There’s no holding him back – that John Liddiard still wants to be allowed to take his regulator apart, but is this dangerous talk, and what does the dive industry have to say about it?
Last July in Diver, I let off some steam about regulator servicing. I was annoyed at the way I felt manufacturers of diving equip-ment restricted the sale of spare parts.
Without going over the whole argument again, I made the point that a car is potentially lethal and has thousands of parts, yet its owner can choose where to buy it and whether to service it himself, get a local workshop to do the work, or to take it to a main dealer. With a regulator, manufacturers allow one choice – take it to an approved dealer.
If all service technicians could be relied on to do the job properly, fine. Unfortunately, that isn’t always the case.
I expected to collect some flak for expressing my views. Instead I received nothing but support. The topic of regulator servicing has since been a popular one in the Diver mailbag, and I was interested in pursuing the subject further.
The Health and Safety Executive is the government body responsible for overseeing safety at work, and it identifies the relevant legislation as the Consumer Protection Act 1987 and the Health and Safety at Work Act 1974. According to HSE Special Diving Inspector Mike Harwood, these place various requirements on “duty-holders” which covers designers, manufacturers, importers or suppliers of goods.
Like any other “goods”, a regulator must be reasonably safe when used, which includes setting up, cleaning and maintenance. Information has to be provided to users to enable them to maintain that level of safety throughout the unit’s expected life.
Duty-holders must decide how to meet their obligations under the legislation. Where maintenance requires manuals, tools, replacement items, test equipment and/or particular maintainer competency levels, they are expected to take this into account before the goods are placed on the market; to inform or supply the purchasers or users with documentation setting out those maintenance requirements and who can do it; and to take reasonable steps to prevent users from overriding these recommendations and subsequently making the goods unsafe.
The important thing to note here is that the only prescription about who actually carries out the maintenance work is that duty-holders are required, so far as is “reasonably practicable”, to ensure that maintainers are adequately trained and equipped to do it.
According to Stewart Meinert of the Association of Scuba Service Engineers and Technicians (ASSET), the law considers regulators to be “personal protective equipment” rather than sports equipment.
So manufacturers, dive centres and technicians must consider their legal position, regardless of the wishes of the diver who, as an amateur, is not bound by health and safety law.
“Future European legislation will undoubtedly cause greater restriction on those who service,” says Meinert. “The need for formal qualification and approval will be a feature.”
Why, however, asks Meinert, do divers feel the need to service their own equipment? “Except for those going on an expedition, there should be no need for a diver to obtain a service kit for diving equipment,” he says.
But he is happy to answer his own question, and it is central to the whole issue of DIY regulator servicing. “We know from personal experience that far too many divers are dissatisfied with the standard of servicing they receive,” he says.
“This is due in part to a lack of formal training and experience on the part of the technician. In the past, dive centres had to make do with a manufacturer’s product familiarisation course as the sole means of technician training. Manufacturers’ equipment courses are designed only for product familiarisation. Their duration in terms of hands-on training is seldom more than a few hours. Yet many of those who attend have no prior experience or formal training.
“In most cases, an attendance certificate is issued regardless of performance or understanding.”
Strong words, though ASSET believes the answer to the problem lies not in DIY but in its own 10-day courses for technicians, of which more later.
Manufacturers and distributors rightly emphasise that regulators are life-support equipment and that experience, training and the right tools are needed to service them safely.
“We have witnessed first-hand many instances of dangerous workmanship relating to diving equipment,” was the comment of Carl Baggott of Hydrotech, the UK distributor for Dacor regulators. “Consequently we do not encourage divers to service their own equipment.
“The job of servicing regulators must not be understated. Reputable and competent technicians will have spent many years building up and developing their knowledge; attended service courses covering many different manufacturers’ equipment, updated twice-yearly; and have available all the specialist tools and test equipment required and the many manuals needed.”
Baggott describes trying to keep up with all the technical updates and training required to maintain equipment in accordance with manufacturers’ guidelines and relevant European and British standards as “an expensive and time-consuming task”.
Restricting the sale of spare parts for regulators allows duty-holders to comply with legal requirements but of course at the same time protects the service business of dealers.
“We sympathise with the manufacturers’ position,” says Stewart Meinert of ASSET. “They are concerned with the safety and reliability of their product, their liability if things go wrong, their own reputation and the need to support and channel business towards their retailers.”
So the situation on spare parts and servicing has not changed since my rant last summer. “Repairs and services must be conducted through an authorised dealer,” says Mick Robertson of Scubapro, summing it up. “Technical training is offered annually, but only to authorised dealers who must attend at least every two years.
“This system has been established to ensure that Scubapro can oversee the network of technicians servicing our regulators,” says Robertson. “It enables us to keep them up to date with the latest technical information by regular technical bulletins and finally to ensure that only authorised Scubapro spare parts are used in Scubapro regulators.”
