly, you do it properly and ensure the equipment complies with all the requirements of the standard. If you want to claim something meets a CE standard when it does not, why bother at all with a Notified Body just to certify it complies with half the standard? Using a Notified Body in these circumstances just adds to the deception.

To get a CE marking means getting an auditor for EN14143:2003 and another one for EN61508:2002. Without the signoff from the latter, there should have been no signoff from the former.

Alex

Quote: (Originally Posted by paulraymaekers)

hello all, I didn't even mean to go that far

I simply ment company's that make up a paper without doing the proper testing, testing company's that are not accreddited to perform EN14143
So I was even just only talking abouth the 'legitimate marking'

I mean everything besides the boris and the inspi
both seem to have done proper testing by accreddited companys
the others.....

regards

paul

paulraymaekers · 1st February 2007, 10:24

Quote: (Originally Posted by AD_ward9)

Hi Paul,
You cannot sit on a fence. Either a unit meets a standard or it does not. You cannot say that product XYZ meets EN14143, if you exclude the requirements of Section 2, Section 5.abc etc.

The fact is no eCCR currently meets the standard. Period.

The fact is, several have a Notified Body who has confirmed the unit meets EN14143 without any audit of any ofl the onerous requirements: I know this because the Notified Body they used is not accredited at all to audit those requirements (61508, 12207), and is in fact, ignorant of what those requirements are. This means the kit should not be CE marked.

If you want to do things properly, you do it properly and ensure the equipment complies with all the requirements of the standard. If you want to claim something meets a CE standard when it does not, why bother at all with a Notified Body just to certify it complies with half the standard? Using a Notified Body in these circumstances just adds to the deception.

To get a CE marking means getting an auditor for EN14143:2003 and another one for EN61508:2002. Without the signoff from the latter, there should have been no signoff from the former.

Alex

alex, I know there is discussion about yes or not EN61508 involved
I do not have time to investigate this, so I only concentrate on the EN14143 at the moment
So even if we only look at the EN14143, as far as I know only for the 2 british units a notified/accredited body gave them a green flag.

can someone answer my question in the other post: what about 6.6.3 conc the need of a metabolic simulator to perform the correct testing???

regards
paul

Nad · 1st February 2007, 10:48

Quote: (Originally Posted by paulraymaekers)

hello all, what can we do abouth fake CE declarations??? they seem to spread all over now!
another one has seen the light, dated 19/01/2007
also issued by an italian company..

to put it clear: I'm not bashing other rebreathers, but I hate false competition, meaning fraud!

regards
paul

Hi Paul,
Nice to have met you at the Boot.
I don't know about other countrys but in Italy some CE are done just for Life Support (like a safety Jacket), so not the complete machine.
Or maybe for a WOB like with a regulator but also in this case it is not correct.
Hope this help.
Nad

***jradomski*** · 1st February 2007, 11:00

Quote: (Originally Posted by Nad)

Hi Paul,
Nice to have met you at the Boot.
I don't know about other countrys but in Italy some CE are done just for Life Support (like a safety Jacket), so not the complete machine.
Or maybe for a WOB like with a regulator but also in this case it is not correct.
Hope this help.
Nad

don't forget this one (see attached image)

its for PPE not a rebreather.. this link
http://ec.europa.eu/enterprise/mecha...guidelines.pdf

describes the certification..

***jradomski*** · 1st February 2007, 11:25

Quote: (Originally Posted by paulraymaekers)

hello all, what can we do abouth fake CE declarations??? they seem to spread all over now!
another one has seen the light, dated 19/01/2007
also issued by an italian company..

to put it clear: I'm not bashing other rebreathers, but I hate false competition, meaning fraud!

regards
paul

My biggest pet peeve is that none of the mCCR units should have a CE marking (those already marked) .. Because of this paragraph..

5.7.2 Oxygen partial pressure setpoint maintenance
In apparatus with a fixed oxygen partial pressure setpoint the inspired partial pressure of oxygen shall be
maintained within 0,10 bar during constant depth phases of the dive. This at a ventilation of 40 l min-1 and
associated oxygen consumption of 1,78 l min-1 Standard Temperature and Pressure, Dry (STPD).
During the ascent phase the inspired partial pressure of oxygen may reduce to a minimum of 0,5 bar below
the set point but shall regain steady state set point within 1 min of halting an ascent.
When gas is injected into the breathing circuit the volume of oxygen added in 1 min shall be at least 6 l
(STPD).
Testing shall be done in accordance with 6.7.

