A certification question

[marshall5]

Let's say this is a hypothetical question for now. A loco was recently purchased by a member of our club from a commercial dealer. It came with a new certificate issued by a club whose boiler tester was also the vendor of the loco in his business capacity.
I would welcome comments.

[millman]

As I understand the rules a boiler tester cannot test and certificate his own boilers and from what you say it would seem that he or his business owned the loco before selling it to your club member and therefore he was testing a boiler owned either directly or indirectly by himself, which means that he has a commercial interest in the test result. If it were me I would want a completely independent test or to at least witness the test myself.

[marshall5]

Thanks for your comments. That was also my understanding of the regs. I carried out a 1.5 times hydraulic test for the owner, in the presence of our club inspector, who failed the boiler.

[Cro]

Could you provide details of why it failed?

I’m fairly certain I know the business and owner in question and this has been mentioned a couple of times in the past and as far as I know, due to the way he carries out the certificates/membership for new owner to the club and sale makes what is done legitimate. I also believe they video every boiler test carried out for evidence purposes and if there is any issue they will deal with it swiftly.

[paul]

Interesting discussion point!

In my own personal opinion I would actually far rather a dealer puts their name on the boiler certificates. It’s their own reputation at stake and I would like to make it mandatory that they test boilers themselves before selling. The last thing I would want to see a loco being sold by a dealer on the premise of the boiler being sold as sound without it having been tested, just because it came with a valid certificate! That way if a boiler is failed, then it can’t be sold as any other than that! Likewise, as long as the dealer keeps there evidence of the boiler test (as all dealers should do!) then if the buyer has steamed it, run it dry, then gone back to the dealer saying their product was faulty, then they likewise are not subjected to dishonest treatment. It’s certainly worth remember that the trade is just as important as the clubs in this hobby!

So like I say, I would like to make it mandatory that SRS, Steam Workshop, Antique Steam, View Models, Steam Days, Legacy Vehicles, Maxitrak, Berrybrook and any others I haven’t mentioned, HAVE to put their name on the boiler certificate or sell it as without a boiler certificate. It makes absolutely no sense for them not to take responsibility for the condition of the boilers they sell. I’m more than happy to listen to reasonable argument against this practice!

As per Adam’s query, I too would be interested to understand what the boiler in question has failed on? It would be unfair to see any company’s reputation tainted without evidence provided! I completely understand that no company name has been mentioned, but Adam already believes he knows which company this is so assumptions are already been made and we don’t even know what the loco or what the failure is!

Paul

[marshall5]

I have purposely not mentioned the name of the vendor and I would prefer that other posters don't speculate on the dealer's identity. The reason for failing the boiler has been communicated to the vendor by the loco's owner.

[Cro]

The reason I asked the details of the failure was to avoid speculation. You are suggesting that the dealer is carrying out ‘illegal’ testing and selling a failed boiler. Is that failure as serious as leaking tubes and stays all over or as simple as a leaking valve or flange seal which frankly aren’t a boiler failure so far as to condemn a boiler but a simple fix which if a reputable dealer they will offer to sort I would imagine.

I have to agree with Paul, why can’t there be a Claus in our testing allowing named traders to carry out tests (if qualified) to take responsibility of their own locos. If it were to fail it would be all to obvious they are testing incorrectly or filling out paperwork fraudulently.

I hope they dealer has offered a swift resolution to the issue as they are extremely friendly and would never knowingly sell something that’s dangerous.

Adam

[marshall5]

Adam, I am not suggesting anything of the sort. My original post sought members' views on whether the example given would, in their opinion, be in accordance with the current regs. One member felt that it was whilst another felt that it was not so it is probably best to leave it at that.

[simplyloco]

My Brit TIG welded boiler came with a shell test certificate signed by the maker. Is there a suggestion here that it is not valid?
John

[Neale]

I think that everyone would accept that a reputable commercial boiler maker (that dimishing breed) can certify their own-build boilers. I do not know what level of "qualification" they need to be allowed to do this. But a dealer? I have had no personal dealings with any of the dealers but I would be surprised if they would all be competent to test and certify boilers themselves. Club boiler testers are not just any old members but those with the experience and knowledge to do the job properly. So what does a dealer do to sell a boiler as certified when they cannot do it themselvee? Commercial testing services are probably uneconomic for all concerned so it comes down to using a friendly club. The mistake here seems to be to not use an "independent" club boiler tester to carry out the test rather than the loco vendor doing it himself - although the test should be witnessed anyway?

[paul]

Sept 5, 2020 10:04:59 GMT Neale said:

I think that everyone would accept that a reputable commercial boiler maker (that dimishing breed) can certify their own-build boilers. I do not know what level of "qualification" they need to be allowed to do this. But a dealer? I have had no personal dealings with any of the dealers but I would be surprised if they would all be competent to test and certify boilers themselves. Club boiler testers are not just any old members but those with the experience and knowledge to do the job properly.?

