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Old 13th September 2006, 00:20   #21 (permalink)
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Re: Any news?

Quote: (Originally Posted by AD_ward9) View Original Post
We discussed this on another thread.

Open Revolution is not open source as per GNU type licences. Open Revolution does publish the sources for all to see, publishes the safety process, the verification models and their sources, the circuits, their safety review, the mechanical drawings.
Actually, if I recall correctly, you publsh(ed) pseudocode, which is not "source" in the sense of the word that computer engineers (software and hardware) see it.

My point is simply that an "open" system is, as I define it, one which is free to copy and free to use. The GPL is one step back from "fully open", in that it is intended to (and does, according to several decided court cases) act as a virus, causing anything that incoroporates any part of what is covered by the GPL to likewise be covered by the GPL, whether the user intended that or not.

"Open Revolution" is nothing of the kind. The "open" part of it is intended to allow people to form a conclusion about the safety of the unit (that is, the soundness of the design), but not to allow them to use what has been learned on their own or incorporate it. I honestly believe that "open" is the wrong word for it, but that's ok - this is a semantics argument coming from someone who has a long background in real open-source technology (e.g. FreeBSD).
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However, we have a high regard for Iain's integrity and the altruism of safety comes first in their business, just like in ours. We both believe there have been a string of CCR deaths from poor design. We both would like that to end.
With all due respect, if you are correct in that assertion (I am not passing judgement in this thread on that matter) then you cannot succeed in this goal unless your work is accompanied with political activism to bar from production/use anything that doesn't meet "your view".

And, IMHO, failure or not, the bottom line is that always being aware of Mr. Murphy and covering for his appearance is part and parcel if remaining alive underwater.
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Diving gives access to a wonderful environment under the sea, that it is only really diving that is preserving. When we dive I for one feel grateful at the priviledge of seeing things under the sea, live, in ways previous generations never could. I hope more can enjoy and be part of this. To make that come about, we do need safer equipment. If there is a better way than the Open Revolution initiative to do that, I am keen to hear of it. Please tell me the solution rather than the problem.

Cheers,
Alex
I'm not criticizing your efforts - more units on the market with different perspectives on design = more choice, which is always good. So long as that effort does not turn towards limiting other's choice, I've no quarrel with it whatsoever.

I'm just pointing out that as soon as one runs to the patent office (or any of its analogues in the realm of product protection for commercial purposes) then the idea that this is all about altruism goes in the handwash bucket.

Not that profit is bad, mind you. You'll never see me quarrel with someone's quest for an honest buck, and frankly, I'm looking forward to seeing an actual unit in the flesh. You have definite differences from the other units out there, and some will call those revolutionary. I want to see 'em work before I decide if they are or not

In all honesty I hope you do wildly succeed, because that's good for everyone in the marketplace.

I have my suspicions as to how it will wind up from a competitive standpoint (all things considered, including cost of operation along with capital cost, balanced by what the market perceives as its benefits.) That is, how the value proposition works out for what you're building. But again, I'm not going to pass judgement there until I have something more than mere conjecture - which is all I've got right now.

I personally doubt I would/will be interested in buying one, but I could be wrong. That judgement would have to wait until they're actually "out there" and available to be looked at and toyed with.

No offense intended AD - the more the merrier, and the more information put forward the better, so long as no part of the effort is attempting to force others from the marketplace.
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Old 13th September 2006, 15:30   #22 (permalink)
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Re: Any news?

Quote: (Originally Posted by divetheworld) View Original Post
I think you are taking the scope of the "system" too literally in this case. The reference which is noted in the Official Journal is prescriptive in this case that 61508 only relates specifically and solitarily on the electrical, electronic or programmable electronic part of the apparatus. 61508 would never be applied to the canister
We have a CASS registration underway. We will put the question to the expert and publish the answer. This contradicts the direction we have been given in relation to an ongoing CASS registration (CASS is the independent verification that company or product meets EN61508).
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Old 13th September 2006, 15:34   #23 (permalink)
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Re: Any news?

Quote: (Originally Posted by Genesis) View Original Post
Actually, if I recall correctly, you publsh(ed) pseudocode, which is not "source" in the sense of the word that computer engineers (software and hardware) see it.
It is Metacode. It generates C code and Machine executable code, as well as Verilog, at the press of the appropriate buttons.

