Transcript DEVELOPMENTS IN THE PED AND GUIDELINES

Pressure Equipment Workshop
Romania – Session II part 2
DEVELOPMENTS IN PED,
GUIDELINES, STANDARDS
Ed Haynes
(CEN Consultant)
RHETORICAL QUESTIONS
 When legislation is drafted:
Is it always clearly written?
Are all foreseeable circumstances covered?
 Do you have access to PED Guidelines in [your] language?
 What is the legal status of the Guidelines in your country?
 Is there an easy way to implement the thinking in the guidelines?
 If you are a manufacturer exporting to a country which does not
have strong views on Guidelines, can you ignore them?
 How active is your National Standards Body in standards
development?
Guidelines (1)
• Facilitate coherent and consistent implementation of
Community legislation.
• Not legally binding but are an interpretation agreed by:
• Member States and interested parties, for example:

Users

Manufacturers (via Orgalime)

Notified Bodies

CEN Consultant
• Therefore it would be difficult for Member States
authorities and the Commission to ignore them in Market
Surveillance and monitoring of Notified Bodies
Guidelines (2)
• Drafted by the Working Party Guidelines
(WPG)
• Agreed by the Working Group Pressure
(WGP)
• Available in English, French, and German
• Hyper-text linked to the PED on website
• http://ec.europa.eu/enterprise/pressure_eq
uipment/ped/guidelines/guid-intro_en.html
Guidelines (3)
• Answer issues that are raised as common problems
• Clarify the intent of the PED
• Explain the text of the PED where the wording is unclear
to some readers
• Point out differences amongst linguistic versions of the
PED
• Refer to other guidance such as the “Blue Guide”
• Provide examples (to be read widely for applicability to
analogous situations)
• Try to capture the philosophy of those involved in early
stages of the PED
> 200 Guidelines in 10 groups
1 Scope and exclusions of the directive
2. Classification and categories.
3. Assemblies
4. Evaluation assessment procedures
5. Interpretation of essential requirements on design
6. Interpretation of ESRs on manufacturing
7. Interpretation of ESRs on materials
8, Interpretation of other ESRs
9. Miscellaneous
10. General/Horizontal issues
Distribution of Guidelines (approx)
PED Articles
Article 1 = 65 Guidelines mostly series 1
Article 3 = 40 Guidelines
Article 9 = 9 Guidelines
Articles 10 = 11 Guidelines
Articles 4, 5,11, 14, 15, 20 less than 4 in each
Articles 2, 6, 7, 8, 13, 14, 21 No Guidelines
Numbers of Guidelines (cont’d)
PED Annex I
Prelim observations = 6 Guidelines
ESRs in section 1 = 3 Guidelines
ESRs in section 2 = 11 Guidelines
ESRs in section 3 = 30 Guidelines
ESRs in section 4 = 18 Guidelines
ESRs in section 7 = 8 Guidelines
ESRs in sections 1, 5, 6 = less than 3 in each
PED Annex II = 10 Guidelines
PED Annex III = 7 Guidelines
PED Annexes IV to VII = nil
Guidelines (80:20 rule?)
PED Articles
Article 1, Scope and definitions 65 Guidelines
(33%)
Article 3 Technical requirements 40 Guidelines
(20%)
PED Annex I
Section 2 Design = 11 Guidelines (6%)
Section 3 Manufacture = 30 Guidelines (15%)
Section 4 Free movement = 18 Guidelines (9%)
Observations and conclusions
The number of new Guidelines added
recently has reduced significantly,
indicating that the task nears completion.
Some Articles and ESRs do not seem to
cause problems (or are they necessary?)
Some principles should be derived, detail
simplified, and results added to facilitate
interpretation and application of the PED.
Difficult or contentious areas (1)
Article 1.2.1.2 Guideline 2/4
• Is this clear and/or too long?
• Is this an example for a revision in the PED?
Article 3 Technical requirements – are they too
onerous in view of their empirical nature?
(Categories I to IV and SEP Article 3.3)
Note: for some sizes and duties, the risk category of a
vessel determined for the Simple Pressure Vessels