So what about those dealers who make their own boilers? Seems a bit presumptuous to suggest that dealers aren’t competent when SRS for instance probably make more boilers than several of the smaller one man band boiler makers. The numbers of Stafford’s or derivatives of are into the 100’s. The majority of which they’ve made their own boilers for. I’d suggest it unwise to question competence before knowing the facts.

On the clubs side of the argument, it is true that many are seasoned veterans, but this is not always the case. Several societies are suffering from a decline in member numbers and are happy to accept anyone who puts themselves forward as a boiler inspector. There is no test that you have to pass to say you’re competent! You don’t even have to have built a boiler! There are those who have been an inspector for years too whose judgement may not be what it was, there’s a reason people have driving tests for instance when they get older and why some have there licences removed. To this result and with 16 locomotives to maintain, I specifically ask for boiler inspectors whose judgement I truly respect and there are several that I purposely won’t use for this very reason. I’m sure there are others out there who will be more lenient than I am with boiler maintenance as it ultimate could seriously effect their hobby. For instance if they’re the only club member with a Steam loco passenger hauling, the hand pump has always been dodgy at best but works enough to pass a test 10 months ago, the second injector has been temperamental for the past 4 or 5 weekend steaming and no matter what they do they can’t seem to get to the bottom of why it won’t run clean, there’s a queue of kids in the station wanting a ride and you’ve only got to make a few more weekends before the seasons over noting you’re the main source of income for the club! I’d be surprised if there’s any club that won’t relate to this, waiting for the winter for the overhaul to commence!

Any dealers I use have fully kitted our workshops, employ several staff, are working on engines 5 days a week (or longer) so I would argue that they are more qualified than an amateur engineer who spends a few hours a week in his workshop and builds a loco (including his own boiler) over the course of 30 years. The suggestion above is that the man down the club who knocks out an engine every 12 months before selling said model is the club expert who everyone respects. However the reputable trader who builds/rebuilds 50 engines a year is incompetent. I’m not sure I buy this argument. After all you wouldn’t accuse a car dealer of being incompetent when it comes to a service, but instead give it to a close neighbour who tinkers with cars and assume they know best (certainly not without knowing the quality of both parties work!)

So for arguments sake, if a dealer has been a valued club member for 20+ years, done several years as a club boiler inspector and now sets up a company trading in model steam locomotives. How is that person now no longer competent? You could go down the route of testing all boiler inspectors, but the cost and potential results could end up in some clubs being shut down because they don’t have the necessary resources.

Marshall5 as the boiler inspector, have you gone back to the previous inspector and discussed the issue? As a fellow inspector I expect you to go back and check if and why the material state of the boiler has changed since the date of the original test. Any reputable inspector will have physical evidence to back up their test. I have mine filmed for instance rather than just someone’s written word on a bit of paper.

Like I said earlier, i’ll strongly argue that all dealers should HAVE to put THEIR names on boiler certificates to prove they’d witnessed that that boiler is safe prior to sale! Any reputable dealer would sign up to this as if their reputation is brought in to question then it’s highly likely that their livelihood is compromised, just like a boiler maker!

Well i’ve waffled on for far too long now, over to someone else! 🙂

Paul

[Neale]

Just in case anyone thinks that Paul's interpretation of my comments is what I intended to say - I did say that perhaps not ALL dealers might be competent to test boilers. In the back of my mind was the idea that a "dealer" is someone selling a loco by way of trade. That might include an auction house, for example, and not necessarily an enterprise which also builds boilers. Although I'm still not sure how such people gain accreditation for testing as well - is there a recognised qualification? And again, that's not saying that they are not competent - just curious! I presume that it's the whole professional indemnity/legal liability issues that makes commercial testing services uneconomic for us amateur builders.

I belong to a small club with only a restricted pool of members in which to find boiler testers - and it's not just the "lack of young members" thing that is an issue, it's also that the idea of building your own boiler seems to be becoming rather less common than once it was, so there's less experience being developed. Is building a boiler really more difficult than it used to be, in the days of petrol blowlamps and so on?

[coniston]

Sept 4, 2020 10:42:21 GMT marshall5 said:

Let's say this is a hypothetical question for now. A loco was recently purchased by a member of our club from a commercial dealer. It came with a new certificate issued by a club whose boiler tester was also the vendor of the loco in his business capacity.
I would welcome comments.

Sorry I'm late to this post but I wanted to check the text of the current "Boiler Test Code 2018 Volume 1 - Boilers 3 bar litres to 1100 bar litres" which I assume the loco in question was tested to comply with and the relevant supporting paperwork issued to. 

