PLANT MAINTENANCE

Mechanical equipment and the ATEX Directives

European Union requirements for operating mechanical equipment in potentially flammable atmospheres present major compliance issues for users and suppliers. This article provides guidelines for the appropriate measures to ensure compliance
Andy Hollins ABB Engineering Services

he European Unions Atmosphres Explosibles (ATEX) Directives became fully effective last summer throughout the EU. More commonly referred to as ATEX, there are in fact two different but complementary directives, intended to reduce the hazards created by explosive atmospheres within the refining and petrochemical processing industry workplace. All processing facilities with operations located within the European Union now have to comply with the requirements of these directives. One of these directives is concerned with the supply of equipment while the other deals with the protection of workers. It should be noted that these directives only address the hazards associated with explosive atmospheres and do not consider other hazards, for example toxicological considerations. Collectively, the ATEX Directives have the effect of turning what had until now been accepted best practice within the process industries into mandatory requirements. In addition to flammable liquids and vapours, combustible dusts have been specifically included within the scope of dangerous substances. The definition of equipment within these directives is also very broad and now includes mechanical equipment. Traditionally, only the installation of electrical equipment in potentially flammable atmospheres had been given special consideration. The inclusion of mechanical equipment presents one of the main compliance issues for both equipment suppliers and users. The equipment supply Directive 94/9/EC, also known as ATEX 95, is intended to allow the free movement of goods throughout the EU by harmonising the technical and legal requirements for equipment which is intended to be used in potentially explosive atmospheres. It applies to the placing on the market, putting into service and design of this type of equipment. This directive had a transitional period, which ended

on 30 June 2003. From this date manufacturers and suppliers have to ensure that any of their products, intended for use within potentially explosive atmospheres, meet a series of specified essential health and safety requirements, have been assessed for conformity and are appropriately certified and marked. Manufacturers must also compile a technical file for the equipment and, if required, lodge a copy of this file with an appointed notified body. From 30 June 2003, some categories of products have to be certified by any of the notified bodies appointed by the EU member states. Notified bodies include such organisations as BASEEFA, DEMKO, KEMA, INERIS, PTB, SIRA, and TV. Conformity with ATEX 95 means that equipment can be sold for use anywhere in the EU. It is important to note that it is the use of the equipment within the EU that necessitates compliance with this directive. Hence, equipment exported from the EU need not comply. Conversely, equipment manufactured outside the EU must now comply if it is to be used within the EU. This directive affects the operators of hydrocarbon processing facilities, albeit indirectly, because of the way in which it imposes duties upon their suppliers. It may also restrict an operators ability to use equipment that has been manufactured outside the EU. The definition of equipment under this directive is very broad and includes mechanical equipment (both rotating and static), such as pumps, compressors, fans and valves as well as electrical equipment and instrumentation. The directive means that manufacturers in EU member states are, for the first time, set to work to common agreed standards. A particular benefit is that manufacturers no longer have to get their equipment certified in more than one EU country. While ATEX 95 is concerned with the design and specification of equipment, this directive directly affects the operation of refining and petrochemical facil-

ities. Directive 99/92/EC, known as ATEX 137, provides minimum requirements within the workplace to improve the safety and health protection of workers from the hazards of potentially explosive atmospheres. It places specific duties on the employers. The directive lays out a hierarchy of risk identification and reduction measures. Operators must now demonstrate that all the explosion risks within their facilities have been determined and that appropriate measures have been put into place to minimise and then control these risks. In order to demonstrate that they are doing so, they must compile an Explosion Protection Document for the facility. The risk assessment exercise commences with steps to identify the potentially flammable substances within the workplace and where possible to eliminate or reduce the risks presented by the substances. The next steps include the classification of areas containing flammable substances into zones and the installation of equipment suitable for use within these zoned areas. Operators must be able to show that they are using appropriate management systems including the training of personnel and work control measures, for example permit to work procedures. Workplaces and work equipment, including warning devices, must be designed, operated and maintained with due regard for the avoidance of leakage and the prevention of ignition sources. Existing workplaces are subject to a three-year transitional period. Workplaces used for the first time after 30 June 2003 and all modifications to existing plants after this date must comply when they are brought into use. Workplaces already in use before 1 July 2003 are required to be in compliance with this directive by 30 June 2006.