Its impossible for a mCCR rig to meet this requirement, and the way the current wording is it doesnt distinguish between eCCR and mCCR just that its designed to maintain a constant po2..

About the only way I could see rigs "certified" is to have them tested as SCRs (high flow orifices) so that the above does not apply, and the user convert them by changinf the orifice.. for SCRs you just have to be able to guarantee that the po2 will always be between .21 and 1.6 at a constant depth..

The standard needs updating..

AD_ward9 · 1st February 2007, 11:44

Hi Paul,

EN61508 compliance is definitely required before EN14143 can be met: see Section 2 of EN14143:2003.

On the OMG certificate, have a look at their test facilities to understand the credibility of the certificate.

A metabolic simulator is required (a breathing machine with controlled mass flow O2 injection and CO2 injection).

Both the Boris and Inspo do not meet some clauses of EN14143:2003. For example, if you have an Inspo try the hoses. They do not comply with the requirement to stretch min 10% to max 30% with 1kg load. The one I have here stretched 45%. Only the Draeger Dolphin hose appears to pass that particular test. On the Boris, at least they are decent enough to say which bits they do not comply with, so fair enough.

Incidentally, we are making representations to a have the hose requirement changed in the standard. The requirement is dangerous, in that it causes the equipment to have much longer hoses than is ideal, and a longer hose is more exposed than a short hose, therefore more liable to fail.

Alex

Quote: (Originally Posted by paulraymaekers)

alex, I know there is discussion about yes or not EN61508 involved
I do not have time to investigate this, so I only concentrate on the EN14143 at the moment
So even if we only look at the EN14143, as far as I know only for the 2 british units a notified/accredited body gave them a green flag.

can someone answer my question in the other post: what about 6.6.3 conc the need of a metabolic simulator to perform the correct testing???

