Pressure Equipment Workshop Romania – Session II part 2 DEVELOPMENTS IN PED, GUIDELINES, STANDARDS...

Pressure Equipment WorkshopRomania – Session II part 2DEVELOPMENTS 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_equipment/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 directive2. Classification and categories.3. Assemblies4. Evaluation assessment procedures5. Interpretation of essential requirements on design6. Interpretation of ESRs on manufacturing7. Interpretation of ESRs on materials8, Interpretation of other ESRs9. Miscellaneous10. 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 GuidelinesESRs in section 2 = 11 Guidelines ESRs in section 3 = 30 Guidelines ESRs in section 4 = 18 GuidelinesESRs in section 7 = 8 Guidelines ESRs in sections 1, 5, 6 = less than 3 in each

PED Annex II = 10 GuidelinesPED Annex III = 7 GuidelinesPED 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 Exclusionse.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 practicesAre 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 techniquesCEN/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 TCs132 Aluminium and aluminium alloys133 Copper and copper alloys190 Foundry technologyECISS TCs9 Technical conditions of delivery and QC22 Steels for pressure purposes - Qualities28 Steel forgings29 Steel tubes and fittings for steel tubes31 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/standardization/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)