Area classification
The processing industry undertakes the processing and handling of large quantities of flammable materials, frequently

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Area classification: definition of zones

Vapours Zone 0 Zone 1 Zone 2 Dusts Zone 20 Zone 21 Zone 22 Frequency of Approximate duration flammable atmosphere (hours/year) Continuously Intermittently Abnormally >1000 10 to 1000 <10

Table 1
well above their flash point temperatures. Responsible operators already have in place risk assessment studies such as process hazard reviews and HAZOPs, which seek to address these issues. The nature of the business means that there is effectively little scope for substitution with less flammable substances and generally minimal opportunity to reduce the quantities of the flammable materials. Loss of containment in processing plants consequently has the potential to create flammable atmospheres. Combustible dusts are not generally a problem in such facilities. ATEX 137 requires that areas containing hazardous substances are classified into zones on the basis of frequency and duration. Area classification is, however, a long established procedure within the refining ad petrochemical industries. But the directive has the effect of turning this good practise into a formal requirement. Existing standards, for example EN 6007910, give guidance on carrying out the studies, although until now only the electrical and instrumentation engineers had any real interest in the outcome. Going forward, the mechanical engineers for both rotating and static equipment will need to understand the implications of the area classification upon their equipment located within hazardous areas. The different zones for potentially explosive vapours and dusts, together with much simplified definitions of frequency and persistence are shown in Table 1. Since 1 July 2003 only equipment complying with ATEX 95 can be installed in a hazardous area. Equipment is divided into groups and categories with differing requirements for design, testing, certification and documentation. The equipment groups are easily understood. Group I equipment is intended only for use in hazardous areas in mines while Group II equipment is for use in hazardous areas in other locations. Equipment from Group II is, consequently, suitable for use within refining and petrochemical facilities. The equipment categories are a potential source of confusion. It was

Figure 1 A typical label for ATEX certified equipment

decided that there could be no such thing as a category zero and that therefore the equipment categories should be numbered 1, 2 and 3. This is despite the fact that the vapour zones are designated 0,1 and 2. The use of equipment of the different categories of equipment within hazardous areas is restricted as also shown in Table 2. Although responsible operators will have existing area classification drawings they should now review them to ensure they are up to date and they should be able to produce documentation. For example, minutes of the area classification review meetings, supporting these drawings, which show how the extent of the zones was determined. Operators who in the past relied on the blanket zoning of whole plant areas should seek to establish the necessary extent of individual zones. Otherwise, they are likely to incur unnecessary costs, particularly with regard to their mechanical equipment. In the past, electrical engineers frequently employed blanket zone 1 as a means of ensuring that electrical apparatus suitable only for installation in zone 2 areas was not inadvertently installed in a zone 1 area. The associated cost penalty being regarded as modest when compared with the potential risk. In comparison, mechanical equipment does not have the same potential level of inter-changeability. Additionally, the procurement and ongoing maintenance costs of category 2 mechanical equipment is likely to be significantly higher than for category 3 equipment. supplier is responsible for the design, testing, certification and marking of the equipment that they supply. Operators will need to have amended their purchasing procedures and possibly also their project processes so as to ensure that from now on only ATEX certified equipment is purchased for installation in zoned areas. As far as electrical apparatus is concerned, the ATEX requirements are nothing new for both suppliers and users, with only some changes to existing labelling and certification procedures. Electrical engineers have been dealing with the issue of the safe operation of equipment in potentially flammable atmospheres for about 30 years and the standards and equipment certification procedures are well established. EN 60079-14 covers the selection and installation of electrical apparatus for use in hazardous areas. The different types of protection for electrical apparatus are widely understood by manufacturers and the notified bodies and are covered by the EN 500XX series of standards. In contrast, many of the equivalent standards for mechanical equipment, the EN 13463 series, are still at the draft stage. EN 13463-1 covering basic method and requirements was published in 2001. EN 13463-5 covering protection by constructional safety and EN 13463-8 protection by liquid immersion were published towards the end of 2003. Of the remaining draft standards, EN 13463-6 covering control of ignition sources has been subject to substantial revision and is potentially of interest to the operators of existing facilities. For electrical apparatus the most noticeable change will be in the label affixed to the apparatus. Hazardous area markings are an entirely new feature on mechanical equipment. An example of a typical ATEX equipment label is shown in Figure 1. Certified equipment for use within the EU now has to carry both an Ex mark denoting compliance with the ATEX 95 Directive and a CE mark, which signifies that the equipment complies with all relevant EU Directives. As well as carrying the correct label,

New equipment
It is the users responsibility to correctly specify equipment for installation in hazardous areas on their facilities. The

