PED/CE marking - less than or equal to 0.5bar

[marty007]

I work for a North American fabricator, and our parent company has asked us about supplying a piece of equipment to Western Europe.

I know about PED, but am far from well versed. In the beginning of the document, it talks about scope, with a limit of 0.5bar discussed.

The vessel our parent company is asking us about is being designed for exactly 0.5 bar, and has a very large volume. From what I'm gathering, this vessel would not fall under PED jurisdiction.

Am I correct in this understanding, or are there special circumstances that could bring this vessel back into the scope of the PED?

What about CE marking, if the vessel is outside of the scope of PED, would CE marking also not be required?

Thank you to anyone from across the pond that can help.

 

[samvanwesen]

PED 2014 says:

As your pressure is equal to 0.5 bar, you fall under article 4, Paragraph 3 (sound engineering practice, SEP). and Article 4 paragraph 3 explicitly prohibits CE marking of SEP pressure equipment.

http://eur-lex.europa.eu/[/URL]]Pressure equipment and assemblies below or equal to the limits set out in points (a), (b) and (c) of paragraph 1 and
in paragraph 2 respectively shall be designed and manufactured in accordance with the sound engineering practice of a
Member State in order to ensure safe use. Pressure equipment and assemblies shall be accompanied by adequate
instructions for use.
Without prejudice to other applicable Union harmonisation legislation providing for its affixing, such equipment or
assemblies shall not bear the CE marking referred to in Article 18.

special circumstances could be if your vessel is part of a pressure assembly and other parts fall under PED, you could choose to make everything PED (and increase its category level).

Now, in any doubt; ask Loyds register or another body to confirm.

 

[marty007]

Thank you very much.

 

[XL83NL]

Sam's statement is incorrect. It is correct that for article 4, sub 3, CE marking is prohibited. However, the PED is applicable above 0,5 bar (the demarcation line is not included - they do the same with their modules).

So in your case you may need apply CE marking, nor provide an EU declaration of conformity. Also, a manual is not required.

If you need more assistance I can be of help. However, Lloyd's (as well as other notified bodies here in EU) have developed simple freeware software that allows determination of PED modules and their requirements based on pressure, volume or line size, fluid state and fluid (danger) group.

Regarding special cases, there a lot. Too much to mention. But they are applicable only for cases when the PED is applicable, so for design pressure above 0,5 barg. Did you know the guidelines of the PED (similar documents like ASME interpretations) comprise some 250 articles? By which they far exceed the page count of the PED itself? And even provide more info .... !

 

[samvanwesen]

Hello XL83NL!

Please refer where you found your info.

I read in the question that the vessel was going to have a PS of 0,5 bar and like you said no demarcation lines; it is not above 0,5 bar; PED does not apply.

Or am I confused now? Also if you CE mark, you need conformity certificates and instruction manuals according to the EN harmonized codes.

Please tell me if I am wrong

 

[XL83NL]

Okay here we go

PS equal to or less than 0,5 barg: no PED, and no article 4.3.
PS greater than 0,5 barg but no module: article 4.3.
The rest yields a module, based on pressure, volume/linesize, fluid state and fluid group.

Please note harmonised standards are not a requirement but are useful/handy. 85% of the work we do is ASME w/ PED. Easy to do.

 

[samvanwesen]

Clear, thanks

Sam

 

[marty007]

Thank you all for your feedback, now our parent company is talking about a different piece of equipment that is ~200psi, so no avoiding PED anymore...

As we must get a notified body involved (Lloyd's or equiv), I would imagine they could hold our hand through the process the first time around.

The requirement for a manual would certainly be new to us. Normally we just provide a databook with as-builts, calcs, MDRs, etc... Does the PED spell out exactly what must be included in a manual? Do the buyers or EPCs become involved in writing the manuals, as they would have a better idea in many cases on the finer operational details?

Thanks again,
Marty

 

[XL83NL]

First thing is to figure out what category, and thus which module is applicable to your pressure vessel. From there on you can determine the involvement of the NoBo. Each category gives a choice of module to use. Per category, some modules are aimed at custom design, and some at mass production design (so you dont have to invite a nobo for each vessel you make). If it's mass production, you can choose to apply for a EC design/type certificate, which allows you to manufacture vessels within a certain range of the certificate. Otherwise, choose a module for custom design.

Contact the NoBo immediately, so they can review, where applicable, each step of the process. Tell them your new to this. Itll cost you a few bucks, but itll cost you more if in the end it turns out you did something incorrect. They may also assist in making up the right documents for the technical file.

For category I and II, resp. module A and A2, involvement will be little (for module A its even zero).

Wrt the manual, it's important to know that the manufacturer, or it's authorised representative in the EU market, is required to apply CE, and that party must also draw up the manual. They must also draw up the manual. There is some info in the PED itself wrt details for what needs to be in the manual, but the PED guidelines provide more detail to this respect (when Im at work tomorrow I can give you the guideline numbers which deal with this matter).

The EU Declaration of Conformity together with the manual are 2 minimum document requirements the manufacturer has to hand over to the user. Other documents like drawings, calculations, WPS & WPQ, 3.1 certificates are also oftenspecified by the user, but are not a PED requirement. The PED only requires the manufacturer to keep a copy of these files for 10 years in their technical dossier.

Sometimes customer's can have their involvement in writing the manual, when it comes to very specific details on certain equipment, but usually it's pretty straightforward. If you google for mass produced PED vessels, Im sure there will be manufacturers who have a copy of their manual on the interwebs, so you can review this to get an idea of minimum details of the manual. One further thing to know is that a lot of conclusions from the risk analysis which you must perform, can be copied into the PED (e.g. how the vessel shall be protected against over pressure protection - the user must use a PSV to handle this).

I know this is much info, but I cant make it more comprehensible than this. You just need to read the PED and start understanding it yourself. I know ASME provides courses aimed at the new PED (2014/68/EU) together ASME VIII pressure vessel design. Furthermore, some NoBo's provides seminars on how the PED works, which can also be useful.

If you have any more specific questions, Ill be happy to help you further.

 

[marty007]

XL83NL,

I really appreciate your write-up on this. You certainly took some time to spell it all out, and I appreciate your effort.

At this point, it's a theoretical exercise as our parent company is trying to sell the equipment. But, when I have the time, I will start reading through the PED document.

Thank you very much for the PED guidelines link, I will certainly look through this also.

This feels like going back to school, time to put my study hat on.

Cheers,
Marty

 

[XL83NL]

Youre welcome.

 

[XL83NL]

The PED articles and PED guideline articles I mentioned yesterday; here's a summary of what's useful for making up the manual.
- Annex I, para 3.4
- Guideline A-03
- Guideline D-07
- Guideline H-03
- Guideline I-21


- Here's an example technical file of a vessel manufactured under the PED (please note its somewhat special, and a lot of details on the vessel provided in the file are probably based on user's input - I know this MFR and I know they cant know all htese facts).
- Useful paper by NIST
- Some more useful info.
- Lloyd's website, useful documents and software
- 'PED starters kit' (not sure what it is, but seems handy)
- And another useful one

All of them where found w/ Google using the term "pressure vessel PED manual".

Please note a lot of references are to the old PED< 97/23/EC, and the new one (yet), which 2014/68/EU. In prinicple, to get the understandig, this doesnt matter as theyre both more or less the same. The differences are minor( albeit important). Of course you need to apply PED 2014/68/EU, but for review of above links you can think of it being the current version.