On the cost of servicing, Graham Sharples of Apeks notes: “With hundreds of Apeks service centres covering the country, we feel competent servicing is readily available and competition between our dealers keeps the cost at a reasonable level.”
However, some manufacturers and distributors express, as it turns out, a more open policy, allowing any diver to attend a service course and subsequently purchase the necessary parts.
“We would sell spare parts to end-users if they had attended a Sherwood Regulator Service Technicians Course,” says David Chandler of Sea & Sea, the UK distributor for Sherwood regulators. “These courses can be undertaken by a person not employed in the diving trade for £150 per day. For a person who has not previously attended a course, two full days are required.” A one-day refresher course is then required every two years.
Alpha Distribution, the UK importer for Seac-sub, also has an open approach, with its regulators covered by third-party training courses available from STATS (Scuba Technical and Training Services), an organisation that provides a range of technician training courses to the diving industry.
“I would supply service kits to any qualified scuba technician having completed a recognised Seac service course,” says Alpha’s John Camm, though he adds that he would supply only kits for the products included in that course. “For all new products, the technician would have to complete an update of his or her service qualification before service parts for these would be supplied.”
All candidates who attend the STATS training course cover the Seac range of products, says Camm. “I hold regular update seminars for Seac accounts for all new products introduced. These updates are available on request for users who are qualified service technicians.”
STATS courses are designed to meet qualification standards agreed by ASSET and other organisations, including IDEST (Inspectorate for Diving Equipment Service and Testing), SITA (Scuba Industries Trade Association) and the HSE. The courses lead to an NVQ Level 2 engineering and marine maintenance qualification. In addition to his role as spokesman for ASSET, Stewart Meinert is also manager of STATS, and tells me that courses are available to “end-users”.
One of the responses to my original article was from a diver who had attended the 10-day STATS service technician course and procured a full set of service tools. Unfortunately, his own regulators were not made by Seac-sub, and the manufacturer had still refused to sell him parts.
Hydrotech takes a slightly different approach from Sea & Sea and Alpha and leaves it to the retailer to decide if and when spare parts can be sold: “It’s left to individual outlets’ discretion as to their policies on retail sales,” says Carl Baggott.
The company offers training courses in servicing Dacor regulators, and Hydrotech account-holders are free to nominate “suitable” individuals. So if you own a Dacor regulator and talk nicely to your local dealer, you might be nominated to attend a Dacor service course.
Peter van Burren of Dräger informed me of another way round annual service requirements. The standard interval for regulator servicing is one year, but Dräger, better known for its semi-closed rebreathers, also makes open-circuit regulators, and these have a six-year service interval, though performance still has to be measured each year and servicing provided if necessary.
All the manufacturers and distributors who responded to my questions stressed the importance of adequate training and I’m sure would never intentionally allow the sort of inadequately trained “technician” described earlier by Stewart Meinert of ASSET to service their products.
ASSET offers them the solution. “ASSET-certified technicians undergo an intensive 10-day training programme and are examined and evaluated throughout,” says Meinert. “ASSET qualifications are considered by SITA, IDEST and the HSE to be the minimum standard for a competent technician.
“If manufacturers were to insist on ASSET technicians’ certification prior to attending their courses, the standard of maintenance would improve overnight.”
Just under half of the 10-day technician training course is dedicated to regulator servicing, the remainder coveringservicing of other diving equipment, cylinder-filling and an introduction to cylinder testing. So to train an unqualified candidate as a technician capable of servicing a manufacturer’s entire range of regulators means about seven days of initial training, with biennial refresher training of one or two days.
“Divers should insist that their service centre is IDEST-approved for both regulator servicing and cylinder testing,” says Meinert. “The diver should ask to see the technician’s ASSET qualification, not just accept the manufacturer’s attendance certificate as proof of competence. It costs money to provide quality service. Divers should be prepared to pay for good service and complain loudly when they don’t get it.”
I still don’t think there is any but a commercial reason for regulators to be treated differently from cars, even if they are classed as “personal protective equipment”. You can’t call out the AA or RAC at 50m, but you can carry a spare. And that analogy is just as relevant whether you service your car at home or take it to a main dealer.
Nevertheless, I am encouraged by the availability of training for Sherwood, Seac-Sub and Dacor regulators. Perhaps other manufacturers and distributors will in time follow suit.
All credit to those who were prepared to stand up and be counted, whatever their response. And if your regulator manufacturer has not been mentioned, perhaps it is because it preferred not to comment on what remains for many people a thorny issue.
Alpha Distribution (Seac-Sub) 01226 341133
Apeks 01254 692200
ASSET 01524 381831
Cressi-sub 01484 310130
Dräger (+31) 79 3460 416
HSE 01207 7176760
Hydrotech (Dacor) 01455 273089
Scubapro 01256 812636
Sea & Sea (Sherwood) 01803 663012
STATS 01524 381831