Thought purchasing your paintball air system for use in New Zealand was as simple as jumping online and purchasing off whatever shop had the best price? Think again – legislation and regulation regarding compressed gas cylinders in New Zealand and overseas is confusing, contradictory and hard to understand – even for those with years of experience in the industry.
We’ve just recently gone through the process of designing, manufacturing and importing our new range of imported Asylum Air systems NZ Legal Paintball Cylinders under the new UN system and have the first paintball specific tank to be approved in New Zealand with UN/ISO markings. While we aren’t the first to import a UNRTDG/ISO marked air system (others have tried with tanks which have not passed inspection due to incorrect labelling), we are the first to import a wholly UNRTDG compliant compressed air tank.
Hopefully this article will give the average paintball player an understanding of how this complex system works and importers an understanding of what is required to import a new air system correctly so that paintball players are no longer accidentally (or knowingly) sold air systems that are not legal to fill in New Zealand.
History of NZ Legal Paintball Cylinders
Due to paintball’s size, its use of compressed high pressure air cylinders had been overlooked for overlooked by regulators as we flew under the radar. This resulted in a complete and utter lack of regulation, with the better fields and event organisers self regulating while others filled tanks that were clearly dangerous. Players had to do their best to develop systems to ensure tanks were safe, with organisers generally adopting rules that met US or European best practice. This lack of regulation however had a side effect – tanks were not able to be hydrostatically tested in New Zealand.
Fast forward to 2004 and we saw law changes that regulated paintball, specifically under the Hazardous Substances (Compressed Gases) Regulations 2004. Over the years these laws have equally been adhered to and ignored by fields, tournament organisers, players and importers, depending on who you talk to.
In some areas you still have players filling illegal bottles without training and suppliers openly selling bottles that are not NZ legal, while others (especially in major cities, close to enforcement officers) stick closely to the letter of the law. There have been the odd threats of enforcement action at major tournaments, resulting in players moving to legal tanks, or some fields being shut down by EPA & WorksafeNZ (Formerly known as OSH & ERMA)
The Hazardous Substances (Compressed Gases) Regulations 2004
In New Zealand compressed gas cylinders fall under the Hazardous Substances (Compressed Gases) Regulations 2004. These regulations apply to any compressed gas cylinder that is minimum size and over, from a small paintball tank, right up to a petrol tanker. Compressed gas cylinders that are 500ml and below are exempt from the regulations, meaning that they exist in a regulatory wild west, there are literally no laws that regulate the importation, sale and filling of them – which can in effectively make filling a sub 500ml tank more dangerous, as they do not go under rigourous 3rd party testing, nor can they be hydrostatically tested.
Roughly speaking a 500ml tank is equivalent to a 12oz CO2 tank or a 30ci compressed air tank. Bear in mind that this exemption is measured by water capacity when the tank is filled with water right up to the neck of the threads (water volume is the total amount of water that it takes to fill the cylinder with any appliances (tap/regulator) fitted). There are some 12oz tanks that may be slightly over 500ml (approximately 507ml) and therefore require a LAB number in order to be used in New Zealand. There have been rumours of some 12oz cylinders over the years having the necks shaved down by dodgy importers to a 500ml water volume. If you find that your tank has a neck that has been modified post manufacture you should dispose of it and get a new one.
If you wish to use a tank it is far safer to go with a tank that has some form of independently verifiable third party testing than an unmarked, cheap sub 500ml tank. Also remember that these tanks only have a limited service life and cannot be hydrotested.
LAB Numbers Explained
LAB number is a unique special register number allocated to each individual pressure cylinder (e.g HPA tank) design.
Slight change in design or manufacture requires a different lab number. This number is placed on the tank label, either by manufacturer or a tank certifier. The process of approval and LAB certification has been put in place to prevent multiple cheap and potentially dangerous pressure cylinders from entering New Zealand
The process of gaining LAB number (and EPA approval) looks like this:
- Approval by the EPA of the design standard e.g. AS 2469:2005 Steel cylinders for compressed gases – Welded two-piece construction – 0. kg to 150kg
- Verification of the cylinder design by a design verifier (test certifier) and the issue of a design verification test certificate
- The allocation of a register number (LAB number) for the verified design by the EPA
- Pre-commissioning of the first shipment by a pre-commissioning tester (test certifier) including type testing of sample cylinders (where required) selected by the test certifier from the shipment, at a cylinder testing laboratory and the issue of a cylinder pre-commissioning test certificate
- Inspection and clearance of each shipment and issue of an imported cylinder test certificate by a test certifier prior to distribution
There are still people who openly sell bottles that do not have a LAB number and are not UN/ISO certified and thus illegal to fill in New Zealand. If you currently possess one of these bottles the best bet is to sell it on PBNation.com to a country which allows bottles like that, or dispose of it safely – do not resell it back into the New Zealand paintball market.
