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Valve Magazine Article

Valve Magazine Article

As printed in Valve Magazine Summer 2002 Web published courtesy of the Valve Manufacturers Association of America "Reducing the Cost of Addressing the PED" by Lindsey Bredemeyer The Pressure Equipment Directive(PED) 97/23/EC became enforced on 29 November 1999 and became mandatory on 29 May 2002. Pressure equipment to be sold for use in the European Economic Area must now address PED requirements. The PED applies to pressure equipment with a maximum allowable pressure over 0.5 bar (7.25 psi). There are currently companies who are just now addressing the PED. Initially, some of these firms had decided not to participate in the European common market, because they did not see enough pay off for the expense. In some cases they simply did not want to deal with the hassle of documentation, but these companies are starting to reconsider the need for addressing the PED. Seemingly small organizational changes can put a companys product into a strong sales network within Europe. A straight forward project order to a US OEM can place the product into assemblies destined for Europe. A decision to close a small shop in Europe may place the US factory as the sole provider for a product. Does this mean that you must make the product compliant to European design standards and get an agency to approve the product? Not necessarily. The PED is one of the few directives without a requirement to follow harmonized standards and its own design requirements are simple and specific. Particular assessment by a third party agency is only required for category II and higher assessment levels. There are exclusions and application limits within the PED which significantly reduce the cost and effort of addressing the PED by avoiding the more expensive aspects of PED compliance. Some of these are extremely specific, but some are quite far reaching. These methods will restrict sales to a more limited range of applications and services, but if your business has a primary focus within one of these areas it can still provide a worthwhile sales activity. It is easier to view these opportunities from the standpoint of a general hierarchy of the PED. Pressure at or below 0.5 bar is outside of the scope of the PED. The PED simply does not apply, so there are no requirements. There is a range of exclusions which either completely exclude the product from the requirements of the PED or defer to other directives or regulations. The hierarchy of assessment levels are Safe Engineering Practice (SEP) and assessment categories I,II,III,IV. SEP has the least requirements increasing to category IV which has the most requirements. The requirements for the categories are defined within the PED. These requirements may be clarified in the official published guidelines or in harmonized standards. Regardless of the method followed, even with product outside of the scope, one must ensure that all other applicable directives are addressed. Both valve and actuation products may fall under other directives based upon their application. Even with the lowest requirements, one must ensure that adequate documentation is provided for safe installation and use of the product.

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Exclusions Exclusions are the reason that I commonly refer to addressing the requirements as opposed to complying with the PED. The use of an exclusion eliminates the requirement to comply with the PED. There are 21 distinct listed exclusions in Article 1. Listed here are the exclusions that are most applicable to valve and actuator manufacturers. The advantages and pitfalls of each are also noted. In some cases the exclusion can be claimed only by meeting the requirements of another directive or regulation. These other directives have their own range of requirements which may be lesser or greater than the requirements of the PED. One exclusion that initially appears valid is 3.1. It excludes equipment for transport pipeline service which is designed specifically for pipelines. This does not apply to standard pressure equipment incidental to use in pipelines. Unfortunately, Guideline 1/17 has clarified this to state that pressure regulators, safety valves and valves are standard. This prevents the use of this exclusion in most instances. Networks for the supply, distribution and discharge of water and associated equipment (3.2). Initially one would assume that this exclusion would have restrictions in a similar manner to exclusion 3.1, but Guideline 1/16 allows for a much broader interpretation. It defines the networks as the complete water distribution system up to point of use in buildings, industrial sites and plants. The guideline defines water as both potable and waste water. It also specifically includes items such as water meters and line valves to be within this exclusion. This provides a very powerful exclusion for water service valves. In the event of valves used in buildings, care must be taken that the equipment does not fall under specific areas of the Construction Products Directive. 3.3 allows exclusion of some items such as low pressure air accumulators for actuators. It defers to the Simple Pressure Vessel Directive (SPVD) for welded mild steel and aluminum tanks for nitrogen and air. This directive is focused on mass produced vessels. For products under this directive, it is probably easier to procure approved tanks than to qualify a PED vessel or SPVD tank. Almost all equipment specifically for the operation of vehicles or for transportation use by road, rail, air, or sea is excluded. These typically fall under other specific directives or international regulations such as IMDG, ADR, RID or ICAO(3.5, 3.14, 3.19). Some exclusions to the PED are required to be no higher than CATI under the PED and comply with another specific directive (3.6). --Machinery Directive: There is a problem in this exclusion in that under the Machinery Directive, if the risks are partly or wholly under a specific community directive, the Machinery Directive shall not apply. This provides two directives pointing to each other, but the PED is specific that Category I and lower falls under the machinery directive. --Low Voltage Directive: This is clearly applicable to items such as solenoid valves or other low level pressure equipment with electrical systems which fall under the LVD. --Medical Devices Directive: This may apply to items such as valves for medical gasses --Appliances burning gaseous fuels: This may apply to items such as gas shut off valves and
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Valve Magazine Article