As regards forcing others off the market, that is not the objective, and is very unlikely. What should happen is higher standards of safety design get put into products as upgrades, and the old ones fall away. However, I do believe that unless companies get their act together on this, some products will be forced off the market, just as CE regulations have forced many rebreathers off the European market because they do not comply with a standard EN14143, designed for safety. EN61508 has the same weight as EN14143 for eCCRs, and no-one is meeting it. This is not a bad thing: I for one do not like buying a rebreather only to find it has a series critical failures in the first few weeks - this was the score. I mean failures like the computer hanging, that will kill some people in a population of users, and certainly spoiled my dive.

Cheers
Alex

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Old 13th September 2006, 15:58   #24 (permalink)
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Re: Any news?

Quote: (Originally Posted by AD_ward9) View Original Post
We have a CASS registration underway. We will put the question to the expert and publish the answer. This contradicts the direction we have been given in relation to an ongoing CASS registration (CASS is the independent verification that company or product meets EN61508).
Alex
Thats cool, good luck with that. The certification process is difficult enough, try not to put too many barriers between you and realisation of the product.
Obviously you could bring your product to the market place very quickly if you wanted to, and the fundamental principle of the product precludes that.
I guess I am suggesting not to do too much if you dont have to.

Brent
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Old 13th September 2006, 16:03   #25 (permalink)
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Re: Any news?

Quote: (Originally Posted by AD_ward9) View Original Post
It is Metacode. It generates C code and Machine executable code, as well as Verilog, at the press of the appropriate buttons.
Ok......
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This is not a bad thing: I for one do not like buying a rebreather only to find it has a series critical failures in the first few weeks - this was the score. I mean failures like the computer hanging, that will kill some people in a population of users, and certainly spoiled my dive.
Oh I certainly agree there! I'm frankly appalled at the somewhat-cavalier attitude towards bugs in handset firmware, epecially when there's an integrated deco or bottom timer function integrated in there. As a software engineer I'm well aware of what can happen when code goes "haywire"; the usual cause is that something wrote somethere where it didn't belong, and at that point the integrity of the entire system is suspect at best.

If you can't shut off the involved device and fly on what's left, that's even worse......
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Old 13th September 2006, 17:30   #26 (permalink)
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Re: Any news?

Quote: (Originally Posted by divetheworld) View Original Post
Thats cool, good luck with that. The certification process is difficult enough, try not to put too many barriers between you and realisation of the product.
Obviously you could bring your product to the market place very quickly if you wanted to, and the fundamental principle of the product precludes that.
I guess I am suggesting not to do too much if you dont have to.

Brent
Following on from your earlier point, I just raised this question of whether or not the scrubber is within the EN61508 scope in an eCCR with Audrey Canning of Verkonnen. Audrey was involved in setting up CASS, a Director of CASS Scheme Ltd until recently, works with BSI on 61508 implementation and on the International Committee for 61508. More definitive is hard to find. Audrey's view was the scrubber is certainly included in the scope of EN61508 if it is fitted to an eCCR.

CASS is the official interpretation of 61508. If a product meets 61508 it can be CASS registered.

The reason the scrubber falls into 61508 in an eCCR, is throughout 61508 there is an end to end requirement: one is not allowed to say, "our electronics ends here, so the fact that it is connected to a stick of dynamite with a burning fuse is not our concern, so the whole thing must have a SIL 4 safety level as that is what our electronics has". Does not wash. If the electronics is controlling the mechanics, then the mechanics and electronics together form the system. If the electronics is just injecting O2 but the system must remove CO2 for the user to stay alive, then the CO2 control falls into 61508. Just like on aircraft: you cannot say the wings are excluded from the safety case.

You appreciate the issues of bringing equipment to market fast, but without cover. This is fully accepted. I know it is very tempting when one is diving a product but we cannot sell anything until the independent safety certificates are in the safe. This is embedded in our formal Quality Processes.

How this works is interesting: our clients are either they are in countries where the Objective Responsibility law applies, or they are in the USA and big enough that if it is not done to the letter of the book then lawyers feast on them as soon as something goes wrong. What I am saying, is that after deciding to do it properly, we took on a client base that has the same objectives and would not sway from this noble goal. A mutually comfortable situation.

On both ethical and commercial grounds, we will apply the regulations exactly as they are written. EN14143 is easy - almost any decent design can meet it if the EN61508 compliance is ignored. EN61508 involves much more work. HSE are just really starting to pick up on this. Soon it will be just like trying to sell product that does not meet EN14143, if it does not meet EN61508 it has neither certification, so cannot have the CE mark. I think that will be good for diving generally, making it more accessible and with fewer personal tragedies.

Cheers,
Alex

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Old 14th September 2006, 11:35   #27 (permalink)
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Re: Any news?