List of NZ Legal Paintball Cylinders with LAB Numbers
A full listing of cylinders that have LAB numbers can be found on the Register of Gas Cylinders document on the EPA Website. Most tanks are scuba tanks, LPG cylinders and the like, with the most important being the paintball specific tanks we are aware of (There are more than are actually listed on EPA fact sheets) below:
- 2046 Luxfer “P11F” High pressure air (HPA, 68cui, 4500psi, Composite (Aluminium, Fibre Wrapped) DISCONTINUED
- 2089 SCI High pressure air (HPA, 91cui, 4500psi, Composite (Aluminium, Fibre Wrapped) DISCONTINUED
- 2090 SCI High pressure air (HPA, 68cui, 4500psi, Composite (Aluminium, Fibre Wrapped) DISCONTINUED
- 2153 Catalina Carbon Dioxide (CO2, 20oz, 1800psi, Aluminum)
- 2154 Catalina Carbon Dioxide (CO2, 12oz, 1800psi, Aluminum)
- 2190 Catalina High pressure air (HPA,47cui, 3000psi Aluminum)
- 2209 Shanghai High Pressure Air (HPA, 0.7L, 3000psi Aluminum)
- 2257 Quing Pu Fire Carbon Dioxide (CO2, 0.68L, 1800psi, Aluminium)
- 2258 Quing Pu Fire Carbon Dioxide (CO2, 0.85L, 1800psi, Aluminium)
- 2259 Quing Pu Fire Carbon Dioxide (CO2, 0.7L,1800psi, Aluminium)
- 2331 Quing Pu Fire High Pressure Air (CO2/HPA,44cui, 1800/3000psi, Aluminium)
- 2346 Piper Impact Carbon Dioxide (CO2/HPA,50cui,1800/3000psi, Aluminium)
- 2418 Inspire High Pressure Air (CO2/HPA, 48cui, 1800/3000psi Aluminium)
IMPORTANT: Steel and alloy bottles usually do not have official expiry date, unless stated by manufacturer while carbon fibre wrapped cylinders have a working life of 15 years from manufacture – meaning that there are a lot of fibre wrapped cylinders which are currently nearing their use by date in New Zealand.
Luxfer P11F Fibre Wrapped Tanks (LAB 2046)
Due to the high costs of the certification process, the Luxfer P11F remained the only legal fibre wrapped 68cui paintball air system in New Zealand for close to 10 years.
This cylinder was originally made legal and given a LAB number through the hard word of the New Zealand Paintball Players Association (now defunct), Martin Dannefaerd and Grant McNeil (Bookie) around 2003-2004. With special mention also to Toby Marsh, Lex and Jared Ward.
On the 14th of January, 2014 we received the following email from Leonie Marshal the General Manager of Luxfer Gas Cylinders in Sydney, Australia:
“I have received word from our marketing people and they have confirmed that Luxfer exited the paintball market in September last year (2013). As this market was low margin business but high costs Luxfer took the direction to exit the paintball market. As products can be bought and sold through the internet this has driven pricing down for this type of product with a lot more competitors in the market treating this product as a commodity low priced product. For these reasons and more Luxfer no longer make or supply paintball cylinders. You will also notice that there are no paintball cylinders currently listed on our website.”
With this in mind a replacement was required for the most used compressed air tank in New Zealand, and it was needed fast!
UN Model Regulations Recommendations on the Transport of Dangerous Goods (UNRTDG)
The UN Recommendations on the Transport of Dangerous Goods are contained in two documents prepared by the Sub-Committee of Experts on the Transport of Dangerous Goods of the United Nations Economic and Social Council (ECOSOC). They cover the transport of dangerous goods by all modes of transport except by bulk tanker.
They are not obligatory or legally binding on individual countries, but have gained a wide degree of international acceptance forming the basis of several international agreements and many national laws
New Zealand appears to have adopted some of these these recommendations (specifically clause 18.104.22.168 of the UN Model Regulations Recommendations on the Transport of Dangerous Goods 17th revised edition) relating and adopted them with them being passed into law September 2012. As with anything regulatory involving paintball, nothing was ever actually passed onto industry, and these changes passed most of us by without noticing them.
