Declaration of conformity

[mw87]

Hello, everybody here,
can someone help me i'm stuck;
what requirements must meet a tee, which will be subject to the PED 2014/68/EU?
Medium: group I (hazardous); pressure: 1,5bar; temperature: 40C?
In declaration of conformity I have to include every single detail
as I do it during pressure vessel manufacturing?
Are there any simplified methods of conformity assessment?

 

[XL83NL]

A tee in itself does not need a DoC (Declaration of Conformity), nor may it be CE-marked. A piping systems is subject to the scope of PED, a fitting not. A tee is a component of pressure equipment. Review guideline A-08 and A-22. You're on the wrong track. Let me if I can help further.

 

[mw87]

XL83NL - you are a very helpful person;
I see that you often give the right answers.
Thank you.
BTW: to be honest I was hoping for your help.

 

[XL83NL]

You're welcome

 

[mw87]

Hello,
maybe I specify more detail:
let's assume that I'm a tee maker. First I prepare drawing and submit to my Client in order to approve it.
After that I'm actually doing it (I buy the material first – for example P265GH acc. PED then I weld it, thread it
- it's made acc. to the client's requirements, finally done - so it may be named: a special-purpose tee).
Recap of discussion with my client is looks like:
1. first my Client required submission the declaration of conformity (the tee is acc.2014/68 / EU) + sign CE
2. Now it "only" require put in the drawing - written: acc. 2014/68/EU
but does it make a difference?
substantially (theoretically) I still should prepare everything according to Directive PED;
even if he doesn't need the declaration of conformity?
is this time for NoBo?

 

[ajab]

As XL83NL says the guidelines suggest that pipe fittings do not have to be subject to PED, however a Tee can be supplied CE marked.
We manufacture and supply PTFE line pipe & fittings and all are CE marked (where appropriate).
Requirements for CE marking of these parts are similar to those for Pressure Vessels (which we also supply).

It is an offence to declare that an item is according to the PED (and especially to apply a CE mark) if it is not subject to approval of a NoBo.

 

[XL83NL]

Can you provide a sketch or something to indicate what exactly it is youre making?
Based on your last reply, I dont see where the PED should come in. A design can never be acc. PED 2014/68/EU, since the PED does not spell out any rules how the design things. It only specifies what (minimum) Essential Safety Requirements (short ESR) must be met (and not how), provided the scope of your work is under the PED, and subject to a category greater than or equal to I.
A design can however be in compliance with the requirements of Annex I of the PED, i.e. the ESR's.
Now in your case, how in are you e.g. going to hydrotest the thing? Have you done a risk analysis?

CE-marking seems to be out of the picture. Writing acc. 2014/68/EU also.
I suggest you read the PED, try to get an understanding of the PED guidelines, and follow some sort of course. In my experience, people listen to easily to NoBo's (note 1) or client, without knowing exactly whats inside the PED. Since you (as a manufacturer or distributor) are fully responsible for something where you put CE on, you better make sure you understand what you're doing under the Directive you're working on (in this case, the PED).

Note 1; NoBo's also dont always fully understand what inside the PED, and sometimes just make a quick call of what should be done, rather than fully understanding the context of the PED.

 

[XL83NL]

@ ajab; Ive seen (PTFE/PFA)lined piping fittings being placed on the market as CE-marked products under the PED. How exactly are lined fittings, such as lined & flanged eblows or lined & flanged tees, considered under the PED? Are they considered as piping by your NoBo?

 

[mw87]

I've just made a call to my BoDy and he exactly say the same thing;
I mustn't: put in CE marked on Tee (fittings), write somewhere PED
and submit declaration of conformity.
(Exeption: We can CE marked, but always after positive acceptance
by NoBo, verify welds, welders, documentation ect.
but without PED)
I'd rather not put the drawing here..anyway it's still company secret...
thank you for your help.

 

[ajab]

Yes they are considered as piping by our NoBo and the (different) NoBo of our sister company in France.

I believe guideline A-09 applies:
'Individual piping components, such as a pipe or system of pipes, tubing, fittings, expansion bellows, hoses, or other pressure bearing components are not “piping”.
However, a single pipe, or a system of pipes, for specific application, may be classed as “piping”, provided all appropriate manufacturing operations such as bending, forming, flanging and heat treatment, have been completed'.

Guideline A-08 applies to pressure accessories (and excludes Y-shape or similar fitting as being piping).
Guideline A-22 applies to flanges, dished ends and nozzles that are to be incorporated into (usually welded to) pressure equipment.