To answer the original question, it is allowed for an Inspector to test their own equipment / boiler BUT only if the equipment / boiler has been tested and passed by another Inspector - Paragraph 3.9 (a). So as long as the loco was presented with documentary evidence of previous successful tests there should be no issue. 

Of course when a boiler changes hands it will require a new Written Scheme of Examination to be completed in the name of the new owner - Paragraph 3.13 (d) (i).

Paragraph 4.8 suggests that when you performed the 1.5 times hydraulic test witnessed by your club inspector that a 'fail' certificate should have been issued to the owner which indicated the reason for failure, the club / organisation copy shall also be endorsed to record the failure and the information shall be passed to the boiler registrar of the association or federation supplying the boiler certificate. The owner then has clear documentary reason for the failure.

BTW the Boiler Test Code 2018 booklet is considered the 'Written Scheme' and an owner of a boiler should have a copy, I wonder if a dealer selling a loco / traction engine etc. provides a copy or at least ensures the new owner has a copy? without it the certificates are really of little use in so far as any explanation of how the pressure system has been tested and validated as safe for operation. Paragraph 1.5 refers. 

With regard to other peoples comments about dealers testing boilers they have for sale, in the case highlighted in this thread there could be an argument that the inspection was being charged for which is in contravention of the code - Paragraph 4.6 - "They or their club or Society shall not charge for examination, testing or certification". Maybe as the dealer was selling the loco then a charge was being made? up for debate that one but I suspect an insurance company or the HSE may well come down on the side of it being a charge albeit hidden within the sale price.

We have to remember the code referred to above (and the supporting certificates etc.) has been prepared by the various organisations primarily for the hobby of model engineering. Commercial organisations can and in my opinion should use the services of an independent inspection company or develop their own test code, written scheme, certificates etc. to comply with the requirements of the Pressure Systems Safety Regulations. I say this because as a business they are placing onto the market a pressure system which should comply with current legislation / regulations. As I say this is my opinion.

(now let's wait for the barrage of abuse)


Chris D

[paul]

Sept 6, 2020 8:12:06 GMT Neale said:

I did say that perhaps not ALL dealers might be competent to test boilers. In the back of my mind was the idea that a "dealer" is someone selling a loco by way of trade. That might include an auction house, for example, and not necessarily an enterprise which also builds boilers.

Thanks for your response and clarification Neale. I completely agree that some dealer’s may be unlikely to do their own boiler testing and this is where I feel that anyone in this situation should therefore be restricted to sell a model as either unticketed recently expired or with no boiler history. Auction houses tend to do the later for instance.

Ultimately what we want to avoid is an unsuspecting purchaser of a model being sold an item under false pretences and either ended up financially out of pocket or worse still, injured by a dangerous boiler. It is for these reasons alone that I would argue that certification and regulation of our dealers would be a good thing! It would however also need to be rolled out to the clubs too.

Sept 6, 2020 8:12:06 GMT Neale said:

Although I'm still not sure how such people gain accreditation for testing as well - is there a recognised qualification?

My understanding is that there is no accreditation for testing, all that needs to happen is for a club to list who they nominate. As a result the experience, knowledge and competence of those operating as boiler inspectors can range vastly between clubs. Therefore it is possible for someone with good intentions to unknowingly pass fit a dangerous boiler, or fail a sound boiler.

Regulation of boiler inspectors would certainly help to improve consistency across boiler inspectors. However it will add cost and could result in some clubs at risk of losing willing volunteers for the post or even having no competent person available due to time, cost or competence reasons.

Paul

[smallbrother]

Sept 7, 2020 23:41:54 GMT paul said:

Sept 6, 2020 8:12:06 GMT Neale said:

My understanding is that there is no accreditation for testing, all that needs to happen is for a club to list who they nominate. As a result the experience, knowledge and competence of those operating as boiler inspectors can range vastly between clubs. Therefore it is possible for someone with good intentions to unknowingly pass fit a dangerous boiler, or fail a sound boiler.



Paul

Hi Paul, out of interest for those of us without the expertise, could you give a "for instance" where this might happen?

Pete.

[paul]

Hi Pete,

Sorry just logged in and noticed your question.

I have seen several examples of boilers with valid tickets which were in a dangerous condition. Off the top of my head I can think of the following.

• Bulge in the boiler firebox/crown yet still pass both a hydraulic and steam test because of no obvious signs of water escaping.
• Inappropriate use of materials such as brass boiler fittings which will fail and fracture with use.
• Following from the above, cast brass firebox tube plate and backhead (with obvious cracks in both!) covered up with cosmetic copper plate. A similar coverup could also be achieved by paint or cladding! Completely unnoticed if previous paperwork provided and test passed!
• Poor quality repairs, I.e. soft solder, adhesive which is not up to long term exposure to heat etc.
• Poorly made fusible plugs. I’ve seen plugs which have only been holding by one of two threads when removed to check condition. Agin this would survive a hydraulic and static steam test, but could drop without warning when in use due to bouncing/physical movement when on the move.
• Frugal use of solder on stays/joints when built in an effort to produce an aesthetically neat solder joint rather than a structurally sound one.
• Lack of suitable stay construction of original build resulting in poor boiler design. If the original inspector missed this and then issued valid paperwork, then there’s no further need to take the boiler back out the frames for future tests.

