Boiler, the sequel

[jamiepage]

It may be a bit mischievous to open another thread having had two shut down now, but  I did just want to say the following-

John,
Thank you, but no worries. No apology necessary from you, believe me.

Andy,
I hope the G3S do set up a sub group to look into boiler schedules, and also that they take up the opportunity to have you involved.
  I wrote to the Society in October asking that they consider the G1MRA/ 16mm Assoc approach for Small boilers, and was told the issue would be debated internally, which debate would lead to a discussion piece in the last Newsletter followed by vote at the recent AGM.
When neither appeared, I asked again, to be told the G3S had already decided to maintain the status quo.

The lack of process (or the lack of interest in explaining the process) to get to that decision led to my resignation.

Of course, I fully accept that resignation holds me open to the charge that what the G3S does is now no longer my business, but its actions do, in my humble opinion, have the capacity to influence future insurance requirements on all of us, whether collectively in a group or as individuals. There is a straight line from 'additional requirements' to 'recognised good practice', to 'best practice', to tomorrow's 'mandated insurance requirements'.

Of course I could go directly to MELG as an individual and ask what their rationale concerning boats/ locos was, but I assume influential representative organisations would already have done that before signing up to it- or indeed, pushing back if it didn't fit with their stated aims, and with much more strength than an individual.
So I would still like to understand the G3S position and how it got there, hence my original posts which hoped someone on here would know.
Anyway, best of luck Andy.

John,
Standing by for lockdown!
Yours
Jamie

[John Candy]

Jamie,

This matter does need to be thrashed out and in the open.

I now want to see a copy of the G3S policy to see precisely what are the conditions of cover.

It is all very well the G3S providing me with a copy of their certificate of cover for my garden events but that cover is worthless if the conditions are not met and underwriters deny cover for an incident on basis that boiler certificates are invalid/wrongly issued or for some other breach of policy conditions.

John.

[IanT]

I have some knowledge of these matters but would like to make it clear that I am not speaking on behalf of the Society (and have no authority to do so).

First, let us be clear that Jamie's issues with <3BL policy has no connection whatever in my mind to the matter of blow-down valves. They are separate and different issues. The Societies >3BL policy is (and has always been) to adhere to the Southern Fed guidance with respect to boiler testing (G1MRA & 16mm have exactly the same policy for >3BL boilers in practice). It's that simple and I believe there are good, practical reasons for doing so.

The background to the blow-down issue seems to be that last year a Member submitted a large G3 engine (not a Brit I might add) for boiler test and the Boiler Inspector felt he was unable to make that test because he could not blow-down the gauge and test the recovery time (as required in the Green book). The owner queried the guidance (he certainly asked for my view and possibly others too - I don't know).

My personal view was that there was a level of (let's call) 'ambiguity' in the guidance, in so far that some could take it to mean that 'if not fitted' there is no need to test the blow-down valves. This does assume that 11.6 should read "the water level gauge(s) shall be tested (if blow down valves are fitted) " - which it doesn't of course.

However, because of this potential ambiguity, I understand that the SF was contacted and that they made clear that the requirement for >3BL boilers was that water gauge(s) must be fitted and that they must also be tested e.g. they need blow-down valves.

As a result of this, I believe that Kingscale were contacted by the Society and that they immediately stated that an alternative gauge fitting would be provided to any Brit owner who required it and that it could be reto-fitted. I assume that this is what Dave intends to do with his Brit.

So the SF guidance has not changed and the Society simply asked for (and received) clarification of (let's call it) 'interpretation'. It may well be that others were interpreting the guidance in a different way but I cannot speak for them. What is clear is that there can be no further misunderstanding of the SF guidance on this issue going forward.

I hope this helps to clarify the matter. I started this with a disclaimer. I will add another comment (again a personal one). If some of this Forum insist on shooting the 'Messenger', then it will get increasingly hard find any willing Messengers going forward.

Regards,

IanT       

[Andy B]

Thank you, Ian, for answering part of the great 'blow down valve' mystery!
Do you know if MELG (not just the SF) accept that this is unclear in the code as currently issued, will include the explicit clarification as part of a future revision?

It still leaves two questions open for >3BL boilers on blow-down valves -
1) Why was this point picked up on one particular loco when others which were >3BL and not having a blow-down valve (i.e. at least one 'Brit') not refused a certificate.  Lets ignore the legal side for the moment - this is purely a question about consistent application of a common code (that was intended to bring consistency.....)
and
2) Why is there an exemption for model boat boilers <10BL? On what (risk-based) analysis is this justified?

I appreciate that, as the messenger, you may not know the answers to these - I'm not shooting!

Regarding <3BL boilers, there is still ambiguity regarding blow-down valves.
It is clear that <3BL boilers do need to have a water gauge at all (clause 14.1). But if they do, then does it need to have a blow-down valve?
A 'follow what I do have written' type of inspector might say 'yes'. A 'risk-based' type of inspector might say 'no' (on the basis that a water gauge is clearly not considered to be necessary for safe operation, so whether it reads accurately or not does not improve safety).