Some time during 2013 various importers became aware of the changes that were to allow us to import these UN marked cylinders, and attempts were made to import various cylinders (the most common example is the Guerilla Air Cylinder), but none of them (although they all carried UN style markings) met the strict interpretations of the marking map in the clause 22.214.171.124 UNRTDG. A discussion group was formed involving industry stakeholders from across the country, as well as those with cylinders and regulatory experience.
Around November 5, 2013 the New Zealand Environmental Protection Authority released Environmental Protection Authority – Guide To Gas Cylinders (October 2013) which included updates referencing the changes to allow UN/ISO marked cylinders as well as various forms with new fields for UN markings.
UN marked cylinders are more appealing for importers as they do not need to go through the expensive process involved with LAB marking cylinders. Instead its a relatively simple process requiring importers to provide the manufacturers certificate to prove that the cylinders have been manufactured according to the UNRTDG requirements and upon importation a test certified must inspect the tanks and issue a test certificate. Tanks cannot legally be sold until the certificate is issued. While it might seem like a lot of red tape, its far cheaper than an importer spending between $5,000-$15,000 to get a new cylinder LABed only to find that other people can import it without covering any of the costs.
It turns out however, that while paintball cylinder manufacturers (who often subcontract manufacture to other companies) were aware of the UN requirements, they are yet to be adopted as the main form of certification, with DOT, EN and PI still being common place – even though UN/ISO is now recognised in Europe, USA, Canada and parts of South East Asia!
Due to this there are many incorrectly labelled (and therefore non compliant) cylinders on the market. The new mission was to find a cylinder which was carried the UN/ISO markings and was correctly labelled for importation into New Zealand. While it is possible for anyone retailer (or any individual) to import these new tanks, it is easy to screw it up (as others have found out the hard way). Here are the lessons that we learned along the way.
Incorrectly UN/ISO Labeled Cylinders – How Not to Do It:
The cylinder below, while meeting the technical standards for the UN/ISO certification, and legal practically everywhere else in the world does not currently (at the time of writing – this could change at any time, and the authors of this document are working on it) meet the New Zealand EPA’s strict interpretation of the labelling requirements. This means that it cannot currently be filled legally anywhere in New Zealand.
This doesn’t mean that theres anything “wrong” with the cylinder in terms of safety, what it means however is that the manufacturers did not follow the labelling rules as strictly as they should have. Providing future batches meet the labelling requirements this tank will eventually be legal in New Zealand. The reason – the text on the third horizontal line is not aligned correctly. This is why it is so important to get proper advice before importing a paintball cylinder of any type into New Zealand – if the markings are not 100% correct it will not be legal to fill. Just because it has the UN/ISO mark doesn’t mean it’s automatically ok for NZ – it has to have these markings done correctly, and the rules are very specific.
To check the marking guides yourself refer to clause 126.96.36.199 of the UN Model Regulations Recommendations on the Transport of Dangerous Goods 17th revised edition (UNRTDG) which is reproduced in full on page 117 at Environmental Protection Authority – Guide To Gas Cylinders (October 2013)
Correctly Labelling a UN/ISO Cylinder to UNRTDG Requirements – Our Experience
When we decided to start manufacturing a paintball cylinder we’d already head of the problems other suppliers had bringing in tanks. As far as we know there have been a few previous attempts to import UN marked cylinders before us, which have all failed due to minor technicalities.
We wanted to avoid any problems, so did what anyone should do when importing compressed gas cylinders into the country – consult an expert. We enlisted the help of Mike from Haztec to ensure that our cylinders were 100% compliant and correctly labelled as per clause 188.8.131.52 of UNRTDG.
Note that while our tanks were UN/ISO compliant in terms of manufacture, and our labelling was sufficient for most countries – it was not to the exact specifications required to make it legal where there is strict application of the marking maps such as NZ. The same problem with the tanks that had previously been attempted to import into NZ.
This goes to show how important professional advice is when importing paintball cylinders, and why you shouldn’t just purchase a tank from an overseas online store. Our advice from Haztec suggested that changes needed to be made to our tanks due to the following problems:
Line 2: “AA6061” is an additional marking and may be marked elsewhere on the cylinder but not within the UN marking map
Line 3: “π” and “1266” are European conformity markings and may be marked elsewhere on the cylinder but not within the UN marking map
The UN regulatory requirements under Section 184.108.40.206 of the UN Recommendations for the Transport of Dangerous Goods (UNRTDG), 18thEdition make it very clear what is and isn’t allowed within the marking map. Unfortunately many manufacturers don’t follow these requirements exactly, meaning that although the tanks may be “safe” they cannot legally have a cylinder test certificate issued in New Zealand.
