Back to a discussion we had a couple of months ago… The issue: A local store whose management insisted that the VIP sticker must be stamped so that its “life” does not extend beyond the life of a hydro expiration date. For example, if a cylinder has hydro date stamped that expires this Dec, but a visual inspection was being done in May, then that VIP sticker must be falsely stamped as being done in the previous Dec so the sticker’s end date does not exceed the expiring hydro date. Why? The store owner says that it is too much to expect the fill station operator to check both the hydro date and the VIP sticker before filling a cylinder… And why would an inspector object to this practice? One reason is that conducting a viz in May, but stamping the viz sticker as if it was conducted in Dec, is falsifying the record.
So while I was at DEMA I asked the leadership of the two major cylinder inspection agencies for their opinions on the issue of back dating the VIP stickers so they will not exceed the stamped date of a hydro inspection. Both concur that the real issue is that the fill station operator needs to pay attention to his/her job, and only fill a cylinder if both dates indicate that the cylinder is “in date” for an allowable fill. Of course that assumes the employer (dive store or other entity) actually trains the fill station operator (which is a very explicit legal requirement - called function specific training!). And both agency leaders rightly point out that the only law or regulation that governs any of this issue involves CGA regs regarding hydros (since there are no actual regs that require VIPs).
Having said all that, Guy A from Agency A suggests that if the business can’t trust that their employees will actually inspect both the hydro date and the VIP sticker, then go ahead and back date the VIP sticker so it does not extend past the hydro expiration date. Q: Doesn’t that constitute “backdating the record” which is falsifying the record? A: Well… no, since there is no actual requirement to place a sticker on the cylinder. Q: But without a sticker there is no fill. ANS: Right, but it isn't a law. Q: But marking it Dec when it was inspected in May is not accurate. ANS: Well... yeah. Q: And the fact that the VIP sticker that has the inspector’s number on it (not the store, but the inspector!) with a form or other written record of the inspection now has date that will not match the sticker? Doesn't that put the veracity of the inspector in question? ANS: Uh… well… no answer… gotta go.
So I sought out Guy B at Agency B. Of course you don’t back date records. But remember that the VIP is not actually law, but obviously if you want the cylinder actually filled, you need a sticker, and a proper one. Why are we assuming that a fill station operator can’t conduct a basic fill protocol that involves checking the dates? There is even a term for the cursory inspection, and part of the law that talks about “function specific training” should cover this exact situation. [Now comes the ticker from Guy B at Agency B] Oh wait, you said this is from Florida… OK, I get it.
So there you have it. The expiration date dilemma as seen by the folks who train cylinder inspectors… with the recognition that practices in Florida might have to account for those riding the short bus.
I thought you might want to know.
Cheers
:doctor:
