I have received the response below, to my post of August 9th on this topic from Stuart Gray. I hope it contributes to the debate!
David Rushton


Dear Mr Rushton

As a former Director of the Steam Car Club of GB, a founder member of the new National Steam Car Association and a General Council member of the NTET, I feel that it is appropriate to offer you a response to your questions over your concerns as to the NTET's advice to Rally Organisers on steam cars and the questions concerning affiliation, both of the NSCA and the SCCGB (both old and new). I appreciate your concerns as does Mr Robert Herring, Chairman NTET, with whom I have discussed your post on the Steamcar website Forum.


On behalf of Mr Robert Herring and the NTET, I would first like to stress that the Trust has for some time sought advice from all groups associated with Steam Cars on their safe operation for not only their owners and exhibitors but also advice that would hopefully provide reduced risk for the general public and therefore offer suitable protection as well for event organisers. The TSU (Technical Services Unit) has shown a willingness to sit down and discuss a suitable scheme for Steam Cars.

Throughout 2007 and into 2008 the SCCGB had it's own Technical Committee under Mr Peter Williams who was working on behalf of the SCCGB with the NTET's TSU to arrive at a dedicated code of practice that would be suitable for all steam car users, when attending NTET authorised events. At the same time the SCCGB with it's affiliation to the NTET, decided at its AGM in Feb 2008 by a majority to endorse the NTET's Disc scheme.


Following this decision at the AGM, the then Directors of SCCGB who opposed this, overturned the decision as they considered this their prerogative under the Articles of Association and hence triggered the unfortunate divisions that followed.

I would like to quote extracts from a letter written by Bill Rich, then Chairman of the SCCGB to Peter Williams in September of last year;


...........There has been so much talk about rules and regulations, PSSR 2000, NTET discs and insurance that the committee wishes to state once and for all where we stand on these issues.........................

The club has had forced onto it rules and regulations copied from the NTET and the time has come that this must stop. Their rules are for traction engines and the like and should not be confused with steam cars.


The pressure systems regulations 2000 apply to those systems which are used or intended to be used at work and therefore do not apply to steam cars. The technical committee have mislead the club regarding the application of these rules to steam cars and are also incorrect in saying that it was agreed at the AGM that these rules be adopted.

It was agreed at the last AGM that NTET discs would not be required on cars attending club tours and at present the technical committee appear to agree with this until they change their minds.


On the question of insurance and boiler tests, it is not up to the club to dictate that all boilers of whatever type require to be tested...........

............The committee is in favour of a complete divorce from the NTET as it sees no merit in becoming a sub-section of a traction engine club.


The committee is also in favour of doing away with the code of practice as the club has dispensed with the need for a NTET disc, there is no incentive for the dictat by the NTET for the organisation to have a code of practice.

E. W. Rich (Chairman)

As a result the SCCGB did not renew its affiliation to the NTET in December last year.

The TSU has attempted to sit down with the former Directors at the time but this was offer was positively rebuffed.

As a consequence the NTET Executive had become concerned at the potential risk from steam car entrants to its approved rallies without any recognised form of competent examination of the pressure systems and the confusion that was being placed on the shoulders of Rally Organisers, hence the interpretation of our code of practice and the advice given. The point that you raise about fuel pressure systems does and will need further clarification. The NTET does not endorse either the Pressure Equipment Directive or PSSR 2000, but it does enter into the 'spirit' of both in its code of practice and Duty of Care ethos. Fuel Systems are for the most part outside the scope of both the Directive and the Regulations and therefore exempt, however with our Duty of Care ethos, in our code of practice we are currently, together with a number of our independent pressure systems inspectors, looking at devising a written scheme of examination for all steam cars with both fuel and steam pressure systems, that would be acceptable for both steam car owners and the inspectors. It is likely that the fuel pressure systems would only require a visual inspection of the system under working conditions to ensure that there are no leaks and that any pressure relief valves are operating correctly, as this would pose a risk if the valve did not function, thereby allowing the fuel pressure systems to reach unacceptable levels.

As for MOT's the jurisdiction of an inspector does not extend to any pressure system inspection, however an inspection of the fuel system resulting in the identification of a leak of any sort could I would suggest be a failure under their rules. I am not an MOT inspector so am only guessing here.