Directive 87/404 is different from that for the PED
Difficult or contentious areas (1a)
Article 1.3 Exclusions
• Does not explain the reasons for the
exclusions, focusing on objectives of
promoting trade, avoiding duplication in
low-risk situations
• Does not explain the logic of when
something is or is not mentioned as an
exclusion.
Difficult or contentious areas (1b)
Article 1.3 Exclusions
e.g. Should Pipelines exclusion 3.1 acknowledge
the state of development of the gas supply
infrastructure at the time of writing the PED, the
existing coverage within National Legislation and
the limited extent of further development of that
infrastructure.
e.g. Should Vehicle exclusion 3.5 explain the
differences between equipment mounted on
vehicles and equipment necessary for them to
function, also in relation to the older Directives
cited.
Difficult or contentious areas (2)
Annex I Essential Safety Requirements (ESRs)
Preliminary observations (6 Guidelines)
Hazard analysis is frequently mis-understood,
even though clearly stated.
Should there be a standard? (cf. CEN/TC 114:
EN 1050:1996 for hazards related to Machinery)
Difficult or contentious areas (3)
Annex I ESRs Section 2
Design is very important but there are only 11
Guidelines on this subject.
Are design standards sufficiently developed to
address the issues adequately?
Is the 6000 bar*litre limitation on experimental
design meaningful?
Are the differences between ESRs 2.10 and 2.11
clear? (Protection against exceeding allowable limits
and Safety accessories)
Difficult or contentious areas (3b)
Assemblies
Range of sizes (e.g. fire extinguisher or
pressure cooker up to petrochemical plant)
Do the 17 Guidelines explain the differences
between designation of equipment
comprising the assembly for purposes of
conformity assessment (PED Annex III)
and classification of risk (Annexes I &II)?
Difficult or contentious areas (4)
Annex I ESRs Section 3
Why are there so many Guidelines on
permanent joining (Guidelines series 6?)
Can they be merged?
Now that EN ISO standards on welding are
well-established, is this detail necessary?
(EN ISO 15609 and 15614 series etc)
Difficult or contentious areas (5)
Annex I ESRs Section 4 (also ESR 7.5)
Materials (18 Guidelines in series 7)
Difficult area in standards-making
Former national practices
Are the requirements in the PED too onerous?
Do the guidelines exceed the ESRs?
What happens if EN materials are not available?
Are manufacturers and Notified Bodies breaking
the rules?
Omissions and overlaps (1)
Does the PED cover too much or too little?
Should it apply to one-off equipment as well
as serially produced items e.g. fire
extinguishers, simple pressure vessels?
Should there be (special) provision for
serially produced items?
Are there too many or too few exclusions?
Intelligibility to non-Europeans
Omissions and overlaps (2)
Life cycle of pressure equipment
Putting into service – e.g. boilers and safety
valves; baseline inspection
Operational restrictions follow from
manufacturer's hazard analysis
In-service inspection frequencies
Role of National Authorities
Omissions and overlaps (3)
Environmental considerations
e.g. CEN/TC 182 considers this in EN 378
series
CEN Environmental Help Desk
Operational efficiency
Repair and change of duty – availability of
records
Ultimate disposal
Alternative or parallel thinking
• Guidance exists for other Directives in a
form which is easy to read and assimilate
e.g. ATEX
• If the PED was revised to address the
issues raised as guidelines, would that
answer all the issues?
Proposals for future of PED
Guidelines
• Essential messages should not be lost
• They should be consolidated or
incorporated in the PED to make it easier
to understand the philosophy and apply it
to situations not yet addressed
• Encourage those with responsibilities
under the PED to answer their own
questions
Specific Guideline 8/15
