EOI Sticker Dilemma Revisited
- Created on Friday, July 01 2011 16:53
Can you defend the statement printed on your evidence of inspection (EOI) sticker? Take a moment, look at what is written; study what is stated and what is implied. Do you perform what is written and do you inspect to gas industry standards? I have, over the past 15 years written several articles and lectured frequently on the importance of what is written on inspection stickers and the need to be trained. Many self-proclaimed inspectors as well as some trained inspectors have ignored important warnings.
The significance of sticker wording and training became a relevant issue in a civil lawsuit several years ago. A cylinder ruptured and questions by the plaintiff’s attorney were asked about the quality and visual inspection completeness. The sticker wording (this cylinder was inspected inside and found free of significant corrosion. Valid for one year) made the task of defending the inspector difficult. Can you visualize why?
A similar lawsuit settled in 2005 at great financial loss to the inspector was partly due to his use of an EOI sticker that, by it’s wording, made it clear his inspection was both inadequate and incomplete. His case was also diminished by his failure to have documented formal inspector training.
Visual inspection is a technical, objective assessment of a cylinder’s condition and its suitability for continued service. The EOI sticker applied by the inspector should be a statement as to the standards followed, identify who performed the inspection and when the inspection was performed. Those standards should be in written form and on hand at the inspection site.
In the first paragraph of this article I urged you to look at your EOI sticker. Does it only state “inspected to CGA C6? If that sticker is applied to an aluminum cylinder then the inspector has stated the cylinder was inspected to standards for steel cylinders not aluminum. Does your sticker say valid for one year? If so, you have implied a one year service guarantee. Can you even approximate that once out of your control, the cylinder will be serviceable and safe for one year? A common sticker legend states:inspected to dive industry standards. Ok, does the inspector have a copy of those standards? Not likely as there is no dive industry standard except for the PSI inspection protocol. Only the PSI inspector training and inspection standard is recognized by the US Department of Transportation (DOT), Transport Canada (TC) and cylinder manufacturers. Even the Compressed Gas Association refers to the PSI training and inspection manuals.
When an inspector applies an EOI sticker, he/she must understand the standard used and be prepared to prove the inspection was conducted according to the standard(s) listed. A written, detailed inspection report is the best proof of a complete technical inspection. CGA documents often become law by reference and although they are usually general in the subject matter, if you say you inspect to that standard you best have a copy of it and know its contents. CGA C6 is a guide for steel cylinders while the C6.1 provides guidance for aluminum cylinder inspection. C6.2 provides specific instructions for visual inspection of composite cylinders.
Dive stores often use a sticker that advertises the business as well as lists the inspection standard and month of inspection. When more than one inspector uses those stickers, it is not possible to identify the actual inspector. If later, there is a problem with that cylinder, those who did NOT handle the cylinder will want to be eliminated from scrutiny. Provisions should be made to identify the actual inspector.
Can you find fault with the following selection of EOI sticker legends?
(1) Inspected to gas industry standards and found free of significant rust or corrosion.
(2) Inspected and found free of significant corrosion. Valid for one year.
(3) The inside of this cylinder has been visually inspected and is good for 1 year from date marked.
(4) This tank has passed a visual inspection which conforms to standards set by the dive industry. This certificate valid for 1 year from date punched.
(5) Visual Inspection Certificate. This certificate valid for 1 year from date punched
(6) This tank met or exceeded all standards of the diving program and pamphlet C-6 of the Compressed Gas Association at time of inspection (used on 3AL cylinders).
Lets look closely at a popular sticker legend. This tank has been visually tested in accordance with all regulations of the Department of Transportation and was found to be free of visible defects on the test date shown. First, visual inspection is generally not considered to be a test but rather an examination. The DOT regulations offer very little in the way of inspection guidelines. A person reading only the Code of Federal Regulations will not find the information necessary to be a quality visual inspector. Does the person using this sticker have a copy of the most current Title 49 codes? The Compressed Gas Association is a recognized source for inspection information although its manuals are often general in nature to cover a wide variety of cylinder types.
Most scuba cylinders have some corrosion damage or other abuse appearing on the cylinder after the first year of service. Therefore, very few cylinders are “found to be free of visible defects”. A properly trained inspector will determine that damage found is within the manufacturer’s prescribed allowable limits and the cylinder remains suitable for continued service.
Some DOT regulations do have specific inspection references to certain scuba cylinders. DOT states cylinders made from 6351 alloy should be inspected annually by a TRAINED inspector. Also, the E12479 scuba cylinder MUST be inspected annually by a PSI trained inspector. Visual inspectors with formal, documented training recognized by the cylinder manufactures will be most defendable.
If you, as a high-pressure cylinder visual inspector want to have a high level of defensibility then you MUST:
(1) Be trained for the cylinder types you inspect and be current (at least every three years) in your training,
(2) Possess and understand a printed copy of the standards that you follow, and ensure those standards are recognized by the cylinder manufacturers.
(3) Never allow unauthorized persons access to your EOI stickers
(4) Use an EOI sticker with a legend that truly represents the type of inspection performed.
Cylinder inspectors, handlers and owners are encouraged to visit the PSI, Inc. website (psicylinders.com) for additional information on scuba cylinder inspection and safety.