I hope that this helps allay some of your concerns. The launch of the NCSA at GDSF is purely coincidental that this announcement coincides with the notification to Rally Organisers.

Please do not hesitate to contact me or write to Robert Herring directly in future.

With best regards

Mike Clark has forwarded to me and the committee the following e-mail sent from Robert Herring, Chairman of the NTET, through Stuart Gray to our club. My observations are that Robert Herring is still not prepared to deal with the committee directly. I assume that Robert Herring by using the word onerous which as you know means “burdensome, causing or requiring trouble” simply confirms his and the NSCA’s intentions.

It’s not for Robert Herring or Stuart Gray to dictate to our club. We’ve already dealt with trouble makers over these past few months when our worldwide membership forced out the G15. I’m surprised that the G15 do not endorse PSSR2000 bearing in mind the grief they gave us all over it, it’s a famous U-turn in an attempt to find a new home. I don’t understand what is meant by “the spirit”, the law is the law. Their total lack of understanding of how steam cars work is amazing. There are numerous types of steam cars and they all operate differently, yet through ignorance they’ve tried to bring them all into one flawed rule. I have made a number of enquiries since receiving this, including talking to the much respected Tony Reen of SFP Inspection Consultancy one of the few inspectors qualified to operate under Health & Safety rules. He had no knowledge or input with regards to the claims made in this e-mail. We as a club have been operating for 20 years so why has the NTET taken 20 years to make this mistake whilst trying to dictate to us. I see it as no co-incidence that it has happened at the same time as the formation of the NSCA.

With regards to him claiming to have sought consultation with us in the past, I can find no record of it over the past years, in fact the NTET hardly recognized our existence. Had they consulted I’m sure that Peter Williams and co during their many speeches would have brought up that we weren’t co-operating, after all this was their pet topic including working to the strict guidelines of PSSR2000.

The NTET and NSCA clearly have no understanding with regards to MOTs, in fact the NTET never mentions it, albeit it’s the law. The NTET should stick to what it knows best, traction engines, and we will stick to what we know best, steam cars. Unfortunately the NTET has decided that it knows best with regards to steam cars, a catastrophe in the making. I ask one thing of Robert Herring and the NSCA that is to do one decent thing, GET BOB DYKE BACK AT DORSET. He’s been there for the past 20 years without trouble, he’s one of the best ambassadors the steam car movement has ever had and we all owe him a great debt of gratitude, including NSCA. They instigated this mess and should put it right and Robert Herring could easily do this, he only has to tell Dorset that a mistake has been made, which it clearly has with regards to fuel and boiler systems.

For the benefit of Robert Herring and NSCA I will point out that firstly the responsibility of one’s vehicle is that of the owner. With regards to steam cars you must have an MOT and you must also continue to keep the car road legal. Where boiler certification is required you must obey the full requirements of PSSR2000 and use a qualified inspector to do so. If the certificate you give to your insurers is not to this standard it’s possible that your insurance could be invalidated, and you must continue to maintain your boiler to this standard. You must declare your car to be a steam car to your insurers. You must also obtain a tax disc. If you do the above you will be road legal. You will also then, more than probably, meet all the standards required when attending off-road events.

May I suggest that in future we stop giving the NSCA a voice in any way on our Phorum, they don’t support us or the law, in fact they tried to destroy us and are still trying. They are in the past now and they’re isolated and I feel we should leave them there as a bad memory.


Dear Mr Clarke

We note the concerns expressed on your clubs Forum under the topic 'Chairman's Update' over the proposed inspection of fuel pressure systems on steam cars and the advice given to NTET Rally Organisers.

Our Chairman, Mr Robert Herring feels it is onerous on you to allow him the right of reply on behalf of the NTET and all steam car users and as such would be grateful if you could post the following statement from him.

Regards Stuart Gray, NTET General Council Member.



