EPA Consultation

Do you want to be allowed to use the same cylinders as people in the EU and US? To be legally allowed to put helium in your tanks? To use mixes with O2 < 21% or > 40%? To do an O2 flush at 6m? To have your cylinders filled on a humid day?

Filling cylinders in non-workplaces

The Environmental Protection Authority is consulting on Filling of SCUBA cylinders in non-workplaces. This is your opportunity to provide feedback through official channels.

Most of us would agree with the implied objectives of ensuring that people who fill cylinders are competent in doing so safely and that what they fill them with is safe to breathe. A modified version of the EPA’s proposal could be considered, but not without regulatory reform to address the reasons why people are filling cylinders that are not approved, and fill cylinders with gas mixtures that do not comply with the regulations. People should not be criminalised for not complying with the regulations, which are unreasonable and undermine the safety of divers.

What about workplaces?

While the consultation is about filling in non-workplaces, it talks about what cylinders can be filled and with what gases, referring to the same regulations as for workplaces and thus effectively provides an opportunity for feedback about regulations that affect both workplace and non-workplace filling.

Responding to the EPA

You can visit the EPA site about this consultation. Note that the consultation relating to SCUBA cylinders is just one small part of a long consultation document on a variety of topics such as pesticides.

If you wish, you can adapt this template response.

The template response covers a range of issues relating to SCUBA cylinder importation and filling that have arisen during the course of the petition, so please read it to ensure it reflects your views and add, change, delete portions as you wish.

  1. Download the template response.
  2. Put your name etc on page 1.
  3. Change, add or delete anything you like.
  4. Email it to hsnotices@epa.govt.nz.

Please also share this (or your revised version) with your networks.

Note: consultation closes 5pm, 19 April 2017.

Key points:

  1. The regulations are overly prescriptive, dangerously strict and out of touch with private and industry practice in New Zealand and internationally.
  2. The standards with which fillers are expected to comply should be freely available and accessible.
  3. The regulations need to be changed in order to increase safety in the diving community, increase consumer choice and reduce regulatory costs by pre‑approving the use of imported scuba diving cylinders that are approved for use in trusted jurisdictions such as Australia, the EU and the US.
  4. The standards specify maximum humidity levels that are sometimes unachievable even with the very best compressors.
  5. The regulations undermine diver safety by restricting the use of oxygen and helium in gas mixtures.