Quote: (Originally Posted by AD_ward9) View Original Post

On the Micropore cartridges there is an interesting technicality. We cannot use granules, by law. It must use cartridges. I will explain:

The law in Europe says rebreathers must meet EN14143:2003, and that requires meeting EN61508. The latter applies to any system incorporating any electronics or electrical system, or programmed system.

This means if the CCR has a controller, EN61508 applies to the whole lot.

CCRs using granules cannot meet EN61508. This means any CCR marked CE without a Micropore cartridge, is a lie.

The reason is users have too much variation in packing. A recent posting to select Inspiration users from Martin Parker highlights this problem. Not even all the instructors APD trained know how to pack it safely.

Cheers,

Alex

How about prepacked granules then?

Something like this maybe:
Intersurgical Complete Respiratory Systems. News

Or the RGUFM, didn't the Japanese Fieno have that? I have also seen drawings of Russian scrubbers for UW use with prefabricated scrubbers.

Not that I know of any rebreather that is for sale today that uses prepacked scrubbers.
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Old 14th September 2006, 12:42   #28 (permalink)
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Re: Any news?

Quote: (Originally Posted by AD_ward9) View Original Post
The reason the scrubber falls into 61508 in an eCCR, is throughout 61508 there is an end to end requirement: one is not allowed to say, "our electronics ends here, so the fact that it is connected to a stick of dynamite with a burning fuse is not our concern, so the whole thing must have a SIL 4 safety level as that is what our electronics has". Does not wash. If the electronics is controlling the mechanics, then the mechanics and electronics together form the system. If the electronics is just injecting O2 but the system must remove CO2 for the user to stay alive, then the CO2 control falls into 61508. Just like on aircraft: you cannot say the wings are excluded from the safety case.

On both ethical and commercial grounds, we will apply the regulations exactly as they are written. EN14143 is easy - almost any decent design can meet it if the EN61508 compliance is ignored. EN61508 involves much more work. HSE are just really starting to pick up on this. Soon it will be just like trying to sell product that does not meet EN14143, if it does not meet EN61508 it has neither certification, so cannot have the CE mark. I think that will be good for diving generally, making it more accessible and with fewer personal tragedies.

Cheers,
Alex
In a nut shell the problem lies in the fact that the writers of 14143 had no idea of the implications of including 61508 in the clause as they did. The clause I quoted earlier is actually an oxymoron. This allows a reasonable argument for interpretation and "due dilligence" in the rationale that is put forward for the scrubber pack. We both know that no scrubber pack, even micropore can meet SIL4 without diversity, redundancy and monitoring. Ergo, to comply with the system requirments of a SIL4 design with current scrubber technology is nigh on impossible.
My advice would be to approach the certification body and find their interpretation of the clause and more importantly the competance of the person carrying out the certification part inclusive of 61508. As far as I know, there are no practitioners for 61508 appointed under the PPE directive. The CASS route you have chosen is by far the best approach. IF ou can comply, then that is very good news for you and very bad news for the competition.
I would suggest that in the case of any market surveillance enforcement under this clause would invoke the safeguarding clause and dispute of the standard (14143) in opposite corners.
If you do have problems in ensuring the scrubber meets SIL4, which I do expect, then the above may be your only recourse. This was the conclusion(?) of the head of the electrical and control system unit at the HSE whom I was casually chatting to today. I hope his opinion would be helpful to you.
Summary? Sure. To apply 14143 literally is predisposed to contradiction. 61508 would be for the entire system as you stated above. The official Journal has applied only the clause for presumtion of compliance leading to argument. The HSE say your right, but you can get out of it because I'm right if you argue it correctly. Go figure.
I can see some manufacturers getting into trouble if the certification of their products was challenged.

Brent
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Old 14th September 2006, 13:13   #29 (permalink)
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Re: Any news?

Interestingly the comment has been passed to me on reflection that "clause (5.13) is of sufficient imprecision to render its meaningless"

Very interesting.



Brent
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Old 14th September 2006, 16:13   #30 (permalink)
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Re: Any news?

Quote: (Originally Posted by jaap) View Original Post
How about prepacked granules then?

Something like this maybe:
Intersurgical Complete Respiratory Systems. News

Or the RGUFM, didn't the Japanese Fieno have that? I have also seen drawings of Russian scrubbers for UW use with prefabricated scrubbers.

Not that I know of any rebreather that is for sale today that uses prepacked scrubbers.
One could probably make a safety case for prepacked granules and meet EN61508.

Challenges would be:
1. Packing consistency, after the unit has been shaken on a RIB for a couple of hours to check for tunnelling.
2. Flooding. This would be a "Highly Likely" scenario to be considered in the safety case.

Cheers,

Alex
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