Regarding water gauges in general, the code has fallen into the trap that afflicted many Railway Group Standards -  written based on the common technology at the time without being explict. Clause 6.7 tells us that we must have a water gauge. By inference of it and other clauses, it appears to be assumed that said gauge will be the 'traditional' tube type. Is an electronic gauge allowable, or not? If not, why not?
As above, the messenger probably won't have 'the' answer - but maybe an opinion?


Andy

NOTE : Andy has since confirmed typing error : Statement above should have read "It is clear that <3BL boilers do not need to have a water gauge at all (clause 14.1)."

Edited by Andy B to correct another typo in the final paragraph ('many' was 'may'). Must get some new fingers!

[Andy B]

One other comment - having decided to adopt a policy of requiring <3BL boilers to be tested by an appointed tester (rather than a 'buddy' system), I do feel that the G3S committee should make positive efforts to ensure a good geographical spread of boiler testers.
The membership is no longer clustered in the home counties, and one new tester north of Watford gap as announced at the AGM (whilst welcome) is not enough to support the Society's aims.
Another benefit would be to extend those formally involved in discussion on such matters within the Society to canvas a wider input.
This is no disrespect to the existing testers - just a practical reality of widening geographical spread.

Andy

[454]

As a result of this, I believe that Kingscale were contacted by the Society and that they immediately stated that an alternative gauge fitting would be provided to any Brit owner who required it and that it could be reto-fitted. I assume that this is what Dave intends to do with his Brit.

IanT,
You got it in one shot. We did not need the aggro & agonising over regs.
That is why I have self-embargoed my Britannia until advice from Mike Pavie has filtered down.
I await his professional advice & would prefer to await a positive outcome.

As I am a fully paid up G3S & N2.5G Assoc member it does not matter a jot as to who certifies any of our locos.
We do not need to be exclusively G3S or N2.5 G Assoc or even our local friendly ME society.

The Southern Fed cert will rule ok irrespective.
Rules is Rules & my locos will comply whenever the "fix" is secured.

Dave
N2.5, G3S, Local ME Soc

[jamiepage]

Ian,
Thank you for your reply, and also may I say, for the time you have spent on other public and private replies to me.

You're right, the blowdown issue is separate from my beef concerning over- complication of the <3 bar litre boiler schedule, and I ran the risk of confusion by conflating the two.

However, the issue I have been most keen to understand is the process by which certain requirements have become  mandated (or are becoming mandated), the how and why, and there does seem to be a shared characteristic there.
On the face of it, there seems no more logic in differentiating between a boat boiler and a loco boiler (of a certain size) so far as blowdowns are concerned, than there is in applying unnecessary testing requirements to Small boilers.

But, to repeat once again, if there are good reasons for where we are, then fine, I would like to think I'm intelligent enough to understand a reasoned answer, and open- minded enough to accept it.
But I would like to hear the definitive reasons why (and not oblique references to 'laws' which aren't, or insurance requirements which aren't etc, or indeed an implication I was offered- not by you, I hasten to add- that the G1MRA/16mm Assoc schedules were somehow not quite right).

I tried the G3S but they didn't help, I've tried here a couple of times but the conversations seem destined to shoot off in strange but entertaining directions, with my questions generating a lot of heat in return but no light. (There is probably some kind of boiler pun there).


Yours
Jamie

[John Candy]

Thank you Ian and Andy.

In view of what has been said, it is necessary to know on what basis the insurance cover has been issued.
If on strict compliance with the blow-down valve requirement of the regs., then many boiler certificates will be invalid for insurance purposes!

Andy, please clarify statement

It is clear that <3BL boilers do need to have a water gauge at all (clause 14.1). But if they do, then does it need to have a blow-down valve?

Did you mean to type not clear ?

I know for a fact that the "Finescale" boiler provided with the GRS 2021 GWR pannier kit does not even have a water gauge!  I bought a kit and was surprised to find it had no gauge and then enquired about having one fitted.....I was told it was impractical by two independent sources!
I never built the kit and exchanged it for two electric GRS kits.

It may be that all GRS live steam locos lack water gauges.

Regards,
John.

[454]

LONG LIVE MAMOD !

Dave
N2.5inch

[John Candy]

VIVA battery electric!!!

John.

[IanT]

I have plenty of 'personal' opinions Andy and have indeed made them known to the appropriate people but I've generally tried to keep my own opinions to myself on here as these matters seem to get quite confused enough without any further help from me. What I do try to do is state/explain the current situation as best I understand it myself.

When I was asked about this particular matter (by another Member) last year - I looked at the Green book and did feel that the guidance could be a little clearer. The only reason for this uncertainty (?) was because Para 6.7 doesn't actually mention blow-down valves. It's a matter of omission in my view.

However, Para 11.6 contains a perfectly clear "Shall be blown down" statement. The Boiler Inspector involved was very clear in his view that this engine needed to be capable of the gauge blow-down test and my advice to the Member was that (ultimately) the Boiler Inspectors decision is always final. A bit like a Football Referee or Cricket Umpire I guess.

