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PED question regarding equipment installed prior to PED

PED question regarding equipment installed prior to PED

(OP)
I've searched through the PED regulation (2014/68/EU) and I don't see any reference or discussion about equipment that was in service prior to PED. Are PED regulations retroactive?

It seems inconceivable to me that the answer would be yes. After all, most of today’s vessels and relief installations pre-date PED. Retroactive application would have a pretty high cost without producing any safety benefit, unless the existing PRD was improperly designed and/or installed. I expected that this would be a widely discussed topic, but after searching the internet and the PED text I came up empty.

Take, for example, an ASME Sec VIII vessel (installed in the 90's) that has two in-service PSVs (one set at the MAWP and the other set at 1.05MAWP) and the valves were sized for an accumulation of 16%, as permitted by ASME Sec VIII. PED allows the existing set pressures, but it doesn’t allow the 16% accumulation. For multiple relief devices, the PED allowed accumulation is still 10% for a non-fire case. Does PED require a field modification or is this installation grandfathered?

RE: PED question regarding equipment installed prior to PED

No, PED does not apply to old equipment (prior to PED) as long as parameters are not changed due to equipment modifications.

RE: PED question regarding equipment installed prior to PED

(OP)
micalbrch - Thanks for the response. It makes sense that PED would not apply retroactively. When this question comes up, I'd like to be able to reference a citation. Do you know where that it stated? Thanks.

RE: PED question regarding equipment installed prior to PED

From what I remember, this and a few other things only really get enforced when CE marking comes into play, and more importantly the re-work or refurbishment of that machine or piece of equipment. If "major" items are changed of replaced from within that machine/assembly, then a new assessment must be carried out, according to the latest revisions of the directives. So PED, machinery directive etc. to follow the ESHRs. Pretty sure you'll find it in CE marking advice or machinery directive guidance, not in PED.
Not sure if that helps much though.

RE: PED question regarding equipment installed prior to PED

Also PED certification may be mandated by the plant certifying authority, insurer, owner, other. The driver here is that familiar commercial term "cost" !

Regardless, per ISO, only the term Safety Valve is used for all overpressure eventualities.

RE: PED question regarding equipment installed prior to PED

See the following link - you can probably use this for quotation (apart from the PED Directive itself): http://ec.europa.eu/enterprise/sectors/pressure-an...

..."The Pressure Equipment Directive (97/23/EC) was adopted by the European Parliament and the European Council in May 1997. It has initially come into force on 29 November 1999. From that date until 29 May 2002 manufacturers had a choice between applying the pressure equipment directive or continuing with the application of the existing national legislation. From 30 May 2002 the pressure equipment directive is obligatory throughout the EU."

Dejan IVANOVIC
Process Engineer, MSChE

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