small 16mm loco Boiler Certificates

[steveh99]

Can anyone offer simple clarity on the need for boiler certificates?
I am only talking about 16mm locos manufactured by Roundhouse and below 3 bar/litre. Please do not consider anything larger here.
As I understand it, any boiler made by roundhouse in the uk is fully tested to comply with any requirements or not as the case may be.
Early roundhouse models circa 18 years ago were not issued with any kind of certificate
Later models had a generic boiler certificate for the model type but no boiler serial number or other identifying mark
Current models get issued with a boiler certificate with matching serial number.
For all these models, the certificate is valid for the life of the model providing no changes or alterations are made to the boiler.
Therefore is it true to say that any roundhouse model automatically has a valid boiler certificate by default, as without a matching serial number on the paper and boiler, the paper certificate is fairly meaning less anyway.
I carry out an annual steam test (in fact more frequently than annually) and record the results.
Small boiler code does not seem to apply to less than 3bar/litre and in fact for this size, not even a boiler certificate is required. It certainly wasn't 18 years ago when I started so if and when did things change?

[Gralyn]

Things havn't changed. The 3bar Ltr rule still applies. If you are concerned about liability join the 16mm assn. they will issue you with association sponsored public liability insurance certificate.

[steveh99]

I am a member of 16mm assoc. I still need better clarity on whether a certificate is a must or an option and what makes that certificate "valid" given that earlier roundhouse ones were generic and did not have a serial number to link it to any specific boiler.

[TonyW]

Hi Steve...

I did send you a Private Message about this but it remains firmly on my Outbox and looks to be going nowhere. The following refers only to boilers that do not exceed the 3 bar/litre limit:

The 16mm Association's notes about boiler testing (http://www.16mm.org.uk/membership/membe ... insurance/) are, in my view, particularly "woolly" and non-specific. Lots of "recommended", "should" and "advised" and no "must", "required" or "mandatory". The second sentence on that page is the one to be noted: "Fundamentally this code states that small boilers with a capacity of not more than 3 bar-litres are exempted from the requirements of the code.". My understanding of this is that no certificate is needed for any boiler or gas tank to comply with the 16mm Association insurance requirement, no matter how old the loco may be.

However, this only applies to running at home or on another member's line. Anywhere else will probably be different but it is up to the owner of the line to tell you what certification they require and who can supply it. Their line, their rules.

If you really do want a certificate for locos that do not have one then remember that only a 16mm Association tester (or a boiler tester appearing on the National Traction Engine Trust Register of Boiler Testers...!) can issue a certificate that would then be accepted by the Association's insurers. Nobody else will do. I have a friend who has been building and testing boilers for 30 years, but his certificates hold no weight with the Association's insurers. However, the word of an Association tester is taken as gospel, despite him only needing to be "living and breathing" in the Technical Director's words to perform the test. Personally I would not allow such a person to lay a finger on any of my locos unless they could prove their competence to me, but then my nearest one is 150 miles away so it is not likely to happen!

[steveh99]

Thanks Tony

I agree with you about the woolly wording from the 16mm association, I get conflicting statements, so I am trying to pin Mark Rennie down to yes/no answers to specific questions. I agree with you that I don't believe we need boiler certificates, the insurance document states that, but it does require a self certified annual steam test that is easily performed and is essentially a test of the safety valve and visual inspection. I do this on a regular basis during the year anyway, usually before I go to an exhibition.

All roundhouse boilers are built and tested to the relevant specification and are valid for the life of the loco provided they are not modified in any way. Current roundhouse boilers come with a certificate that has a serial number matched to a specific boiler (albeit the serial number is actually the date of manufacture so there are probably multiple boilers with the same serial number, but I guess not many people ever change boilers) Older locos had a generic blank certifcate that would apply to any roundhouse boiler and older ones still never had certificates issued of any type.

Oh for some very clear and concise instructions, it can't be that difficult.

[TonyW]

... but it does require a self certified annual steam test ...

Require? No. Only "should be carried out". I should do all sorts of things...

... and older (Roundhouse) ones still never had certificates issued of any type.