regulators for appliances. --Equipment and protective systems intended for use in potentially explosive atmospheres (ATEX): The ATEX directive will become mandatory on 30 June 2003. It will then replace the other European explosive area regulations. 3.8 excludes items specifically designed for nuclear use, failure of which may cause an emission of radioactivity. I believe that this exclusion is adequately self explanatory. 3.9 excludes well control equipment intended to contain or control well pressure, specifically addressing well heads, blow out preventers and all equipment upstream. This is interpreted to include everything mounted on the tree. Once the system drops off the wing valves or chokes, it enters the reign of the PED. This interpretation is reinforced on Guideline 1/37. A common exclusion which is typically claimed on actuators is that of pressure not being a significant design factor(3.10). This claim is that the product is designed for the requirements of rigidity and other loads and that pressure related stresses are not significant to the design. Per the directive, actuators are on a list of equipment that may fall under this exclusion. The statement does not explicitly permit actuators to use this exclusion. At one time it was not particularly clear since there was no definition of when the pressure portion of the total stresses were not considered significant. Guideline 1/11 has clarified the interpretation for the exclusion in adding the definition of if it is primarily designed to move or rotate or fulfill other functions than pressure containment and requirements related to low elongation, low change of diameter or low other deformation because of functional requirements to rigidity. This provides a route to demonstrate that the actuator is designed primarily based upon deflections and indicating that the pressure based stresses are not significant compared to the rigidity requirements. This is a very powerful exclusion in that it applies regardless of the assessment category of the equipment when reviewed on the assessment tables. Some large gas actuators would otherwise possibly reach category IV. This would require the same assessment requirements as a main boiler pressure relief valve. Another clarification was stated in what you can not do. An over-dimensioning as such shall not result in exclusion from the PED with regard to article 1.3.10. This statement prevents the use of extremely high safety factors as an excuse for the exclusion. Pressure vessels for transportation and distribution of drinks within specific pressure/volume limits and bottles and cans for final drink consumption are excluded (3.17,3.18). When you finally start your micro-brewery, at least your kegs do not have to meet the PED. Advantages of SEP/CATI The PED like most other requirements is an economic decision. Is the effort to address the requirements going to be compensated with continued or increased sales? Like all requirements, there are costs related to PED compliance. These costs increase with the criticality of the particular equipment. The level of criticality is defined by the assessment category. The higher the assessment category, the more stringent are the requirements applied. There are several major advantages to limiting the category of the equipment to SEP/CATI rather than assessing to CATII and above. The determination of Categories is by application, size, and pressure. By limiting these criteria, the equipment can be reduced in Category. The simplified differences of the assessment category
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tables are gases vs. liquids and chemically hazardous vs. non-hazardous fluids. The hierarchy of requirements are roughly descending on Tables 7-10. Because the curves have different criteria this hierarchy is not exact. Within the range of applications there are variables of sizes and pressure ratings which will allow the use of the SEP/CATI assessment. Assessment category II and higher require notified body assessment of the quality assurance system and/or the equipment design. It also requires regular surveillance of equipment production. Non-harmonized materials require notified body approval for particular material appraisals of category III & IV (Annex I 4.2). The most significant costs of PED compliance are the manufacturing and materials requirements. Assessment categories II and above require European competent body assessment of weld procedures and personnel. Above category II NDE personnel for weld inspection must also be approved by a European competent body. Probably the most significant advantage is in relation to material certifications. Category II and above requires a certificate of specific product control. The material manufacturer must have assessment for the material and a quality assurance system certified by a European competent body. If a material supplier does not meet these requirements, the materials used must be approved by a competent body. Category I only requires a non-specific material test report and a certificate of compliance with no specific requirements for QA systems or assessment (Annex I 4.3). Limiting the product to category I or lower eliminates notified body requirement for assessment and material review. The most significant advantage is that it eliminates the competent body requirement for material suppliers. It does not eliminate the need to properly document compliance. These requirements are called out for both SEP and category I. SEP is technically outside of the requirements of the PED. SEP product is not required to comply with the PED beyond the requirement to meet the safe engineering practice of a member nation and have adequate marking and instructions for safe use (Art.3 3). SEP products are specifically required not to have the CE mark per Art.3 3. Even when SEP products are assessed to a higher level by following the assessment module of a higher category, the CE mark shall not be applied per Guideline 2/18. Limiting a valve to non-compressible non-hazardous (Table 9) service allows for SEP at any pressure through an 8 valve. Above 8, pressures below 7250 psi allows the use of CATI. Compressible non-hazardous service (Table 7), such as steam and air, allows the use of SEP up to 1 and CATI above this through 4 at any pressure. The tables for hazardous fluids (Table 6 & 8) have limiting pressures for SEP & CATI regardless of size. The liquid table allows all sizes up to 145 psi to be CATI. There are several ways to approach the assessment tables. For specific services, different sizes of the valve can be restricted to particular pressures. For a family of valves across several pressure classes, each class can be cut off at a different size, with lower pressures at larger sizes. Safety accessories are typically defined as a category IV, but there is a significant exception in that equipment for a specific application lower than category IV may be assessed to that level (Annex II - 2). This would allow the safety accessory to be categorized to the equipment on which it is mounted. A specific example would be a small pressure relief valve for a specific sized water heater could be limited to the same category as the water heater.
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Valve Magazine Article

Conclusions There are opportunities for some products to be sold into Europe with a relatively small investment. In many cases the cost of addressing the PED can be reduced, compared to performing a broad band assessment to place the product into all services. The limited application to achieve these reduced costs is primarily a market management decision. In all cases, care must be taken to ensure adequate documentation is available.

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