PED Question: Claiming Sound Engineering Practice
PED Question: Claiming Sound Engineering Practice
(OP)
We manufacture a couple of small cast aluminum pressure tanks that we are looking to sell in Europe. Both tanks fall under the Sound Engineering Practice article of the PED. The tanks are so old that we have no design or qual test documentation, only drawings and QA inspection test results.
Without having to wade through all of EN13445 or ASME VIII-1, what is the most expedient route to creating a technical file for these tanks showing SEP? I have been unable to find anyone that can say "For your tank, you need to calculate this and test to spec XYZ". The thought of looking through 712 pages of the EN13445 design spec alone is making me nauseous.
Thanks in advance,
-Mike
Without having to wade through all of EN13445 or ASME VIII-1, what is the most expedient route to creating a technical file for these tanks showing SEP? I have been unable to find anyone that can say "For your tank, you need to calculate this and test to spec XYZ". The thought of looking through 712 pages of the EN13445 design spec alone is making me nauseous.
Thanks in advance,
-Mike





RE: PED Question: Claiming Sound Engineering Practice
As far as we are concerned our notified body (Lloyd's Register) has advised us that for SEP items you do not need a technical file and you don't have to put a CE mark on them.
RE: PED Question: Claiming Sound Engineering Practice
What Lloyds Register should have told you is that for SEP Equipment you are NOT ALLOWED to put a CE mark on them rather than "you don't have to".
RE: PED Question: Claiming Sound Engineering Practice
First, thanks for the input. Second, do you know of anyone (i.e. consultant) that can help determine if these tanks comply with EN13445? Right now we have no calculations or test data and feel it would be prudent to confirm that we meet the requirements of EN13445 prior to selling these tanks in Europe, even if a technical file is unneccessary.
Thanks again,
-Mike
RE: PED Question: Claiming Sound Engineering Practice
RE: PED Question: Claiming Sound Engineering Practice
RE: PED Question: Claiming Sound Engineering Practice
Whessoe Technical Computing are not just contemplating including BS EN13445 into their PVE5 software but are busy doing it NOW. It should be incorporated later this year. PVE5 will then cover PD5500, ASME VIII and EN13445.
RE: PED Question: Claiming Sound Engineering Practice
RE: EN13445, CODEWARE: THE HOME OF COMPRESS, AND OTHER SOFTRWARE VENDER IS INCLUDING THE EN13445 FOR THE NEXT RELEASE.
ALSO, FE-PIPE
Leonard@thill.biz
www.thill.biz
RE: PED Question: Claiming Sound Engineering Practice
You do not have to use a design code at all.
The important thing with the Pressure Equipment Directive is that you fulfil the Essential safety requirements of Annex 1.
Within these requirements it is considered acceptable to design by experimentation, hence, if you are unsure about using a design code then you should construct some tests that show compliance with the Essential Safety Requirements of the directive.
Regarding SEP, you CANNOT CE mark a vessel considered to fall into Sound Engineering Practice as defined in Article 3 Paragraph 3. Howevere, if you check out the definition of Sound Engineering Practice on the PED web site (see FAQs in the CEN forum) you'll come to the same conclusion that we have that, to cover risk you should design the vessel along the same lines as a CE marked vessel.
Therefore, it would be prudent to find a notified body and to get them to aid you in performing your tests. This would cover you against all consumer protection legislation in Europe (in Europe a worker/operator is considered to be a consumer and falls within this legislation, this means that in the UK the Consumer Protection Act is more important than the Health & Safety at Work Act).
I notice that a similar post has been placed in the CEN forum so I'll copy this post.
RE: PED Question: Claiming Sound Engineering Practice
I'm basically doing what you've outlined in your message. We are drafting our own test specification that will address all the key design points of the vessel using ASME and EN requirements as a framework where applicable.
We are using the Hazard Assessment to guide development of both the qualification and continuous conformance test spec. The Cat. I and SEP tanks will be treated equally in this regard. We have also consulted with a Notified Body for their guidance.
You have confirmed for me that I am on the right track. Many thanks!
-Mike