Remanufactured is an unusual word. It's long, it's kind of awkward and certainly isn't in common use in the fire industry. The term refurbished is the mainstay. However, the process of refurbishing might mean different things to different people. I hear about bad actors, unsafe practices or poor quality but then if we step back from the situation it might be that each company undertaking the refurbishment of fire safety products is aiming for a different thing: A different segment of the market at different price points and expectations. A company that is going to strenuous lengths to ensure that an assembly utilising second-hand components is of the highest quality might feel aggrieved if another organisation has just dusted down and refilled an old fire extinguisher assembly and then adorned it with a new label. They are not the same things obviously. But if they just share the same banner of refurbished it's easy to understand where the friction comes from.
Such is the case with fire safety equipment it's hard to know the difference between effective and ineffective products until they are needed at that crucial moment. It's not as if you can go home and give the fire extinguisher a quick test squirt - they are for one-time use and need to be serviced afterwards. And it's not really obvious if the pressure vessel's integrity is compromised by stress corrosion cracking or internal corrosion. With uncertainty, consumers might just steer clear of refurbishing altogether thinking it's not worth risking the unknown to save a small amount of money.
Remanufactured is a term taken from BS 8887 - Part 220 Design for manufacture, assembly, disassembly, and end-of-life processing (MADE). The process of remanufacturing. The definition is to return a used product to at least its original performance with a warranty that is equivalent to or better than that of the newly manufactured product. It's an important standard as it provides a framework to determine what is good and bad practice for the production of assemblies using second-hand components. It stands to reason that without a common definition of what good looks like then there are going to be varying interpretations. In essence, the blueprint for what good looks like is what any standard aims to achieve. Like the British Standards BS 5750, BS 7750 and BS 8800 that gave rise to quality systems ISO9001, 14001, 45001 and others. It might be that BS 8887 takes a similar path as the world taking a more purposeful approach to sustainability.
With growing environmental sentiment things have changed over recent years with more focus on reusing, recycling, and sustainability. Second-hand is now trendy. Environmental considerations make their way into tender documents. Consumers are demanding that organizations be more environmentally conscious, and they are voting with their feet.
Life safety products have been slow to adopt the circular economy. It's a cautious industry sector and with evidently good reason - function first. Always.
I didn't lead the article with environmental statements for that reason. Green is now the agenda, but function will always remain the absolute priority. Even ozone-depleting gases such as halon get a pass when it comes to firefighting given their proven effectiveness. Fire products have to save lives first and foremost.
It's not as if the fire industry has been ignoring environmental considerations. The adoption of C6 foams following regulation changes is one example. Using second-hand components is another proposition entirely. It's difficult to ensure consistent performance if the ingredients themselves are not consistent. Think of the circular economy for a fire extinguisher as being a full production process. It's originally made under a type of approval, it goes on to a 10-year service life under varying conditions, The components are then taken and used in a new assembly. That's a 10-year gap where the "processes" undertaken on that component are unknown. The solution is to test and inspect the component to ensure that the performance is maintained as well as any anticipated issues are mitigated.
What is KM certification under BS 8887?
Kitemark certification for remanufactured fire extinguishers currently limits the scope to carbon dioxide fire extinguishers. The scheme evaluates and certifies the processes to produce assemblies utilising second-hand cylinders. It's not the same as a KM certification affixed to new-type approved items, however, there is a significant focus on the consistency of the original equipment so that the performance is maintained. In-process inspections and operations are borrowed from BS 5306-3 with additional requirements for batch production tests in accordance with limited clauses of EN 3-7. Pressure safety certification is a pre-requisite for the scheme and is also offered by BSI.
One of the driving factors for a certification scheme for second-hand equipment has been the uncertainty around the application of the Pressure equipment directive and Pressure equipment (safety) regulation. The HSE in the UK has provided specific guidance on the topic for machinery and medical devices but nothing specific for pressure equipment. This puts conscientious organisations in a quandary. The EU commission Blue Guide section 2.1 offers the following information: Products which have been repaired or exchanged (for example following a defect), without changing the original performance, purpose or type, are not to be considered new products according to union harmonisation legislation. It's clear that the intention is to allow a product that has already been placed on the market to have its life extended by servicing. In the case of a fire extinguisher where all but the cylinder has been replaced, there is more ambiguity.
I would challenge any uncertainty with regard to the regulation with the idea that we shouldn’t wait to be told what the legal minimum is and instead be striving to push the market forward.
The term remanufacture is just a term, but it is useful for differentiation. If those companies targeting a lesser standard of quality have tarnished the term refurbished, then let them stick with it. BSI offers manufacturers of quality assemblies utilising second-hand components the ability to differentiate themselves and provide assurance to the market so they can participate in the much-needed circular economy which is important for environmental sustainability.
With our remanufactured KM scheme for fire extinguishers, BSI is striving to enable more environmental choices as well as enabling safer choices.
