I assume you have the EN161 paper (shutoff for automatic gas burners)and local comments or extensions available ? What exactly is said in writing? Comments from competing suppliers or local authorities?
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Anyway a comment from a valve specialist completly unfamiliar with this paper:
We are obviously talking about a critical safety aspect, where shortest possible closing time is positive and longer is negative (right?).
Test conditions should ideally be nearest possible practical.(Any rules laid down?)
For even a low pressure gas present through a valve I believe the closing time would be somewhat prolonged, and I suspect that the gas would have a rather drying than a greasing effect. (Any others with opinion?).
Conclusion: should be tested with gas at 'upper limit pressure' conditions if not other specified in EN161????