Roly, have there been additional mods/ devices that met these exemptions, or are you speaking of theoretical exemptions that might be met in the future?
I worded the post wrongly (now edited - thanks). As you say, it refers to possible exceptions for designs using alternative methods for gas dumping, or for designs where two batteries won't work even though they may fit. Etc.
but then after listing the appropriate language for vendors/manufacturers to use once compliant with EMSS, it says:
...or similar. This is because we have not inspected, tested and approved it. ECF cannot test and 'approve' any product, it is not a testing authority. We will list it as complying with EMSS.
So what are the ways in which completely new designs, or other conceivable "exceptions" can be properly appraised (if not outright inspected) for compliance by way of exemption from the EMSS?
We are prepared to give a new design an exemption on inspection (but without testing and approving it). In other words:
1. If it has obvious features that mean it is obviously unlikely to explode, we would exempt it. This specifically involves features that make it inarguably safer - such as the use of square section metal.
2. If it has features that can be verified immediately on switch-on: for example if it won't switch on since two batteries don't work in it, it will be exempted.
3. If it has features that require some form of testing of a destructive type in order to verify their efficiency, we cannot approve such a device, but will do so if:
a. Given a unit to inspect and return.
b. Given testing results that we can reasonably expect to have been carried out competently.
We would like to do this in a supportive way, in order to allow/produce more development, not stifle it. The idea is to get out of the current situation one way or another.
We cannot act as a testing & approvals agency as we don't have the facilities or funds. This is for the makers. If they show us new designs that are safe, with testing results to prove it, we would probably need to agree. If it looks as if I'm being a bit circumspect about this, it's because my experience tells me that this part of the industry contains a small number of people who couldn't care less about anyone's safety as long as they make a buck, and will do anything/everything possible to cut corners and costs no matter the price someone else pays in their health.
What the vendors have asked us to do
Several vendors have already asked, in the private Suppliers forum, that ECF consider banning metal tube mods of the type affected. We are told that the entire trade experienced a drop in sales across the board after the January and February incidents. There is plenty of support in the trade for either a ban on these metal tube mods, or some kind of serious restrictions on them.
I am unhappy with this for a multitude of reasons, including:
- I have several of these mods and see nothing wrong with them if they have certain design modifications. They are among my favorite devices because they almost always work faultlessly, there is very little to go wrong, there is a lot of bang for your buck, and they are easy to service. I wouldn't personally put two batteries in them, and every metal tube mod needs substantial gas vents regardless.
- A simple device will work even when other more complex ones have packed up.
- ECF has found that advice and gentle nudging are better options than bans, regulations and so on. One of the reasons is that the subtle approach helps to spread the effect wider. Bans just increase the hate and there is no evidence that bans work for anything.
- I have to take account of everything the trade tell me. This includes many of them saying there was a drop in sales (and the implication that there will more, bigger falls in sales with future incidents; not to mention a gigantic drop in sales if this results in government or State regulations) versus a few people disagreeing with the fitting of gas vent holes while offering no other alternative for discussion.
- I personally hate big government with a vengeance, and don't want anything to do with that kind of approach. This has to be balanced against ECF members being put in hospital, and legal restrictions being placed on ecigs in general, because of the explosive incidents, plus calls from some in the trade to ban these devices from ECF. Taking all these into account, it is hard to argue against the current ECF approach: advice, warnings, and an appeal for new designs.
Should a venting event occyr, the plugs would easily blow out and may even give advanced warning prior to going into full on flamethrower mode if the pressure builds up from the venting gas and pops the plugs out...giving the user time to drop the PV and avoid injury. Maybe....will need testing to confirm.