regards
paul

1st February 2007, 08:02	#1 (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: 1,638	what about FAKE CE declarations??? hello all, what can we do abouth fake CE declarations??? they seem to spread all over now! another one has seen the light, dated 19/01/2007 also issued by an italian company.. to put it clear: I'm not bashing other rebreathers, but I hate false competition, meaning fraud! regards paul __________________ www.rEvo-rebreathers.com .... the earth is flat, Elvis is alive, and radial scrubbers give longer dwell time than axials...
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1st February 2007, 08:15	#2 (permalink)
Boris The Builder New Member Current Rebreather/s: Ouroboros Other Rebreather/s: Join Date: Nov 2006 Location: UK Posts: 29	Re: what about FAKE CE declarations??? Does anyone know exactly how many different manufacturers do have a legitimate CE marking? I know the Ouroboros does and I know the amount of work, time and money goes in to getting the CE testing done. The legalities of selling a unit marked with one illegally, or gained through sub standard testing with a back hander in some far eastern remote island assembly unit by small unskilled children, wearing fake clothes for 4pence a day does not bear thinking about! Can anyone with a legal brain enlighten? IMHO I would'nt get in the bath with half the units out there and would hope that the divers using ANY life support equipment would have enough grey matter to thoroughly understand the mechanics, electronics and potential problems and subsequent bail outs of any unit prior to purchasing or diving! __________________ Boris The Builder Do not go where the path may lead, go instead where there is no path and leave a trail! - Ralph Waldo Emerson
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1st February 2007, 08:31	#3 (permalink)
AD_ward9 RBW Member Current Rebreather/s: Other CCR Other Rebreather/s: Other CCR Join Date: Jun 2005 Location: Scotland Posts: 2,011	Re: what about FAKE CE declarations??? There are two different things: 1. A legitimate marking 2. Equipment that meets the CE standard. Not a single eCCR out there meets the CE standards. Meeting the standard means there are no lines saying "it meets EN14143:2003, except for XYZ", and also means it must meet EN61508 and ISO 12207. None come close. They have a marking because the Notified Body does not look at any normative standard: he just files the case. The auditors used are not even accreddited to do EN61508 audits. Alex
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1st February 2007, 08:44	#4 (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: 1,638	Re: what about FAKE CE declarations??? Quote: (Originally Posted by AD_ward9) There are two different things: 1. A legitimate marking 2. Equipment that meets the CE standard. Not a single eCCR out there meets the CE standards. Meeting the standard means there are no lines saying "it meets EN14143:2003, except for XYZ", and also means it must meet EN61508 and ISO 12207. None come close. They have a marking because the Notified Body does not look at any normative standard: he just files the case. The auditors used are not even accreddited to do EN61508 audits. Alex hello all, I didn't even mean to go that far I simply ment company's that make up a paper without doing the proper testing, testing company's that are not accreddited to perform EN14143 So I was even just only talking abouth the 'legitimate marking' I mean everything besides the boris and the inspi both seem to have done proper testing by accreddited companys the others..... regards paul __________________ www.rEvo-rebreathers.com .... the earth is flat, Elvis is alive, and radial scrubbers give longer dwell time than axials...
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1st February 2007, 10:09	#5 (permalink)
AD_ward9 RBW Member Current Rebreather/s: Other CCR Other Rebreather/s: Other CCR Join Date: Jun 2005 Location: Scotland Posts: 2,011	Re: what about FAKE CE declarations??? Hi Paul, You cannot sit on a fence. Either a unit meets a standard or it does not. You cannot say that product XYZ meets EN14143, if you exclude the requirements of Section 2, Section 5.abc etc. The fact is no eCCR currently meets the standard. Period. The fact is, several have a Notified Body who has confirmed the unit meets EN14143 without any audit of any ofl the onerous requirements: I know this because the Notified Body they used is not accredited at all to audit those requirements (61508, 12207), and is in fact, ignorant of what those requirements are. This means the kit should not be CE marked. If you want to do things properly, you do it properly and ensure the equipment complies with all the requirements of the standard. If you want to claim something meets a CE standard when it does not, why bother at all with a Notified Body just to certify it complies with half the standard? Using a Notified Body in these circumstances just adds to the deception. To get a CE marking means getting an auditor for EN14143:2003 and another one for EN61508:2002. Without the signoff from the latter, there should have been no signoff from the former. Alex Quote: (Originally Posted by paulraymaekers) hello all, I didn't even mean to go that far I simply ment company's that make up a paper without doing the proper testing, testing company's that are not accreddited to perform EN14143 So I was even just only talking abouth the 'legitimate marking' I mean everything besides the boris and the inspi both seem to have done proper testing by accreddited companys the others..... regards paul Last edited by AD_ward9 : 1st February 2007 at 10:15.
