Non-compliant mild Steel CO2 extinguishers should be taken out of service

Non-compliant mild Steel CO2 extinguishers should be taken out of service

1475 SAQCC Fire registered technicians are reminded not to service and sign off on mild steel CO2 extinguishers which were not revalidated during the exemption period ending in December 2020.

The exemption was granted by the Department of Employment and Labour in December 2016 after it came to light that there were CO2 extinguishers in the South African market with incomplete manufacturing design specification stamping with specific reference to BS 5045.

When CO2 cylinders are manufactured, the manufacturer needs to follow an approved design standard and this standard needs to be hard stamped on the cylinder for traceability purposes. Often such standards will consist of difference parts with specific scopes. Thus BS 5045 has different parts such as BS-5045-1(Seamless steel gas cylinders), BS-5045-3(Seamless aluminium alloy gas containers). So when it was discovered that there are mild steel CO2 cylinders with incomplete stamping, BS 5045, only, it was realised that these cylinders do not comply with the Pressure Equipment Regulations (PER) issued in 2009. This raised concerned that due processes were not followed when the cylinders were manufactured and subsequently imported into South Africa.

Any company that wishes to import such CO2 cylinders need to follow the requirements of the PER for importers/manufacturers. Some of these requirements include that equipment should be designed and manufactured and be conformity assessed to the requirements of specific South African national standards, the relevant safety and health standards and that a certificate of manufacture be supplied with a verification signature by an approved inspection authority.

This means that when the extinguishers are submitted to an approved entity in South Africa for approval and certification to South African national standards, conformity review certification documents need to be submitted to this entity. The latter then needs to review and ensure that the conformity documents comply with regulations and requirements. However, it appeared that some CO2 cylinders imported up to 2016 did not undergo this scrutiny and thus potentially non-compliant CO2 extinguishers were sold to the South African market.

When this was reported to the SAQCC Fire in 2016, the Committee approached the Department of Employment and Labour for guidance on how to manage these cylinders are there were huge volumes of these in use and it would have had major financial implications for the owners to replace these cylinders all at once

The Department appointed a working committee to investigate the safety and risk implications should the cylinders be allowed to be kept in service. The outcome of the working committee’s conclusions was that if certain measures would be followed, it would result in a very low safety risk to keep the cylinders in service.

Thus in December 2016, the Department issued an exemption with some of the following requirements:

All mild steel carbon dioxide extinguishers that came into the country after October 2009 to be subjected to pressure testing for the first time on a 5 yearly interval and thereafter on a 10 yearly interval

The practical implications were that all service technicians had to present mild steel CO2 cylinders to an approved Gas Test Station and should the cylinder pass a pressure-test, such cylinder could be signed off by a 1475 registered person and it could be kept in service to be then pressure-tested 10 years later as per national standard requirements. Note that cylinders stamped BS5045 had to be failed by Gas Test Stations due to incomplete stamping and only cylinders with complete stamping BS4054-1 that fulfil in the other requirements could be passed.

In December 2019, the Department replaced the exemption of 2016 and included details on other cylinders, but with specific reference to the CO2 extinguishers, the following requirements were stated:

The revalidation condition of exemption….for any mild steel CO2 fire extinguisher shall lapse on 31 December 2020, all cylinders not validated by this date shall be deemed non-compliant and shall be removed from service

This meant that all of the BS 5045-1 cylinders had to be pressure-tested by December 2020 as the exemption expired by the end of December 2020.

There is concern that there are still mild steel CO2 extinguishers in service which have not been pressure-tested by a SANAS approved entity and has either been failed or has not been stamped with a pressure-test date either 5 years after manufacturing or in the period ending December 2020. The concern is that service technicians are servicing and signing off on these extinguishers thinking it is compliant and only need to be pressure-tested 10 years after date of manufacturing. As importers/manufacturers had to import compliant CO2 extinguisher strictly as per the PER as informed by the Department’s exemption notice of 2016, cylinders imported since that period were stamped with design manufacturing specifications for alloy steel or aluminium CO2 cylinders. However, this means that there will potentially still be some of these BS 5045 or BS 5045-1 CO2 cylinders with a manufacturing date up to 2016 and technicians may think it can be serviced until it needs to be pressure-tested leading up to an including 2026.

Thus technicians are warned to look out for these cylinders stamped BS 5045 or BS5045-1. Check that it was pressure-tested and hard stamped with a date before or up to December 2020. If not, then such a cylinder has to be taken to a Gas Test Station to fail and a test certificate needs to be issued and handed to the owner of the cylinder. 1475 Technicians are reminded that they or their company cannot fail or condemn such an extinguisher themselves as this in contravention of the PER. This procedure can only be done by a Gas Test Station and only such an entity can issue a test certificate indicating the cylinder was failed.

A further recommendation is that any 1475 company or technician purchasing CO2 extinguishers from an importer/manufacturer should ensure that the importer/manufacturer followed due diligence to ensure that the product is compliant to the PER. As stated by the Department of Employment and Labour at the SAQCC Fire 1475 meeting in January 2023, any 1475 company or technician has the full right and the importer/manufacturer has the duty to supply all documents pertaining to a conformity review report for a batch of cylinders. All CO2 cylinders are hard stamped with an unique serial number which should be traceable to such a conformity review report.

About us

FFETA was formed in 1973 for the benefit of manufacturers, wholesalers and retailers of fire fighting equipment and their customers.

Our main aims are to inform members and encourage customer satisfaction through product integrity and our Code of Conduct.

We are committed to promoting high standards in equipment, workmanship, maintenance and service to the public – and ethical conduct within the industry. We also take the responsibility of eradicating any harmful business practices that might affect the industry.

Find out more

Contact Us

  • Address: 1st Floor West
    Helvetia House
    Greenvale Road
    Wilbart, Germiston

    Postal: Postnet Suite #86
    Private Bag X10020
    Edenvale 1610

  • Phone: +27 11 455 3157

  • Fax: +27 11 455 4126

  • Email: rosemary@saqccfire.co.za

Find Us