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Compliance of EU piping system with B31.3

Compliance of EU piping system with B31.3

Compliance of EU piping system with B31.3

(OP)
Greetings from Germany,

I'm really new to ASME B31.3 and so I would be really happy about some help on this code.

My Company manufactures gas Mixers for welding, heating, Food, etc. applications. We are now designing a mixer for use with N2/H2 that should comply with NFPA 86 requirements. NFPA 86 requires all piping to be in accordance with ASME B31.3.

Piping components/fittings are made of brass (EN CW614N) and piping/tubing is made of special copper for H2 usage (EN 1057 Cu-DHP). No welding/brazing, everything is threaded/compression type connection. For most materials we get EN 10204 material certificates from our suplliers. Our gas Mixers comply with PED and we have longterm experience (>40 years) in pressure designing/manufacturing such Mixers to EU Standards.

Now, according to B31.3 all of our components and materials are considered unlisted.

Q1: When it Comes to unlisted components, you are instantly redirected to 304.7.2 saying your components shall be based on the design criteria of this code (provisions of para. 302?) and substantiated at least by one of the means stated in (a) to (d). Well, Time/Money aspects lead us to (a). But what is „extensive, successful service experience”? What evidence is needed? Can we rely on 304.7.2 for a whole piping system like a gas mixer?Is this accepted by local authorities?

Q2: According to para. 323.1.2 unlisted materials may be used provided they conform to published specification. But what is a published specification? I found this interpretation from the ASME committee: „published specification is one that contains all of the information outlined in 323.1.2 and is available to the public.“. Here again: what does “available to the public” mean? I’m not sure whether this applies to EN material Standards or material certificates? Is a published specification limited to US-specifications?

I’m grateful for any information!
...and sorry for my bad English wink

Thanks,

Daniel

RE: Compliance of EU piping system with B31.3

Interesting topic. Ill try to help.

Why do your piping systems require both CE making, and NFPA86?

Yes, an EN standard can be considered a standard available to the public, as you, I, and everyone else can purchase them.

The other questions ill come back later on, hopefully your answers will shed some light first

RE: Compliance of EU piping system with B31.3

(OP)
Hi,

thanks for your reply.

Actually we already sold similar units to US customers, knowing they are safe (PED / longterm Service experience). But customers demand compliance with OSHA-standard, standards incorporated by reference, local codes, etc. NFPA 86 is one of the standards we need to follow. The information we got is that most US authorities don't care about CE marking. So we want to make sure that our products comply with US requirements.

Good to hear that EN Standards are considerd published specifications.

Now I'm hoping that we comply with 304.7.2.(a)....wink

Daniel

RE: Compliance of EU piping system with B31.3

304.7.2, to me, always has been a though one. Yes, "longterm experience (>40 years) in pressure designing/manufacturing such Mixers to EU Standards" may be used as an argument if you apply 304.7.2(a). Read other topics on this forum concerning the interpretation of that paragraph.

I would also reading more literature, e.g. books like Process Piping: The Complete Guide to ASME B31.3, which may give a better understanding to some wording in B31.3, when it comes from committee people who should know how it's meant.

However, if its the US market you supply to, then why dont you drop CE-marking, forget about the whole PED stuff, and re-design the system using materials (ASTM) and standards (ASME/MSS SP) acknowledged by ASME B31.3? That could make it a whole lot easier.

RE: Compliance of EU piping system with B31.3

(OP)
Hi,

I agree with you that re-designing with ASTM materials would be the cleanest way. But switching materials in a (more or less) serial production incl. third party suppliers is not a small matter. Costs would explode. In fact, the approach is to change as little as possible and as much as necessary. That's the reason I'm asking for interpreation of 304.7.2 wink

Maybe more literature will help. I will try to get the Guide to ASME B31.3.

Daniel

RE: Compliance of EU piping system with B31.3

I live in the EU over 10 years, but still don't care if a product bears a CE marking, as it only indicates that the manufacturer says it's suitable. With that kind of "certification", I would assume that nobody's really watching the fox in the hen house at all, are they, and that it really means it's only as good as the manufacturer's wants it to be at any given time. A product bought today might not be anything like the same thing you bought last year. Actually it might be a totally different machine, even though it could look exactly the same from the outside, and have the same CE marking, all the materials could be totally different, or similar. Whatever CE marks are, they are not a universal standard of quality, possibly meaning different things between a mfgr and each and every consumer. PED doesn't seem to be a whole lot more meaningful either, but I may be wrong. I just can't seem to find a reason to keep on reading it to the end.

I hate Windowz 8!!!!

RE: Compliance of EU piping system with B31.3

Quote:

Whatever CE marks are, they are not a universal standard of quality, ...

I think if you replace quality with safety, you've summed up the principle behind CE-marking.
Maybe looking at it from that perspective will convince you. Not that I'm a big believer of CE, but a few basic things make really good sense.

RE: Compliance of EU piping system with B31.3

(OP)
Hi,

I don't want to start a discussion about pros and cons of CE marks. But just for your information:
We are certified by a notifyed Body (TUV...maybe you know them) that we follow Module H of PED (full Quality assurance for manufacturing of products in the scope of PED). Our CE mark is followed by the number of that notifyed Body. So CE is about safety and Quality and is not always some kind of self-certification.

Daniel

RE: Compliance of EU piping system with B31.3

Oh yes I know TUV very well and that's another story. Probably better than any other kind of certification anywhere. I'd buy anything with TUV stamped on it. My only point was that a CE mark by itself alone is about as minimal a certification as one could possibly invent, useful as it may or may not be to some. I'd generally call it "convenient", rather than useful.

XL8
You're correct, it is safety, but thinking about that further, I'd just as soon not have to distinguish between those two essential ingredients. No wonder that I have problems with CE quality. No quality, but safe? I don't want that either.

I hate Windowz 8!!!!

RE: Compliance of EU piping system with B31.3

What you probably need to do is get a US registered PE or consultant engineering company to write you a report with the conclusion that your equipment complies with NFPA86, 31.3 because of clause x.y.z etc etc and then use this as "proof" to your US customers that all is well.

Given that API 5L is now married to ISO 3183, the insistence of only US codes is fading a bit. If you can use ISO codes instead of EN ones that would probably be better, but as noted above EN is a recognised body of standards with details equivalent to the US codes. You probably just need someone with an American accent to say that....

My motto: Learn something new every day

Also: There's usually a good reason why everyone does it that way

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