So we had to go back and forth with our tank manufacturer and Haztec to ensure that our labelling 100% met the requirements to ensure that it can legally be imported into New Zealand and filled by approved fillers. Once we had the sign off from Mike at Haztech we added our custom design elements to the labelling before sending the bottles off to be manufactured.
After manufacturing, our bottles needed to be signed off by the third party verifier, in the case of ours – Arrowhead. This process took way longer than anticipated, as Arrowhead were unaware that NZ now accepted the UNRTG markings. We first had to contact the EPA and get them to confirm with Arrowhead that this was the case. We then ran into some problems with the labelling due to British requirements for paintball cylinders. End result being that we had to reprint all of our labels, resulting in anther production line delay of at least a week or two before these could finally be sent to New Zealand.
After manufacture, bottles then needed to be sent to New Zealand and go through the importation process. This applies for any importation of tank from one off ANSGear order, or 1000 if you are a wholesaler (this costs from $100-200 per shipment).
Importing Paintball Cylinders
Importing paintball cylinders with the UN Markings is a relatively straight forward process according to emails we’ve read from the Compressed Gases Working Group in October 2013.
First you need to ensure that the UNRTDG marking map is followed exactly and that any miscellaneous markings are outside of the map (Such as those for other standards such as EN, DOT and PI).
The cylinders manufacturers certificate must accompany the shipment and relates directly to that shipment, including all serial numbers, including proof that the cylinders have been manufactured and tested according to all requirements.
Finally cylinders need a test certifier to issue imported cylinder test certificates for the batch upon importation. All cylinders will be visually inspected (see test clearance procedure below) before being issued the certificate. Cylinders cannot be distributed or sold until the test certificate has been issued. Theoretically there will be a central listing of all cylinders that have been imported into New Zealand including their manufacturer, serial number, manufacture date and importation date. If your cylinder is not on that list, it’s technically illegal.
Importing cylinders under the old LAB regime is a little more expensive and complex as a design verification test and pre commissioning certificate is also required.
Its worth noting that the regulations, legislation, and official government communications basically assume that cylinders are being imported on a commercial bulk basis, and are written in a way that almost always refers to LAB numbered cylinders rather than UN marked cylinders, though this is slowly changing.
It isn’t currently clear regarding the process that an individual has to go through to import a single UN marked cylinder permanently or even what a travelling team has to do if they are attending a paintball tournament. We hope that the answer is simple and one along the lines of “they don’t have to do anything” and will be seeking advice to clarify the matter for the industry.
We strongly suggest that you purchase from a local supplier to ensure that a test certificate has been issued and all cylinder markings (be they UN or LAB) are correct – so that you don’t end up with a lemon that you can’t’ use. This isn’t anything new – even under the old regime a tank that was LABed overseas (such as tanks made for the Australian market but carried a LAB number) wasn’t technically legal unless the tank had a test certificate issued upon import and its serial number logged centrally.
Import Test Clearance Procedure for UNRTDG Cylinders in New Zealand
1. Purpose of import test clearance The purpose of an import test clearance is to verify that a cylinder has foreign test markings indicating that the cylinder has been tested in accordance with clause 220.127.116.11 of UNRTDG (and is therefore safe to be filled in New Zealand).
2. Verifying foreign design and construction certification If the first interval following manufacture specified in regulation 52(1) has not yet passed, a test certifier may issue an import test clearance for the cylinder if the cylinder is marked in accordance with clauses 18.104.22.168.1 to 22.214.171.124.5 of Chapter 6.2 of UNRTDG— (a) by or on behalf of the government of a country other than New Zealand; and (b) certifying that the cylinder has been designed and constructed, and passed initial inspections and tests, in accordance with Chapter 6.2 of UNRTDG.
3. Verifying foreign periodic testing If the first interval following manufacture specified in regulation 52(1) has passed, a test certifier may issue an import test clearance for a cylinder if the cylinder is marked in accordance with clause 126.96.36.199 of chapter 6.2 of UNRTDG— (a) by or on behalf of the government of a country other than New Zealand; and (b) with current periodic inspection and test markings that certify that the cylinder complies with the periodic inspection and testing requirements of clause 188.8.131.52 and 184.108.40.206 of chapter 6.2 of UNRTDG.