Equipment categories and permissible zones

Category 1 2 3 Vapours Dusts

Zones 0, 1, 2 Zones 20, 21, 22 Zones 1, 2 Zones 21, 22 Zone 2 only Zone 22 only

Table 2

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new equipment must be supplied with a certificate of compliance. Again, hazardous area equipment certificates for electrical apparatus are nothing new, while Ex certificates for mechanical equipment is a new phenomenon. The certificates should be read and understood by the operator. Most ATEX certified mechanical equipment comes with a conditional certificate requiring specific operating and/or maintenance regimes for the certification to be valid. While there were bound to be some initial problems with the certification of new mechanical equipment, many of the manufacturers supplying mechanical equipment for use on chemical processing plants are now able to supply ATEX certified equipment. The same is true for spares and components. For example, ATEX certified mechanical seals are readily available from the major manufacturers. There are, however, likely to be residual issues with one-off and specialist items of mechanical equipment and with the importation of equipment from outside the EU. Should they wish to, operators are allowed to import uncertified equipment into the EU, but before they can use this equipment in a hazardous area they must undertake all of the duties assigned to the supplier under the ATEX 95 Directive. For existing mechanical equipment the route to demonstrating safety is much less clear-cut. The equipment will not have been designed and built to standards, which directly addressed the potential for the equipment to create ignition sources. Many of the mechanical items within refining facilities will have been built in accordance with the API standard for that type of equipment. In essence, these standards capture the petroleum industries operating experience and establish the design features necessary for reliable operation at the required throughput. Having undertaken the area classification review, ATEX 137 requires that risk assessments be carried to show that ignition sources have been identified and either eliminated or effectively controlled. It follows that one of the major consequences of these directives is that the operators now have to carry out the risk assessment of uncertified equipment located within their hazardous areas for potential sources of ignition and provide the technical and the organisational measures required to eliminate or reduce the identified risks to an acceptable level. At this point, it may not be clear how the installation and operation of mechanical equipment can lead to the introduction of potential ignition sources within a zoned area. EN 1127-1 lists 13 potential groups of ignition

Control of ignition sources

The ATEX Directives permit existing equipment to be used indefinitely provided that the operator can show that this equipment is safe for use in the zone in which it is located. Spare parts that were in stock before 1 July 2003 can be used providing that they do not require substantial modification. For installed certified electrical equipment, demonstrating suitability for ongoing use should be relatively straightforward. This can be based on the fact that the apparatus was manufactured and certified to existing standards, which addressed the ignition source potential of that particular type of item. Activities will typically include the following steps: Inspecting the apparatus to check that it is correct for the zone and to confirm that it has been maintained in good condition The replacement, where necessary, with apparatus appropriate to the zone The repair of any defects identified during the inspections Documentation of the above steps. The first step is important, particularly as the zoning may have changed since the equipment was installed. Inspection regimes for electrical apparatus located within hazardous areas are given in EN 60079-17.

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Operators will need to be able to demonstrate that the equipment in use within the zoned areas does not result in active ignition sources. The tolerability of active ignition sources varies according to the zone in which the equipment is located. The requirements are outlined as: Zone 0/20: In normal operation and resulting from expected malfunctions, and resulting from rare malfunctions Zone 1/21: In normal operation and resulting from expected malfunctions Zone 2/22: In normal operation (no malfunctions). Equipment located in zone 0 requires the highest level of protection from potentially active ignition sources while that installed in zone 2 areas requires the lowest. Hence the required level of protection is proportionate to the likelihood of a flammable atmosphere being present. Having identified the potential ignition sources associated with the mechanical equipment it is then necessary to identify how they are to be eliminated or controlled. Once this has been completed, any necessary modifications can be progressed and the required mitigating measures can then be implemented. The risk assessments need to be documented since they will form part of the overall Explosion Protection Document. Any necessary inspections can then be undertaken and recorded. The range of mitigating measures includes: Maintenance and operational procedures Process operator checks Maintenance inspections and records Condition monitoring regimes Instrumented trips and alarms Hardware protection devices (such as torque limiters). Inspections for mechanical equipment mirror those for certified electrical equipment. The inspection points have been identified during the ignition source risk assessment. They involve confirming the specification of the equipment, checking its condition and confirming that the necessary mitigating measures are in place. Processing facilities will typically have thousands of installed plant items operating within their zoned areas, representing a significant challenge to operators. To meet this need ABB Engineering Services has developed an ignition source risk assessment methodology that identifies any effective ignition sources created by the operation of equipment in hazardous areas. The necessary mitigating measures are then selected to reduce the residual risk to an acceptable level. The methodology enables full credit to be taken for the