8/15 refers to ESRs 1, 2, 3, 5
Is this a mis-use of the purpose of guidelines
and/or a useful pointer to standardisation?
Horizontal Issues
• Is there relevant guidance associated with
other Directives?
• Is that guidance in line with the present
PED Guidelines?
Links to Standardisation
Since it is not mandatory to use EN / EN ISO, how
can we promote and encourage their use?
Are the risks of not using EN which include
guideline concepts clear to those who choose
not to use these standards?
Is it clear that using EN provides advantage in
compliance with PED as well as technical and
economic benefits?
Standardisation
• CEN, the European Committee for
Standardization, was founded by the national
standards bodies in EEC and EFTA.
• Now CEN is contributing to the objectives of the
EU and EEA with voluntary technical standards
which promote free trade, the safety of workers
and consumers, … environmental protection,
exploitation of research and development
programmes, and public procurement
Pressure Equipment Sector (1)
Adopted standards
• 213 European Standards are available.
They provide presumption of conformity to
essential requirements of the PED
• 20 standards provide presumption of conformity
to essential requirements of the Simple Pressure
Vessels Directive (87/404/EEC)
Pressure Equipment Sector (2)
66 projects leading to European Standards
providing presumption of conformity to
ESRs of PED in development and 3 for
87/404. (September 2006)
Available documents including pressure
equipment, pipes, tanks and accessories:
• 590 Normative documents
• 59 Amendments
Product standards: 2002
Pressure vessels EN 13445 series (10 parts)
(CEN/TC 54)
Boilers EN 12952 and 12953 series
(CEN/TC 269)
(CEN/TC 57 = Central heating boilers)
(Metallic Industrial) Piping EN 13480 series
(6 parts)
(CEN/TC 267)
Product standards (CEN/TCs)
• 23 Transportable gas cylinders
• 155 Plastics piping systems and ducting
systems
• 182 Refrigerating systems
• 210 GRP tanks and vessels
• 237 Gas meters
• 268 Cryogenic vessels
• 286 Liquefied petroleum gas equipment and
accessories
• 326 Natural gas fuelling
Components and techniques
CEN/TCs dealing with components
• 58 Safety and Control devices for gas burners and gas burning
appliances
 69 Industrial valves
• 70 Manual means of fire fighting equipment
 74 Flanges and their joints
• 235 Gas pressure regulators and assoc safety devices for use in
gas transmission/distribution
• 342 Metal hoses, hose assemblies, bellows and expansion joints
Techniques
 121 Welding
 138 Non-destructive testing
Materials standards
CEN TCs
132 Aluminium and aluminium alloys
133 Copper and copper alloys
190 Foundry technology
ECISS TCs
9 Technical conditions of delivery and QC
22 Steels for pressure purposes - Qualities
28 Steel forgings
29 Steel tubes and fittings for steel tubes
31 Steel castings
(Migration) Help Desks
Due to the complexity of some European Standards
CEN/BT created three “Help Desks” for those applying
the standards and for correcting (potential) errors:
• EN 13445 “Unfired pressure vessels”:
http://www.unm.fr/en/general/en13445
• EN 12952/12953 “Shell and water-tube boilers”:
http://www.nard.din.de/index.php?lang=en&na_id=nard
• EN 13480 “Metallic Industrial Piping”:
http://comelec.afnor.fr/cen/en13480
OJEU
Standards providing presumption of
conformity to the PED are listed in the
Official Journal of the European Union
The latest entry was on 19 December 2006
pages C 311/31 to C 311/44 - see
http://ec.europa.eu/enterprise/newapproach/stan
dardization/harmstds/reflist/equippre.html
5- yearly revision of standards
Main product standards were published in
2002 (when the PED entered into force)
Some standards are already being revised,
to include latest thinking and further work
not originally covered.
Where a review confirms a standard, this
enhances the status of earlier versions.
(Debate)