PED 2014/68/EU - Assemblies

[IdanPV]

Hello all,

I would like to consult regarding the definition of an "assembly" as per PED 2014/68/EU.
The system I have contains the following pressure equipment:
* Steam Generator (MAWP=5 Barg) - Category III
* Pressure Vessel (MAWP=3 Barg) - Category III
* Piping System with DN<32, piping is classified as SEP.
* Pressure Relief Valves which manufactured by PRVs manufacturer.
See illustration below

All the items are CE marked and supply to the user with Declration of Conformity.

According to Artice 2:
assemblies means several pieces of pressure equipment assembled by a manufacturer to constitute an integrated and functional whole.
That's my case I think.

According to Article 4(2):
The following assemblies which include at least one item of pressure equipment covered by paragraph 1 shall satisfy the essential safety requirements set out in Annex I:
(a) assemblies intended for generating steam or superheated water at a temperature higher than 110 °C comprising at least one item of fired or otherwise heated pressure equipment presenting a risk of overheating;
(b) assemblies other than those referred to in point (a), if the manufacturer intends them to be made available on the market and put into service as assemblies.
My questions are:
1. It seems that the steam generator is meet the definition of Article 4(2)(a), but what about the assembly which contain the piping and the vessel?
2. Does the complete assembly which contains all the item described above shall meet the ESR set out in Annex I?
3. Does the complete assembly which contains all the item described above shall be marked with CE and supply with Declration of Conformity?
4. Article 4(2)(b) allows the manufacturer to decide whether to classify the equipment as an assembly. What could be the consequences if the system described above is not classified as an assembly?

Thanks,

 

[AKuep]

1. It seems that the steam generator is meet the definition of Article 4(2)(a), but what about the assembly which contain the piping and the vessel?
confirmed
2. Does the complete assembly which contains all the item described above shall meet the ESR set out in Annex I?
Yes. Assembly means all items incl. pipings and pressure accessories even if only SEP.
3. Does the complete assembly which contains all the item described above shall be marked with CE and supply with Declaration of Conformity?
Yes incl. conformity assessment procedure (risk analysis, operating instruction, Final Documentation), Name plate, CE marking, DoC
4. Article 4(2)(b) allows the manufacturer to decide whether to classify the equipment as an assembly. What could be the consequences if the system described above is not classified as an assembly?
Article means complete assemblies ready for use.
It is not prohibited to place the individual pressure devices separately on the market. Someone then has to carry out the assembly and perform the conformity assessment procedure. This can also be the end user.

 

[XL83NL]

I’ll try and provide a first short answer. More extensive reply with details - if required - later.

1. Individual items remain as they are. SEP piping stays SEP piping. Etc

2. Yes. However for assemblies it is different. I can provide you with a typical list of documents that we make for our assemblies.

3. Yes. On the assembly.

4. It will then not be CE-marked, and you may violate legislative requirements. It depends if the assembly constitutes a ‘functional’ whole.


Also, bear in mind you must perform a hazard and risk analysis. That may indicate you’re PID isn’t ‘safe’ and requires modification. I’m not a chemical or process engineer (but mechanical), but I know a thing or two about the PED. This PID doesn’t seem complete. Not u til its hazoped and safe, you can apply the CE mark. No nobo is likely to give a design appraisal for this if it hasn’t been properly hazoped or process safety verified.