As the Chairman of the NTET I would like to offer some explanation to your concerns relating to the advice given to Rally Organisers over inspection of fuel pressure systems on all steam cars. We accept that this will still need further clarification. The NTET does not endorse either the Pressure Equipment Directive or PSSR 2000, but it does enter into the 'spirit' of both in its code of practice and Duty of Care ethos. Fuel Systems are for the most part outside the scope of both the Directive and the Regulations and therefore exempt, however with our Duty of Care ethos, in our code of practice we are currently, together with a number of our independent pressure systems inspectors, looking at devising a written scheme of examination for all steam cars with both fuel and steam pressure systems, that would be acceptable for both steam car owners and the inspectors. It is likely that the fuel pressure systems would only require a visual inspection of the system under working conditions to ensure that there are no leaks and that any fuel pressure relief valves are operating correctly, as this would pose a risk if the valve did not function, thereby allowing the fuel pressure systems to reach unacceptable levels. We have sought consultation with the former SCCGB in the past on the whole aspect of developing a code of practice and guidance for steam cars, that has been called for by our Rally Organisers and David Smith who heads the Technical Services Unit would be pleased to receive any constructive comments from all steam car owners and users on this subject, irrespective of what club or society that they represent.

Robert Herring - Chairman NTET

Hi Les,I have drawn up a "Declaration of Inspection" and anyone is free to examin my steam car at any event provided they have signed it.
What it does is make the examiner aware that he is legally responsible for; that which he/she is checking. The duration of the responsibility can be decided or may last until the next examination.
Any one signing such a declaration would have to satisfy him/herself that they are empowered to do so.
Copy attached to be used by anyone who wishes to do so.

Best wishes to all in the Steam Car Club of Great Britain, John Hill



Edited 1 times. Last edit at 08/13/09 09:20AM by John Hill.

The Chairman has written the following in his recent statement:-

"May I suggest that in future we stop giving the NSCA a voice in any way on our Phorum, they don’t support us or the law, in fact they tried to destroy us and are still trying. They are in the past now and they’re isolated and I feel we should leave them there as a bad memory"

May I add my voice to this sentiment. I agree that the G15 (NSCA) are best forgotten. They have caused our club untold heartache, especially to our past and present committee members. They have given Greg Walker and myself a lot of work in sorting out the limited company position and finances. They now seem intent in causing mayhem at the NTET yet their "club" is only a few weeks old.

Who do they think they are?

I agree with the Chairman. Let the phorum's webmaster,Jeff Theobald, have the authority to remove and ban all future communications with this mob on this phorum. This also to apply if they send in postings, via members, as they are at present doing.

Having done the onerous duty of passing on Mr Herring's message to the Committee who chose to let him air his views here I'd like to respond to him, or is it to Mr Grey who used the same words in his email to Mr Rushton.


So Messrs Herring/Grey tell us that the NTET do not endorse either the Pressure Equipment Directive or PSSR 2000. I don't really know what that means but I would have thought the Law of the Land stands whether the NTET endorse it or not. Do they mean that they don't require their members to comply with the law or is compliance voluntary or even obligatory? All a bit odd when the G14, to whom it now seems Mr Herring has attached himself, have spent the last two years beating the rest of us over compliance or not with these laws, and are even now using them to exclude non NSCA members from events such as the GDSF, particularly those who have monotube steam generators about which the Law itself is unclear.

Mr Herring has a curious attitude on the certification of fuel systems too. We heard that steam cars are to be excluded from the GDSF if they don't have a certificate for their pressurised fuel system but what do we find now? The NTET can't actually tell us how the certificate should be obtained and as yet have no protocol for testing as they are still cogitating about it. I wonder how the cars of the G14, which will be present at the GDSF have qualified under a rule which does not yet exist? Perhaps they will not be in steam or will follow a man with a red flag.

While the safety of pressurised fuel systems is of concern to us all, the comment about pressure relief valves shows a complete lack of understanding on the part of Mr Herring of how such fuel systems operate. On the Stanley for example fuel is pumped into a pair of tanks each about 2 litres in capacity, one contains a trapped cushion of air, the other contains fuel pumped in by the fuel pump powered by the engine. The only source of pressure is this engine driven fuel pump or the hand pump, both of which are controlled by the fuel automatic, a spring and diaphragm valve which by-passes the pumped fuel flow back to the unpressurised main tank when the pressure in the fuel system reaches the set pressure. There is no pressure relief valve as such. The proper working of this fuel automatic is constantly evident to the driver by means of the fuel pressure gauge on the dash and can be readily tested by operating the hand pump during firing up. Watching this gauge and paying proper attention to any fuel leaks are just part of the daily routine of the driver. Fuel leaks can in theory develop at any time and so a once-a-year inspection is of no great benefit. In any case as I have seen recently when getting my Stanley MOT tested the MOT examiner is required to inspect the fuel system of any petrol, diesel or gas powered vehicle for leaks, with and without the engine running (ie under working conditions). My MOT man will not test the car unless it is fired up for this very reason. A further annual examination by the boiler inspector would add nothing, quite apart from the fact that it is not required in law or by the insurance companies.

