Federal Institute for Materials Research
and Testing
Dept. ERFA-MÜoD
Mrs. Dipl.-Ing. Christiane Kühl
Unter den Eichen 44-46
D-12203 Berlin
Dear Ladies and Gentlemen, Dear Ms. Kühl,
on 06.04.2021 the ” German Association for Gas Technology e.V. (GAGT) has sent a letter with serious infringements of the gas industry and its marketers/dealers with regard to the Ortsbewegliche Druckgeräte-Verordnung (ODV). Since, as you know, these are serious deficiencies, which are also of considerable importance for the consumer, especially in the case of accidents with pressurised gas containers and their use, it now seems time to ask what the current state of affairs is from the point of view of the 16th federal states. Enquiries to the responsible departments of the federal states in detail are refused and the responsibilities are denied.
If the Federal Republic of Germany, with its 16 federal states, should be of the opinion that it can ignore the generally valid EU legislation (regulations), we will inform the EU Commission in detail about the state of affairs, if no other way is possible. Furthermore, the question should be allowed whether the German gas industry has already gained the upper hand over the requirements of the EU (ODV) and you are not in a position to enforce the ODV in all its points (16th federal state). A declaration of conformity is an absolute must when placing goods on the market in the European Economic Area, especially as this is nothing other than a dangerous goods container according to ADR. Why does this apparently not apply to pressurised gas containers in accordance with the ProdSG, as well as other similar goods in this sector, or are accidents and their consequences for people, animals and damage to property being accepted?