Indeed. I find myself in the odd situation where my 30-year-old Roundhouse Dylan with a brass boiler requires no certification, but my large only-a-few-years-old Accucraft loco does become somebody somewhere thinks it is over 3 bar/litre when my calculations say that it is not.

Oh for some very clear and concise instructions, it can't be that difficult.

Good luck with that! And yes, it is that difficult, almost as though it has been deliberately made so.

Remember, anybody can buy and run a steam loco in this scale and not one jot of certification is needed.

[steveh99]

Thanks Tony

I see what you mean. Don't know why the 16mm assoc can't just say no testing or certification is required in order to be covered by the groups insurance and anything more than this is purely at the whim of the exhibition organiser or layout owner who all seem to delight in quoting small boiler guides etc, which don't seem applicable to me.

thanks for your responses as always

[steveh99]

This seems to be the latest info that I can find out:

It now seems that all boilers used in public should have certification called a "written scheme of examination" (the H&S at Work Act 1974 and the Pressure System Safety Regulations 2000 combine to require this). Although not legally binding the test code for model boilers issued by the Model Engineering Liaison Group (considered by HSE to be an "industry code of practice") was updated from 1 January 2013 to reflect this, as well as extending best practice for initial tests following construction. Small boilers under 3 bar litres are now included within the testing regime in this code - but with less onerous requirements.

The new requirements are for a thorough test by a boiler inspector for new boilers and/or a manufacturer's certificate (aka a "boiler certificate"), and a written record of continuous inspection in line with an inspection procedures appropriate for the type of equipment used. It is the latter which is now appears to be a legal requirement for public display. The 16mm Association have a boiler inspection certificate which can be completed by an owner which would comply with the law here: http://www.16mm.org.uk/resources/loco-maintenance/ The Association helpfully go on to describe what should be tested and say these tests should be conducted annually - together they form the "written scheme of examination" required by law.

According to the MELG test code model boilers produced since 2013 should be issued with a manufacturer certificate which lasts for the lifetime of the boiler; home made boilers need to have a similar initial certificate issued by a boiler inspector. The 2013 code requirements are not retrospective, so slightly oddly, older small loco boilers which were not produced with a manufacturers certificate only appear to need the written record of inspection as small boilers were outside the scope of the preceding 2008 code.

Hope this helps although there is still a lot of should and not much shall

[TonyW]

Thanks Steve, that is very interesting.

One thing though: Do you know what is meant by "used in public" and "public display"? If this refers to exhibitions and sites where the public (i.e. people unknown to the owner) can turn up, maybe pay admission, and watch the activities then the regulations are all very understandable and would and should be enforced by the site/event organiser. As I said: Their line, their rules.

Running in a private garden with others in attendance is a totally different thing, in my view. Mr Joe Public can buy and operate a loco in our scale without restriction, but at his own risk and it is my understanding that he is not breaking any law by doing so. It appears that it is only when you join a club or association (16mm, G1MRA, etc.) that things appear to become onerous. So is this is case of "If you don't like the rules, don't join the club"?

Meanwhile, I should but not must ponder on what to do with a well-known manufacturer's certificate that tells me one of my boilers "has been tested to 80psi" but the "maximum permissible pressure is 200psi", i.e. the wrong way around. What's that phrase? Oh yes, not worth the paper...

[steveh99]

I think you are right Tony
Public display is for exhibitions and general public admission
Private layout and garden visits for invited friends is different and the regulations would not apply
I am still investigating. You know what H&S are like in this litigious society we have now become.

[TonyW]

You know what H&S are like in this litigious society we have now become.

Well, yes, but I am not sure they can be claimed in this situation. If it were a government/H&S/EU-based directive telling us "You must have your boilers tested, or else" it would apply to everybody, but it clearly does not apply to not-a-member-of-anything Mr Joe Public and his steam locos.

[steveh99]

The MELG code seems to be a best practice guide including both legal requirements ("shall") and good advice ("should") but it is written as if it were a regulation; as far as I can see the scheme of written examination appears to be the only legal requirement for public use of small boilers built by a manufacturer at present. So I think as long as we record the annual steam test as per the 16mm association document, we should be fine. The boiler certificate requirement is not retrospective and Roundhouse have issued them with locos when they have been required to do so, and not bothered in the past when they didn't need to.