PED Application 1

[alansutherland]

Hi,

Can anyone help me with a question on the application of PED. I have a decent understadning of the requirements of PED and how to apply the code, however the place where I am working is changing how 'things are done' and questions on how we need to apply the code are being asked.

If we own an asset and are then directly responsible for the design of any modifications that may fall into the requirements of PED do we need to still apply PED to the pipework. ie we are not putting anything into the open market which is what PED typically applies to?

My own concern is that we are putting items 'into service' which is a requirement of the PER regulations - however does this count if it is not going to be put into the open market.

Thoughts / comments appreciated.

Thanks

 

[DSB123]

Well alansutherland,
You have asked a good question. From the European PED we get the following "if the manufacturer of an assembly intends it to be placed on the market AND put into service as an assembly – and not in the form of its constituent nonassembled elements – that assembly must conform to this Directive; whereas, on the other hand, this Directive does not cover the assembly of pressure equipment on the site and under the responsibility of the user, as in the case of industrialinstallations"

Now I have deliberately changed the AND to capital letters because if you look at the UK version of the PED the AND is changed to OR. As such the PED is "all encompassing" in which the UK version covers anything manufactured or placed into service whereas the original intent was to cover pressure equipment that is manufactured (possibly by some cowboy down the road with a fab shop) AND put into service. The approaches are distinctly different. What you must remember the PED is for safety essentially and the original intent of the EU version was to prevent "Joe Bloggs" from manufacturing AND installing a boiler which was unsafe. The UK PED committee was basically made up of the insurance companies who wanted to have everything fall under the PED (if it were over 0.5 Bar)so they changed the UK version and the wording from AND to OR such that you had to apply the PED to everything that was over 0.5Barg. Crafty eh?? Lots of work for the NoBo's!!!! Obviously they would not own up to this but why change the word AND to OR otherwise!!!!

However in your case you are the "User" and as such do not have to apply the PED in my view as there are plenty of other Codes and Standards which you apply to ensure safety. The original EU PED was to cover people outside of the industrial areas where Codes and Standards are not used in order to protect the Public. After all Industrial plants have to follow national standards such as ASME, PSSR,PSR etc etc etc so the completed plant should be Code compliant and safe.

 

[ione]

Pressure equipment directive (97/23 ec) also known as PED is not a design code. Harmonised standards have to be used in Europe for the design of pressure equipment which fall under PED.
If the equipment or plant is under the PED jurisdiction and you apply any substantial modification to it, then it has to be considered as a new product covered by the directive (please check the attachment at page 5).
Pipes being part of an assembly will be under the directive as well.

 

[XL83NL]

Excellent point ione, a star for you. I was going to say the same. Guideline 1/4 is perhaps one of the best guidelines that approaches the OPs problem.

Furthermore, checking with the recently revised blue guide on CE marking may also shed some light.
Also, a quick check with your notified body may also help you a bit further.

 

[alansutherland]

Thanks for all the replies,

I think DSB123 covered what I was looking for best with the variation of the words from AND to OR. I use the guidelines a lot for small modifications to pipework - this is actually whata lot of our initial work is going to be all about. However once we begin to undertake larger jobs 'in-house' and possibly installing new systems there may be a requirement as the manufacturer (I have spoken to several fabricators who state that typically the design house is considered the manufacturer) to have the module conformity and ensure PMA's, technical files etc are completed and where required NoBO's notified etc etc.

However I guess one thing is that although the plant is owned and operated by the company I work for there is a lot of third party involvement in the operating of things so im not 100% sure where that leaves us. I am in the process of chatting to some third party PED experts to make sure what we do is legal!

 

[DSB123]

alansutherland,
Hope your third party "experts" have no affiliation with the NoBo's as they will definitely say it is under the PED. If you are the user then you do not really have to involve the NoBo, however all of the Pressure equipment you buy in to build the system (i.e. items that have been placed on the market) should be CE marked.