ATEX Directives
ATEX 95: European Union directive 1994/9/EC. ATEX 137: European Union directive 1999/92/EC. EN 1127-1: Explosive atmospheres explosion prevention and protection Part 1: Basic concepts and methodology. EN 13463-1: Non-electrical equipment for potentially explosive atmospheres Part 1: Basic method & requirements. EN 13463-5: Non-electrical equipment for potentially explosive atmospheres Part 5: Protection by constructional safety. EN 13463-6: Non-electrical equipment for potentially explosive atmospheres Part 6: Protection by control of i ignition sources. (Draft Standard). EN 13463-8: Non-electrical equipment for potentially explosive atmospheres Part 8: Protection by liquid immersion. EN 60079-10: Electrical apparatus for explosive gas atmospheres Part 10: Classification of hazardous areas. EN 60079-14: Electrical apparatus for explosive gas atmospheres Part 14: Electrical installations in hazardous areas (other than mines). EN 60079-17: Electrical apparatus for explosive gas atmospheres Part 17: Inspection and maintenance of electrical installations in hazardous areas (other than mines). EN 60079-19: Electrical apparatus for explosive gas atmospheres Part 19: Repair and overhaul for apparatus used in explosive atmospheres (other than mines or explosives). sources. Of these, the most common associated with the types of equipment to be found in refining and petrochemical plants are hot surfaces, flames, hot gases, mechanically generated sparks and static electricity. Other mechanical plant items have a similar potential to generate ignition sources.

Care needs to be exercised to ensure that materials specifications and dimensional tolerances are achieved. . . While operators frequently choose to use contractors to undertake these activities on their behalf, they cannot transfer their responsibilities under the directives for protecting their employees
mitigation provided by the maintenance and operating procedures, which the operator already has in place together with the protection provided by existing hardware and instrumented protective systems. The outcome of the assessment is then summarised in the risk assessment report for the item of equipment and in inspection sheets to enable the user to implement and manage the required mitigating measures. The methodology enables the equipment user to demonstrate compliance with the ATEX directives. The focus is on minimising the ongoing cost of compliance for the operator while reducing the risk of ignition to the necessary level. The methodology also makes use of software tools to undertake the risk assessment of large volumes of equipment in a cost effective manner.

Repairs and modifications

The repair of electrical apparatus is covered by EN 60079-19. It is supported by recognised training schemes for technicians and approved contractors. Currently, there is no equivalent standard for mechanical equipment. But essentially, any repairs to mechanical equipment should return it to its original condition. Care needs to be exercised to ensure that materials specifications and dimensional tolerances are achieved and that the correct re-build procedures are followed. While operators frequently choose to use contractors to undertake these activities on their behalf, they cannot transfer their responsibilities under the directives for protecting their employees. Operators need to be careful about modifying their equipment. For example, modifications to certified electrical equipment will invalidate the certification. Under the directives, modifications can still be undertaken but in

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these circumstances the operator may have to undertake all the duties placed upon equipment manufactures by the ATEX 95 Directive.

Minimising explosion effects

ATEX 137 accepts that even after the risks have been reduced and controlled as previously outlined, there could still be a residual risk of explosions within the workplace. The directive requires that the operator protect the workforce by having the appropriate measures in place to minimise the effects of explosions. These range from escape and evacuation plans, fire detection and fire fighting systems to explosion containment, venting and suppression systems. The intention throughout is to limit the scale of any incident and minimise the number of employees that may be harmed. Operators will already have such systems and procedures in place. They will, however, need to review the adequacy of their existing measures to take into account the outcome of the risk assessment exercises, particularly where these identify new risks. This will be required as part of their Explosion Protection Document for the facility.

Conclusion
Operators in the refining and petrochemical sector have had to address the issues of handling flammable substances from the outset. Over the years, companies operating in this sector have been at the forefront of implementing procedures and developing standards and best practice to reduce these risks. The avoidance of explosions and fires is, after all, good business. Consequently, operators with facilities located within EU member states and who have been routinely using industry standard best practices will find that they already have in place many of the procedures and much of the documentation needed for compliance with the requirements of the ATEX Directives, the main exception to this being the issues related to the operation of mechanical equipment in potentially flammable atmospheres. The ATEX Directives have legal force within the EU by virtue of being passed into national law by each of the EU member states. In particular, it needs to be understood that compliance with the minimum requirements of Directive 1999/92/EC does not in itself guarantee compliance with the relevant national law. Individual member states have the ability to introduce more stringent measures within their own law, providing that they are compatible with Article 137. This article does not consider all of the aspects of the ATEX Directives. For the avoidance of doubt, following the steps discussed in the article will not in itself be sufficient to comply with either the ATEX Directives or the relevant national law.

Andy Hollins is a senior consultant with ABB Engineering Services, with specific interests in process plant reliability and the safe operation of mechanical equipment. He graduated from Cambridge University with a degree in engineering. He is currently working with clients to address ATEX compliance issues associated with their mechanical equipment. E-mail: andy.hollins@gb.abb.com

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