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1st February 2007, 10:24	#6 (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: 1,638	Re: what about FAKE CE declarations??? Quote: (Originally Posted by AD_ward9) Hi Paul, You cannot sit on a fence. Either a unit meets a standard or it does not. You cannot say that product XYZ meets EN14143, if you exclude the requirements of Section 2, Section 5.abc etc. The fact is no eCCR currently meets the standard. Period. The fact is, several have a Notified Body who has confirmed the unit meets EN14143 without any audit of any ofl the onerous requirements: I know this because the Notified Body they used is not accredited at all to audit those requirements (61508, 12207), and is in fact, ignorant of what those requirements are. This means the kit should not be CE marked. If you want to do things properly, you do it properly and ensure the equipment complies with all the requirements of the standard. If you want to claim something meets a CE standard when it does not, why bother at all with a Notified Body just to certify it complies with half the standard? Using a Notified Body in these circumstances just adds to the deception. To get a CE marking means getting an auditor for EN14143:2003 and another one for EN61508:2002. Without the signoff from the latter, there should have been no signoff from the former. Alex alex, I know there is discussion about yes or not EN61508 involved I do not have time to investigate this, so I only concentrate on the EN14143 at the moment So even if we only look at the EN14143, as far as I know only for the 2 british units a notified/accredited body gave them a green flag. can someone answer my question in the other post: what about 6.6.3 conc the need of a metabolic simulator to perform the correct testing??? regards paul __________________ www.rEvo-rebreathers.com .... the earth is flat, Elvis is alive, and radial scrubbers give longer dwell time than axials...
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1st February 2007, 10:48	#7 (permalink)
Nad Rebel to the Bone Current Rebreather/s: Ouroboros Other CCR Other Rebreather/s: Not Bought Yet Inspiration Classic Other CCR Join Date: Mar 2005 Location: Europe Posts: 1,014	Re: what about FAKE CE declarations??? Quote: (Originally Posted by paulraymaekers) hello all, what can we do abouth fake CE declarations??? they seem to spread all over now! another one has seen the light, dated 19/01/2007 also issued by an italian company.. to put it clear: I'm not bashing other rebreathers, but I hate false competition, meaning fraud! regards paul Hi Paul, Nice to have met you at the Boot. I don't know about other countrys but in Italy some CE are done just for Life Support (like a safety Jacket), so not the complete machine. Or maybe for a WOB like with a regulator but also in this case it is not correct. Hope this help. Nad __________________ The Impossible is often the Untried
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1st February 2007, 11:25	#9 (permalink)
*jradomski* Moderator Current Rebreather/s: Inspiration Classic Sport Kiss Optima rEvo Other CCR Other Rebreather/s: Inspiration Vision Evolution Megalodon Classic Kiss rEvo Other CCR Join Date: Mar 2005 Location: "Da" Bronx Posts: 3,113	Re: what about FAKE CE declarations??? Quote: (Originally Posted by paulraymaekers) hello all, what can we do abouth fake CE declarations??? they seem to spread all over now! another one has seen the light, dated 19/01/2007 also issued by an italian company.. to put it clear: I'm not bashing other rebreathers, but I hate false competition, meaning fraud! regards paul My biggest pet peeve is that none of the mCCR units should have a CE marking (those already marked) .. Because of this paragraph.. 5.7.2 Oxygen partial pressure setpoint maintenance In apparatus with a fixed oxygen partial pressure setpoint the inspired partial pressure of oxygen shall be maintained within 0,10 bar during constant depth phases of the dive. This at a ventilation of 40 l min-1 and associated oxygen consumption of 1,78 l min-1 Standard Temperature and Pressure, Dry (STPD). During the ascent phase the inspired partial pressure of oxygen may reduce to a minimum of 0,5 bar below the set point but shall regain steady state set point within 1 min of halting an ascent. When gas is injected into the breathing circuit the volume of oxygen added in 1 min shall be at least 6 l (STPD). Testing shall be done in accordance with 6.7. Its impossible for a mCCR rig to meet this requirement, and the way the current wording is it doesnt distinguish between eCCR and mCCR just that its designed to maintain a constant po2.. About the only way I could see rigs "certified" is to have them tested as SCRs (high flow orifices) so that the above does not apply, and the user convert them by changinf the orifice.. for SCRs you just have to be able to guarantee that the po2 will always be between .21 and 1.6 at a constant depth.. The standard needs updating.. __________________ Joe Radomski CCR Trimix Instructor Trainer ANDI Instructor Trainer Director #10 All posts are personal opinions and DO NOT reflect any affiliated agency unless specifically stated. Last edited by jradomski : 1st February 2007 at 12:00.
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1st February 2007, 11:44	#10 (permalink)
AD_ward9 RBW Member Current Rebreather/s: Other CCR Other Rebreather/s: Other CCR Join Date: Jun 2005 Location: Scotland Posts: 2,011	Re: what about FAKE CE declarations??? Hi Paul, EN61508 compliance is definitely required before EN14143 can be met: see Section 2 of EN14143:2003. On the OMG certificate, have a look at their test facilities to understand the credibility of the certificate. A metabolic simulator is required (a breathing machine with controlled mass flow O2 injection and CO2 injection). Both the Boris and Inspo do not meet some clauses of EN14143:2003. For example, if you have an Inspo try the hoses. They do not comply with the requirement to stretch min 10% to max 30% with 1kg load. The one I have here stretched 45%. Only the Draeger Dolphin hose appears to pass that particular test. On the Boris, at least they are decent enough to say which bits they do not comply with, so fair enough. Incidentally, we are making representations to a have the hose requirement changed in the standard. The requirement is dangerous, in that it causes the equipment to have much longer hoses than is ideal, and a longer hose is more exposed than a short hose, therefore more liable to fail. Alex Quote: (Originally Posted by paulraymaekers) alex, I know there is discussion about yes or not EN61508 involved I do not have time to investigate this, so I only concentrate on the EN14143 at the moment So even if we only look at the EN14143, as far as I know only for the 2 british units a notified/accredited body gave them a green flag. can someone answer my question in the other post: what about 6.6.3 conc the need of a metabolic simulator to perform the correct testing??? regards paul Last edited by AD_ward9 : 1st February 2007 at 11:52.
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