I am not an advocate of rules and regulations if they can be avoided and have serious doubts as to whether the formal testing and certification of our model boilers is actually avoiding any hazardous incidents.  We built, tested and managed our boilers for many years without any formal control and I am unaware of any accidents that would have been prevented had the boiler involved had a number stamped on it with an associated piece of paper. However, it was inevitable that we would be drawn into the Health and Safety culture which is engulfing our lives and the Code published by the British Model Engineering Liaison Group entitled “The Examination and Testing of Miniature Steam Boilers” has been designed to meet the recommendations of the HSE and the requirements of insurers.  Although the Code does not directly impose any legal requirements it would no doubt be invoked when deciding any insurance claim or settling litigation arising from a boiler incident and should therefore be clear and unequivocal in its statements and requirements.  I believe that in some respects the document leaves something to be desired and would value the comments of the authors of the Code.  One particular area of concern is the design, manufacture and testing of boiler fittings.  A problem has arisen recently in my own Club concerning the design of screw down steam valves (e.g. blower valves, injector steam valves and blow down valves).  The Code suggests that the inspector “should” check that the spindles of these valves are captive.  It does not say what should be done if they are not so – the inspector is only advised to check – “should” is advisory, “shall” is mandatory.  If the boiler is new it might seem reasonable for the inspector to require the valves to be modified or replaced.  If however the boiler is undergoing a re-test and was originally certified before the date on which the Code became effective (1^st Jan 2006) is it reasonable to require modification before renewing the certification?  There must be thousands of boilers built to LBSC and Martin Evans designs to name but a few which do not satisfy this requirement (and some other requirements for that matter).  Should they be refused re-certification?  Should a conditional certificate be issued requiring modification before the next test?  Should the matter be left to the discretion of the boiler tester as is the case with the Australian Code, which is far more comprehensive and rigorous than ours and which states that it is not retrospective to boilers registered before the date on which the Code became effective? >>