4. Issue of import test clearance If the test certifier issues an import test clearance for a cylinder, he or she must provide the Authority with a copy of the import test clearance.
5. Exception Despite clauses 2 and 3, a test certifier must not issue an import test clearance for a cylinder if he or she has reasonable grounds to believe that the cylinder— (a) is unsafe; or (b) despite its markings, does not comply with Chapter 6.2 of UNRTDG.
Source: Environmental Protection Authority – Guide To Gas Cylinders (October 2013)
Filling Paintball Cylinders
Cylinders must be filled by an approved filler who holds a current fillers certificate. Their certificate will identify the type of gasses that they are allowed to fill (in paintball’s case compressed air and CO2).
These certificates are easy to obtain for high pressure air, and can be arranged via dive shops that offer PADI or SCUBA training, or hazardous substances consultancies such as Haztec. Training generally takes a few hours, involves a multimedia presentation and a practical test. Certificates are valid for 5 years from date of issue.
Private training can also be arranged at Asylum Paintball’s training rooms for groups, teams or clubs.
IMPORTANT: ONLY FILL APPROVED PAINTBALL CYLINDERS, THAT HAVE VALID LAB MARKINGS OR UN MARKINGS AND THAT IS WITHIN ITS HYDRO PERIOD
Hydrostatic Testing of Paintball Cylinders
Cylinders must be periodically tested to ensure that they are safe, this is referred to as Hydrostatic testing or slang “getting hydroed”. The time between testing depends on the construction materials of the cylinder but generally speaking it is as follows:
- Fibre Wrapped Composite Cylinders – Every 3 Years
- Aluminium Cylinders – Every 5 Years
How Hydro Testing Works
Hydro testing for steel and alloy cylinders is a straightforward process. The valves are removed if fitted and then internally inspected for cracking or corrosion with two power magnifying mirrors and a 10 power monocle if needed. The cylinder is then filled with still water (water that is supplied from a non pressurised tank via gravity and contains no micro bubbles as pressurised tap water does)
The correct adapter is fitted and the cylinder is hydraulically pumped with water to the cylinders test pressure. it is held there for 30 seconds and slowly returned to no pressure, The amount the cylinder material has stretched during the test is measured by on a burrett and if it is within the limits according to the design the result is recorded and the cylinder is drained and dried it is then inspected again for cracks internally. The test date is stamped on the shoulder of the cylinder and a test certificate is issued.
Composite cylinders are much the same but more attention is required when inspecting the exterior of the cylinder as the resin can be damaged easily. As the composite material stretches more than a solid metal cylinder they cannot be measured in the same way, so must be tested in a water jacket (a large sealed drum filled with water and having an outlet to a calibrated scales) as the cylinder is taken up to test pressure the cylinder expands and forces water to exit the drum to the scales at test pressure this amount is recorded. If the recorded amount is within limits the cylinder is then dried and re inspected and a label with the test date is bonded to the cylinder.
IMPORTANT: Make sure that your tank is on the list of tanks with a LAB number or has valid UN markings otherwise it will fail under Section 6 of the HSNO regulations. Technically the testing station cannot give it back to you legally, and you will need an enforcement officer from the Ministry of Industry, Business & The Environment or The Environmental Protection Authority to Authorise its release. If they give a non compliant cylinder in working condition they face the risk of getting shut down. Usually the tank test officer will give you a call and inform you that a tank either non legal or failed the hydrotesting/safety inspection, they would then offer to dispose of it (destroy) or they return it to you with a whole in the sidewall/threads removed from the tank neck (so that tank regulator/valve cannot be affixed)
There are many facilities that can hydro test paintball cylinders, such as:
A full listing can be found on the EPA Test Certifier Registry.
Do you need your tank hydro tested, drop it off to us, and we will arrange hydro testing on your behalf for a small handling fee.
Environmental Protection Authority – Importing Paintball Cylinders (January 2013) Environmental Protection Authority – Guide To Gas Cylinders (October 2013) New Zealand Government – The Hazardous Substances and New Organisms Act 1996 New Zealand Government – Hazardous Substances (Compressed Gases) Regulations 2004 United Nations – Recommendations for the Transport of Dangerous Goods (UNRTDG), 17th Edition Volume II (2011) Written By Michael Earley, Consultant, Asylum Paintball & Alex Malikov, Asylum Paintball
- Grant McNeil, Compliance Consultant and Owner, Adrenalin Promotion
- Douglas McHardy, Site Manager, Dive HQ Rotorua
LAST UPDATED: 28 April, 2014