Now that some time has passed and the news about the change in the HU directive of 31.12.2019 (Verkehrsblatt 24/2019 No. 176) has reached all affected persons and companies, questions naturally arise as to how things will continue in the future after 01 January 2023. The GAGT e.V. will try to provide answers below.
The fact is, a gas system test for motor caravans and caravans according to DVGW G 607 worksheet will no longer exist in this form. Even beyond the time after January 2023. It should also be noted once again that this gas system test in accordance with DVGW may no longer be carried out as a so-called “provided test” until this date. Here is a written statement from the BMVI, Department STV 22 (BMVI) dated 10 May 2021, for the better understanding of all persons involved in the matter.
“Provided tests are tests which are carried out by a third party and the results of which are included in the test report by the test engineer (PI) for the purpose of carrying out the main inspection. In addition to the AU, the gas system inspections (GAP), the safety inspections (SP) and the performance of the follow-up inspections for the main inspection are also provided inspections.
In order to accept third-party inspections, they must be valid and comply with the requirements of ISO/IEC 17020:2012. If provided tests come from an accredited body, a test report with an accreditation symbol is sufficient as proof. Otherwise, the accepting inspection organisation (OB) must satisfy itself that the requirements of ISO/IEC 17020:2012 are met and document this. Recognised workshops that carry out provided tests must themselves be accredited or belong to an “accredited system” (umbrella organisation).
According to clause 6.3 of DIN EN ISO/IEC 17020:2012, certain requirements have to be met by the “provided tests” in case of subcontracting. To ensure these requirements (including metrological traceability of the equipment used, requirements for the competence of the personnel used, etc.), amendments to the HU Guideline were necessary.
For the test according to DVGW Code of Practice G 607 “Liquefied petroleum gas systems with a maximum consumption of 1.5 kg/h in road vehicles and in residential units for temporary use”, among other things, the metrological traceability of the devices used is not ensured, which is why the defect assessment D 6.1.3 b) is temporarily suspended within the scope of this test (via footnote 5 in Annex 2 of the “HU Guideline”).
The competence of the personnel used is also not ensured for the test according to DVGW Code of Practice G 607. The requirements for “Provided tests” result from the European specifications of the standardisation area. This area is represented internationally for Germany by the German Accreditation Body, end of quote.
Even in the past, these gas system tests according to DVGW G 607 were not “provided tests” with a “sovereign mandate”, which means that this type of gas system test according to DVGW G 607 is never specifically stipulated in the main inspection directive, e.g. like an exhaust emission test (AU) according to § 47 StVZO. Also, the gas system test (GAP), taking into account § 41a StVZO, has to do with Annex Part I and Part II, in relation to the regulation UN ECE R 115, (retrofit gas systems for vehicles equipped with engine drive).
This has now been clarified and is off the table. Of course, one person is now left behind. Namely, the dealers with their customers and the groups of people, as well as the members of monitoring organisations, who have participated in courses on the application of DVGW Code of Practice G 607 for years. This source of money has now dried up, and this for everyone involved. Anyone who is allowed to “test” at all in the future will have to be certified by the DAkks in Berlin, or elsewhere in Germany, according to DIN EN ISO/IEC 17020. However, the hurdles for certification are very high, and the companies also have to spend a lot of money.
In the hope that we have shed some light on the matter, we will take our leave for the moment. The question of who is responsible for all this, also in relation to the past, when millions of money have already flowed here, is something that every individual must now deal with. We, the GAGT e.V., will also have to ask further questions of the monitoring organisations, because how were all the money collected and spent booked to their accounts, when there were no official state requirements for these inspections?
Finally, it should also be said that motor caravan and caravan owners do not have to submit “gas system tests” in so-called test booklets in order to drive on campsites. Nevertheless, this is a case for the market surveillance of the federal states.
Let’s see how things develop in the future and what tricks the industry will come up with again to circumvent the legislator’s requirements.
Yours. Peter Ziegler CEO