Pressure Equipment Directive – Moving to 2014/68/EU
09 February 2016
In an age of increasingly complex and stringent regulation, and despite a strong focus on rigorous HSE standards, many companies in the oil and gas industry are not aware of the requirements of the Pressure Equipment Directive (PED) or whether they apply to their organisation, says UK Notified Body HPI Verification Services. In this article, HPI explains the Directive's requirements and looks at planned changes.
In addition to European manufacturers understanding how they are affected by this regulation, it can also be challenging for international companies expanding into servicing oil and gas operations in Europe to know where to begin. It might sound simple, but the critical first step to progressing an efficient compliance process is understanding what the key aspects of the regulation are.
The original PED 97/23/EC has been in force since 1997. It applies to the design and manufacture – though not operation – of individual items and assemblies of pressure equipment with a maximum allowable pressure greater than 0.5 bar. Equipment in compliance with the PED will be certified with a CE marking. The directive applies to any equipment within this scope, regardless of application, and also applies to certain safety equipment designed to protect pressure equipment from the allowable limits being exceeded. This would include pressure limitation devices, such as safety valves, and certain equipment which is designed to correct or shut down operation, including pressure and temperature switches. The PED provides guidelines for conformity rather than a set of strict rules, and sets out the standards for the design, manufacture, testing and conformity assessment of pressure equipment in the European market.
The directive has a wide range of Conformity Assessment Modules which define the requirements for documentation. The risk factor of the product is categorised by either the state of contained fluid, the stored energy, or the hazards associated with fluid in the product. Once this has been determined, the relevant documentation can be compiled and evaluated. For those unfamiliar with the requirements of these categories, and particularly for those new to the marketplace, this can be a confusing and time consuming process. Knowing where to start and which questions to ask is key to getting this process right.
In June 2005, the requirements of PED were changed for the first time in 17 years, the first step in moving towards the implementation of the updated 2014/68/EU directive in July 2016. The changes to the directive will impact the whole supply chain, including manufacturers, importers and distributers of pressure equipment. Essentially, the changes to the directive look to clarify and streamline the regulations in bringing pressure equipment to market, particularly in an industry facing increasing competition from equipment with fraudulent certification. It is important to understand how these changes impact each link in the supply chain, and what they need to do to ensure compliance with the updated regulation.
The changes to the regulation will affect a wide range of factors, from the classification of fluids, to the obligations of both manufacturers and notified bodies. For example, it will no longer be the manufacturer only who has a requirement to ensure that only safe and compliant products reach the market. Additionally, if an importer of distributer modifies the equipment in any way, or places the equipment on the market under their own name, they are now considered a ‘manufacturer’ by the updated regulation, and are therefore subject to the obligations therein. All of this means that the net of responsible parties will widen, ensuring that all involved at every step in the supply chain will play a key part in ensuring that only safe, certified equipment reaches the end user.
There are a number of exclusions to the PED, largely regarding equipment already regulated in equivalent or more stringent European Commission (EC) directives. This is where certification companies can provide advice on the requirements for an individual piece or assembly of pressure equipment, and ensure that the relevant information is provided.
Another key difference brought about by the changes is the evolution of the safety philosophy of the directive. Whilst there are no changes to the actual safety requirements themselves, manufacturers must now analyse the risks of pressure equipment and not just the hazards, ensuring that every aspect of safety is considered and evaluated. This is a marked change in the approach to safety requirements, reflecting the increasing scrutiny of safety standards in the wider industry. As more companies question whether the utmost safety standards and controls are in place in order to safeguard both staff and equipment, certification can play a key role in evaluating and documenting safety and governance.
Particularly in a period of the lowest oil prices in almost a decade, demonstrating transparency and good governance has never been more crucial in order to remain competitive in the market. It therefore falls to the certification bodies to play a key role in enabling those in the industry to recognise how certification schemes can help companies to improve standards and efficiencies, maintain value through protecting their reputation, and help to continue positive, trustworthy relationships with customers and wider stakeholders.
Good governance goes beyond a ‘tick box’ approach, and demonstrating not just compliance but a thorough understanding of the regulations can provide reassurance that every measurable step has been taken to guarantee the utmost standards in safety and quality. HPi VS adopts a more thorough approach than just the standard checklist, recording not only whether or not a feature is compliant, but also how it reaches the required standard. With this additional information readily to hand, operators can easily provide evidence to prove compliance.
Ensuring that pressure equipment is compliant and meets the required standards in safety and quality is essential, particularly as the industry increasingly looks to raise the bar in standards across all aspects of day-to-day operations. Robust documentation that goes beyond simply stating that equipment is compliant can help companies demonstrate a commitment to transparency and good governance. Certification bodies therefore have an important role to play in empowering companies to understand and achieve requirements smoothly and efficiently. By doing so, certification schemes can help to improve operational standards and efficiencies, drive value through improved reputation, and help to improve relationships with customers and wider stakeholder networks.
The requirements of the PED and the updates to the regulation can be easily navigated with the relevant information readily to hand, ensuring compliance in the simplest and quickest way.
HPi VS has been working with PED since before the original regulation came into force, and our team has found that more often than not, knowing which questions to ask to begin the process is often one of the first and most challenging barriers to achieving compliance, especially when new to the area. This is where working with organisations that can offer step by step, accurate guidance gained over years of experience, can help companies to navigate the regulation and ensure that all of the necessary steps are in place whilst mitigating the risks of non-compliance.
The recently launched PED online training portal (www.eucertification.com) provides fast and easy access to a bank of information relating to the directive, helping companies access the important details they need and steering them towards certification.
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