HPA bottle legislation change

[danf1234]

Has anyone else’s sites been affected by the change in Legislation with HPA bottles. My local site are now checking HPA bottles and refusing use of any that are PI marked (Stamped TT) after 01/01/23. This means my brand new carbon tank I bought 3 months ago and is currently unused now is not site legal.
All tanks dated after 01.01.23 have to carry the British RHO standard marked as a (P) on the bottle. 
The insane thing here is suppliers are still selling HPA tanks with only a TT on.

We have been given this as a guideline

[Tommikka]

I (think) that I referenced this somewhere on the forum last year.

 

The flowchart is broadly right, but fails to take into account test exempt small capacity aluminium cylinders, and simplifies some points

 

It’s not exactly a legislation change, but Brexit, and the move out of European standards.  For a number of standards separate exemptions were made to remain as per the ‘legacy’ EU standards.  Such an exemption was not made for transportable pressurised cylinders, and therefore EU TPED regulations are no longer valid in the UK. (the Pi mark is from TPED)

We now therefor have the Rho mark for the UK

 

 

Below in italics are some of my notes from the UKPSF AGM of July 2024 (with the odd tweak)

 

The flowchart shows a ‘Northern Ireland exemption’.  This relates to the complexities of Ireland being UK in the north and part of EU in the south with no border.  

The extract image below from the Department of Transports document “Placing transportable pressure equipment on the market in Great Britain from  1 January 2023” highlights that Ireland is one market and therefore Pi remains valid in NI - though the flowchart demands documented proof - what could that be?  An invoice - which could legitimately be from a French retailer selling to an NI address??

A players ID with an NI address??

A cylinder on the NI market??

 

 

The flowchart does not take into account multi national UNISO 11119 cylinders, which are internationally recognised, therefore may not be Pi or Rho marked

 

The flowchart tries to take into account hydro test cycles (by referencing a 5 year date.  It is not explicit as to which date is within 5 years - born date or test date.

(A non GB Pi cylinder born after 1/1/23 doesn’t become a GB cylinder if it gets hydro tested, but a Pi cylinder born before 1/1/23 can continue to be used in mainland GB with valid hydro tests)

 

Aluminium 3000psi cylinders also actually have a legal 10 year lifetime before hydro testing is required.  However many manufacturers mark a 5 year expiry (therefore an inspection should reject a 6 year old if the markings say so, but could accept for up to 10 years if the markings do not or painted markings have worn away)

 

An aluminium cylinder could be used forever if hydro tested, but at the cost of a test vs a new cylinder it’s hardly worth it

Low capacity aluminum 3000psi cylinders may also be exempt from hydro testing, this is generally called the 2 x 2 rule due to the US definition of “shorter than 2’ and slimmer than 2” diameter

This would cover common airsoft small

cylinders such as 13ci cylinders 

So such a Pi cylinder born before 1/1/23 could be used forever in GB

 

((((The reason that it is all referring to January 2023 but Brexit happened before is due to the transition period))))

 

The Rho standard applies to all transportable pressurised cylinders, not just game play ones (oxygen cylinders etc). Which means that this has an impact on numerous industries, but with not many factories and Britain being a small market for them.  Few manufacturers were/are interested in registering for Rho approval standards, and even less interested in the sports market share of cylinders 

 

 

 

(Notes extract July 2024)  …… post Brexit cylinders:

Pi is from European TPED and Brexit brings us to Rho certification

There are no Rho cylinders on the market ((((as at July 2024))))

If the born date is before 1/1/2023 then a Pi cylinder remains valid and can be hydro tested until death date 

One or two manufacturers have been confirmed to be able to mark cylinders as Rho, but nothing in the UK yet (((as at July 2024)))

It’s likely that some fibres will be flown in but aluminium’s will only be sea freight

(Bearing in mind that <name witheld> used his DOT bottle everywhere except for me, x and y checking - so it’s a matter of who knows and who checks). <<player name and sites redacted>>. 

Existing Pi cylinders are fine (pre 1/1/2023

If buying check the born date 

Not sure how that affects multinational ISO 

Technically speaking Rho counts at point of sale on the market, so buy in Southern Ireland and new Pi could be fine print legal for UK

https://www.legislation.gov.uk/uksi/2021/1370/regulation/5/made#:~:text=Insertion of regulation 19AZA&text=—(1) A manufacturer%2C,TPE or Northern Ireland TPE.&text=(b)is pi marked TPE,prior to 1st January 2023.

 

 

https://www.gov.uk/guidance/placing-transportable-pressure-equipment-on-the-market-in-great-britain