My personal feeling on the intervention of the NTET in the appearance of steam cars at events such as the GDSF is that they, possibly only a faction within the NTET, are intent on supporting their chums of the G14 in promoting the NSCA and are using every means they can think of to exclude members of the SCCGB so that the NSCA appears to be the leading organisation in the steam car world.

Mike




Edited 2 times. Last edit at 08/13/09 03:47PM by Mike Clark.

John - I do like your Declaration for Inspection!

You've illustrated exactly why our Club's legal advisors are so against the adoption of a Code of Practice - the responsibility it confers on the person or body issuing such a code or doing an inspection.

I've been a member of the Vintage Sports Car Club for 55 years and have seen how their scrutineering of cars for rallies has evolved to suit the current litigious climate. Years ago when entering a rally a car had to be scrutineered which involved an experienced member of the Club looking closely at it for defects in anything related to safety. Now, on legal advice, our rally scrutineers simply look at the MOT certificate, Tax disc and fire extinguisher and make sure the tyres are fit and that there are no fuel leaks. This avoids the Club becoming responsible by having endorsed the condition of a car which may subsequently be involved in an accident. The responsibility for the safety of the car remains where it should be, with the driver.

Please let me know if you find someone prepared to sign your Declaration and I will get him to look my car over too! My insurer might also be quite pleased to find someone with whom to share the burden and even agree to reduce my premium.

Mike





Edited 1 times. Last edit at 08/13/09 03:47PM by Mike Clark.

Hi Everyone,
As the NTET/NSCA are so concerned with safety and pressure systems, why have they overlooked another pressure vessel on steam cars and many other vehicles. The innocent TYRE. If Mr Williams is going to check my car for leaks(something most owners do everytime they fire up) will he check my tyre pressures for me as well!
Before he signs my Declaration for Examination, I will of course want to see his Written Scheme of Examination for checking my fuel system and if applicable my cars tyre pressures.
I am just off now to look at the common factors between a bulb horn and a monotube steam generator----------need to find a proof stress value for latex rubber------------wonder if anyone has done a risk assessment for the safe operation of bulb horns------.
John H

Hi all

Seems strange that FBHVC has worked hard to limit legislation on your veteran cars but the NSCA are working in the opposite direction. Okay I agree in working to a standard but imposing it is another matter.
How do you protect against 90 year old steering failure, wooden wheel collapse, owners machining parts themselves, unofficial aftermarket parts manufacture, loons driving over 50mph with rear brakes only. We are all becoming too risk averse.

Are you aware of The Right To Repair Campaign? This relates to new cars only but the extension to this is the exclusion of non approved repair to any vehicle.
Scare mongering? Well no, because you just need to look at the fight FBHVC has had with Europe over the last 20 years.

John, beware of RSI sqeezing that horn bulb!!

Brian

Thanks Brian, I had not considered that one!
Regards the loons driving at 50mph, I thought they were all in the other club. Talking of the other club rumour has it, one of the members had to repair his Hexane fuel line with a punture repair patch and a jubilee clip whilst on a tour. I must have missed that one in the Code of Practice! Does anyone know if this is true?
I have just obtained some figures from the National Bulb Horn Sqeezers Association and provided you keep the sqeeze frequency under 100sph, RSI should not be a problem.
I will keep you posted on the bulb horn/monogenerator comparison-------------now where did I put that exponential rule.

Regards John H

John,

It was not a rumour. It is stated in their No. 1 Magazine (only 43 to go to catch up) in an article by the man himself, Peter Williams, and I quote:-

"The Mountain Wagon developed a leak in the Hexane Tank which was sealed with a clamp and a puncture repair patch"

No sign of a jubilee clip not that that would improve the situation.

I wonder if his insurance company is happy to hear of this repair to a pressure vessel operating at around 30/35 psi and full of highly inflamable Hexane?

So much for their talk about inspections, safety and good workmanship. The word "loons" sums them up.

They caused our club horrendous problems and it seems they are now doing the same to the N.T.E.T. They are just trouble wherever they go.