Evidence can be provided for all of the above too, although I would always suggest that in any instance the relevant inspector is contacted using the details on the boiler certificate first to discuss in the first place. Each of these examples were approached in that way rather than exposing in a public forum. After all we’re there to educate and ensure safe practice rather than looking to raise a massive witch hunt when someone’s made an honest mistake.

In addition to the above, i’ve Also been witness to a large 7 1/4” locomotive with an up to date hydraulic and steam test, yet the boiler was immaculate! So how did they do a steam test if the boiler’s clearly never seen a fire?

I’m sure there plenty of other circumstances where boilers have been passed when they should’ve been failed.

On the flip side, how many loco’s have you seen with salts around the fittings from use? Regulator burning your finger, water valves leaking, steam brake which won’t seal! These alone are not reasons to fail a boiler, but will amount to an escape of steam which don’t affect the material state of the boiler. I’ve seen several locomotives stripped down because their inspector has incorrectly failed a loco, yet the fail was in no way due to the material state of the boiler. My Father’s own model was failed due to a leak on the rear tube plate and an enthusiastic member stripped the loco to investigate! The failure was a brass bush to which the superheaters were mounted on and to this day (20 years later!) the model has not been reassembled due to loss of enthusiasm! This certainly was an incorrect diagnosis by the then boiler inspector!

Hope that helps

Paul

[smallbrother]

Very much so.

Thank you Paul.

Pete.

[runner42]

Sept 21, 2020 21:01:00 GMT paul said:

Hi Pete,

Sorry just logged in and noticed your question.

I have seen several examples of boilers with valid tickets which were in a dangerous condition. Off the top of my head I can think of the following.

• Bulge in the boiler firebox/crown yet still pass both a hydraulic and steam test because of no obvious signs of water escaping.
• Inappropriate use of materials such as brass boiler fittings which will fail and fracture with use.
• Following from the above, cast brass firebox tube plate and backhead (with obvious cracks in both!) covered up with cosmetic copper plate. A similar coverup could also be achieved by paint or cladding! Completely unnoticed if previous paperwork provided and test passed!
• Poor quality repairs, I.e. soft solder, adhesive which is not up to long term exposure to heat etc.
• Poorly made fusible plugs. I’ve seen plugs which have only been holding by one of two threads when removed to check condition. Agin this would survive a hydraulic and static steam test, but could drop without warning when in use due to bouncing/physical movement when on the move.
• Frugal use of solder on stays/joints when built in an effort to produce an aesthetically neat solder joint rather than a structurally sound one.
• Lack of suitable stay construction of original build resulting in poor boiler design. If the original inspector missed this and then issued valid paperwork, then there’s no further need to take the boiler back out the frames for future tests.

Evidence can be provided for all of the above too, although I would always suggest that in any instance the relevant inspector is contacted using the details on the boiler certificate first to discuss in the first place. Each of these examples were approached in that way rather than exposing in a public forum. After all we’re there to educate and ensure safe practice rather than looking to raise a massive witch hunt when someone’s made an honest mistake.

In addition to the above, i’ve Also been witness to a large 7 1/4” locomotive with an up to date hydraulic and steam test, yet the boiler was immaculate! So how did they do a steam test if the boiler’s clearly never seen a fire?

I’m sure there plenty of other circumstances where boilers have been passed when they should’ve been failed.

On the flip side, how many loco’s have you seen with salts around the fittings from use? Regulator burning your finger, water valves leaking, steam brake which won’t seal! These alone are not reasons to fail a boiler, but will amount to an escape of steam which don’t affect the material state of the boiler. I’ve seen several locomotives stripped down because their inspector has incorrectly failed a loco, yet the fail was in no way due to the material state of the boiler. My Father’s own model was failed due to a leak on the rear tube plate and an enthusiastic member stripped the loco to investigate! The failure was a brass bush to which the superheaters were mounted on and to this day (20 years later!) the model has not been reassembled due to loss of enthusiasm! This certainly was an incorrect diagnosis by the then boiler inspector!

Hope that helps

Paul

Hi Paul,

I am aware of your bona fides being an experienced boiler maker so can speak from a point of strength on potential dangerous boiler issues. However, I think that you have been a little too creative in your listing, because some are not covered by the AMBSC Code Part 1, which is the Australian Code and some are even approved for use. In these instances, if the boiler inspector defects a boiler for these conditions then it could be challenged by the owner/builder. This code has the right of appeal in such circumstances. 

Brian