Fire extinguishers

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stevenconnor
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Fire extinguishers

Postby stevenconnor » Mon Feb 19, 2018 10:19 am

Thanks for alerting us to the MSA 'error' regarding dates.
http://www.monoposto.co.uk/2018/02/fire-extinguisher-regulations/

Can you seek some clarity from the MSA as their rule is very difficult to follow and I am not sure I agree with your interpretation:

"Fire Extinguishers
Existing vehicles competing prior to 1st January
2019 may comply with the following until
1st January 2022. New build vehicles from
1st January 2019 must comply with Appendix 3.
3. A fire extinguisher/extinguishing system must be
carried on all vehicles, the minimum requirement being
that the system be charged with one of the permitted
extinguishants and be operable by the driver whilst
normally seated either by manual operation or by a
mechanically/electrically assisted triggering system.
All extinguishers must be serviced in accordance with
the manufacturers guidelines, or every 24 months,
whichever is sooner."

Thoughts
1. Any regulation (in any field) that uses the words "may comply" instead of "must comply" suggests it doesn't have the element of regulatory requirement..
2. I read that as existing vehicles have until 1st Jan 2022?

It is a very strange wording.

Also, as we are told the published regs are the published regs we must adhere too... doesn't this work the other way as well and both the above queries are irrelevant as the date published is 1st January 2019?

Thanks

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Anson
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Re: Fire extinguishers

Postby Anson » Mon Feb 19, 2018 10:25 am

I have always worked on the basis that the fire-ex has to be "in date" just like belts - that meant being serviced by an approved (by the manufacturer) servicer every two years. The only difference I can read into this is that some manufacturers may want to service more frequently than every 24 months and if so the shorter period will be applicable..
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Rachel
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Re: Fire extinguishers

Postby Rachel » Tue Feb 20, 2018 11:47 am

Hi Steven,

In answer to your points:

1. I will leave it to you to argue semantics with the scrutineers, but in my experience it rarely works. I assume they have used it to suggest that they may choose to comply with the current regulations rather than the updated ones in Appendix 3.

2. As I read the regs, (allowing for their advised error in date where it should say 2018 not 2019):

Competing vehicles that existed before 1st January 2018 must comply to K3 (which states that extinguishers must be serviced every 24 months) and the rest of the Fire Extinguisher regulations (3.1 - 3.5) until 2022.

Additionally to that any new build vehicles from 1st January 2018 must comply with Appendix 3, which is on page 195 of the blue book, and ALL vehicles must comply with it from 2022. Appendix 3 appears to be an updated version of K3.1-3.5.

Regarding your point about adhering to published regs, the MSA continually updates the regs and sends out amendments. As a competitor you should get these bulletins from them via email and in the magazine.

If you read A 2.5 (Page 50 of the current blue book) it states that they "reserve the right at any time to alter these Regulations".

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jonathanbaggott
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Re: Fire extinguishers

Postby jonathanbaggott » Wed Feb 21, 2018 5:53 pm

On a related thought, anyone going to Zandvoort will have to have an up to date fire extinguisher,as well as flame retardant underwear !

stevenconnor
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Re: Fire extinguishers

Postby stevenconnor » Wed Feb 21, 2018 10:12 pm

Thank you Rachel,

Leaving out semantics, what my research suggests is the following:

It appears the intention of the MSA was to mandate that, for the first time in MSA regs, from 01-01-2018 it would be compulsory that all extinguishers must have been serviced within the last 2 years where as in the past it was only recommended. To this effect the MSA published a revised K3 with these changes.

It is recommended that a All extinguishers are must be serviced in accordance with the manufacturers guidelines, or every 24 months, whichever is sooner.”

The confusion comes that the way it is printed in the Blue Book as it appears to be linked to the preceding paragraph which refers to:

“Existing vehicles competing prior to 1st January 2019 may comply with the following until 1st January 2022. New build vehicles from 1st January 2019 must comply with Appendix 3. “
Had this paragraph not been present then the rule change to MUST be serviced would have been clearer.

The 2019 date error you mentioned was in the document https://www.msauk.org/assets/rulechangesoctober2017.pdf which appears to make all the changes have a start date of 2019. The use of 2019 in the Blue Book appeared to confirm this but is actually regarding when the change from MSA rules to FIA rules apply to a particular car that competes before 01-01-2019 and not an implementation date of the rule.

Had there been a clear differentiation between the two paragraphs all might have been a lot clearer..

The MSA intend for us to require FIA homologated extinguisher systems from 2022 (and any new car competing after 01-01-2019 must comply to FIA homologation)

“Reason: Regulation K3 As an interim measure before the proposed requirement for FIA homologated extinguishers in in place (FIA homologation mandates a service requirement). This proposal will ensure that the non-homologated systems are serviced at least every 2 years which is advised the manufacturers.” From Oct 2017 MSA rules changes

Those of us with cars that have already competed can therefore continue to use MSA spec extinguishers (2.25L AFFF being the most common I believe) until 01-01-2022 but after that date we must fit FIA homologated systems (presumably with the FIA stickers) and that is going to mean new extinguisher systems. 2.25L AFFF will not comply with the FIA requirement, thus larger capacity and different content systems will be required.

The MSA do not mandate any sort of 'passport' or other proof of service so for now until 2022 presumably the handwritten stickers with dates on affixed to MSA complying extinguishers will be the only way a scrutineer can check if an extinguisher has been serviced within the preceding 24 months (not just the preceding 2 seasons – so no “Not valid after year XYZ“ date like seat belts ).
Good luck to them reading that on all the extinguishers in all the race cars.

At the Mono Spa events we have always had to advise people to have their extinguishers ‘in date’ as a requirement rather than only being recommended for MSA events held in the UK.
For Zandvoort this year will we require FIA homologated extinguishers?

Thanks.


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