As to why the differences, I can only guess that different people had different interpretations of the rules. I can't say any more than that really, as I wasn't involved directly in boiler testing. However, this has now been clarified directly with SF and there is now no room for other interpretations.

I've also had the opportunity to discuss this directly with several BI's (and one of our more experienced engine builders) btw and they were all unanimous in their view that a water gauge that could not be blown down could be very misleading & therefore potentially dangerous. In short, they support the view that water gauges require testing. Personally, I'm very happy to listen to these guys in this respect.

I cannot tell you too much more - much less the "How's, What's & Why's" of any MERG/SF documents with regards to "Boats" but will simply remind people that the G3S Committee (at the time) were just as concerned at the apparent lack of consultation over this as the other small scale organisations.

Finally, I am also aware that this area has been the subject of some debate & consultation recently and (in my view) the Society has not been complacent in these matters. Beyond that I can't really comment at this time.

Regards,

IanT

[jamiepage]

Quote

'As I am a fully paid up G3S & N2.5G Assoc member it does not matter a jot as to who certifies any of our locos.
We do not need to be exclusively G3S or N2.5 G Assoc or even our local friendly ME society.'

Unquote

Well, that's you ok then. 


G1MRA and 16m Assoc are both set up to encourage scenic railwaying (as the G3S also purports to be) but both manage to also support those members such as yourself who need the the extra documentation required by ME clubs for small boilers, without penalising their members who only wish to enjoy scenic railwaying on dedicated scenic tracks.

And they do it whilst imposing NO additional requirements on such as yourself. It would make not one jot of difference to your boiler schedule or documentation. None. Nil.

So what reason is there to not consider it? At least, to bother to understand the alternative?
If the G3 scale railwaying movement is to expand, it needs to look at organisations who have done well in the same field, and learn from them, doesn't it?.

I can see John's finger hovering over the triple lock button now, but hope this conversation can remain courteous for a bit longer. A triple lock would not be a record I'd be particularly proud of.

[John Candy]

Jamie,

None of the previous "locks" was a consequence of anything you have said!
The temperature was raised by others to near boiling point, so I dropped the fire!

As an irrelevant aside (a memory stirred by Dave's mention of Mamod) I recalled an incident at about the age of 14.
One of my friends (whose father just happened to be a Motorman on the London to Brighton run) owned a Mamod stationary engine. One afternoon (in the drawing room of his house in Clapham) we had this Mamod engine running on meths. In the corner, on an armchair, was sitting the cat, watching with great interest.
While oiling the engine, some lube oil fell on the fire and, gosh, did those extra BTUs speed up the engine......so we added a drop more!
By now the oscillating cylinder was going so fast as to be almost invisible .... until the retaining bolt and spring shot across the room along with the cylinder!
The jet of steam stopped just short of the cat's nose....it sat mesmerized for a few seconds, before flying off the chair and out of the room. We found the cylinder but not the bolt or spring.

We were promised (during the Summer hols.) a cab ride from Victoria to Brighton and back (non-stop in a 12-car train of 2 x 6-PAN units) but unfortunately it never came to pass. Those were the days!

John.




John.

[Andy B]

Andy, please clarify statement Did you mean to type not clear ?

Apologies for my typo.
It should have read "It is clear that <3BL boilers do not need to have a water gauge at all (clause 14.1). But if they do have a water gauge fitted, then does it need to have a blow-down valve?

"14.1
For the purposes of this Test Code small boilers are defined as those with a pressure-volume product below
3 bar litres.
Examination and test of this type of boiler is applicable if the boiler is fitted with (as a minimum requirement)
a safety valve and a pressure gauge. The boiler may also be fitted with a water level gauge and a mechanical method of pumping water in to the boiler whilst under working pressure."

John - please can you put an edit in my earlier post to correct it or point to this correction.

Andy

[IanT]

OK, so let's agree that the >3BL guidance applies to everyone - regardless of organisation and put that to one side.

As I've intimated, this whole <3BL area has been the subject of some debate within the Society recently and there are quite a range of views held from what I understand.

Having said that I wouldn't give any personal views on these matters, I will comment on several aspects of the G1MRA & 16mm scheme from my own viewpoint. Having looked closely at the "alternate" arrangements from a G3 perspective - I believe that they represent a bit of a 'Curates Egg'.  Whilst there's some good, there is also some not so good.

I think the 'Buddy' system is clearly open to abuse (I'm not saying it is being abused - but it's clearly possible) and frankly their documentation system is also pretty poor in this respect.

I said from a "G3" perspective, because we are somewhat different from the other Groups in  being much smaller and more thinly spread. So I don't think anyone will argue that it would be good if we could help G3S Members in this respect (e.g. make testing easier geographically) whilst still maintaining any 'systems' integrity. So the problem really becomes one of test coverage and good (e.g. believable) documentation.

So I hope that's generally the kind of solution we can move towards and it doesn't involve any of the "technicalities" or "legalities" that seem to be dogging this discussion.

My belief is that the Society is aware of this need and is trying to move in the right direction. Any near term solution may not be a perfect one but I do think that we can have something that meets most of our members needs and is still credible.

Regards,

IanT