The future of the Pressure Equipment Directive ORGALIME The future of the Pressure Equipment Directive Our role is to be the voice for common issues affecting our industry as a whole or large sectors of it Danielle KOPLEWICZ – ORGALIME PED/Task Force 27 February 2007

Orgalime LU FI NO SE LV DK LT IE UK PL BE DE NL AT CZ FR CH HU SL HR 36 Member Associations 24 European Countries 130 000 Companies €1598 Bn output 2005 (EU-25 estimates for the whole engineering industry) Orgalime LU FI NO SE LV DK LT IE UK PL BE DE NL AT CZ FR CH HU SL HR PT ES BG IT

Directive 97/23/CE A NEW APPROACH DIRECTIVE Placing on the market and putting into service Essential safety requirements (no limitation of possible technical solutions) In-service inspection, still subject to national regulations FOR STEAM AND PRESSURE EQUIPMENT National regulations in force for more than 100 years Detailed and prescriptive national provisions Different safety strategies in the European countries The second main area is technical – internal market legislation where we are extremely well introduced at the level of the commission and in the Commission member states working groups, where even if we have the status of an observer our competence is well recognized.

Directive 97/23/CE EUROPEAN HARMONISATION In good progress after 5 years of entry into force Heavy work to ensure a correct understanding and a uniform application (manufacturers, users, notified bodies, member states) Harmonised standards now available Previous national rules progressively superseded We also work on a selected number of legal issues, much of this work is already done in UNICE, but what is very special at the level of Orgalime is our publications work. We have a very large range of legal publications which are widely used by industry; For example our General Conditions for the sale of mechanical, electrical and electronic products S2000, the updated version of our first general conditions S92 has with its predecessor sold over 1.000.000 copies. It is also licensed for use in electronic format to more and more companies and a number of groups such as ABB and Atlas Copco have standardized on them.

Simplification of regulation OBJECTIVES Stimulate innovation and reduce administrative burden stemming from regulatory requirements; Reduce the total volume of the Community acquis and promote the transition to more flexible regulatory approaches. PROPOSAL FOR THE PRESSURE SECTOR Recast of 4 Directives on Pressure vessels and equipments, into one legal instrument by implementing the revised regulatory approach to technical harmonisation. Finally we are involved in a number of trade issues. At the present time a few of these are high on the agenda, steel, because of the market situation And The area of counterfeiting which increasingly affects a number of engineering products And CCC which Siemens among others is involved in (Mr. Frölich)

Simplification of regulation INDUSTRY CONCERNS Any change in regulation result for manufacturers in extra-work and extra-cost to adapt to these changes (including administrative adaptation, such as technical file, nameplate, etc) ; Reducing the volume at the European level does not mean reducing the volume in national transposition. Finally we are involved in a number of trade issues. At the present time a few of these are high on the agenda, steel, because of the market situation And The area of counterfeiting which increasingly affects a number of engineering products And CCC which Siemens among others is involved in (Mr. Frölich)

POSSIBLE CHANGES SAFETY REASONS Alteration of some provisions for serious safety reasons : no feedback on such needs We also work on a selected number of legal issues, much of this work is already done in UNICE, but what is very special at the level of Orgalime is our publications work. We have a very large range of legal publications which are widely used by industry; For example our General Conditions for the sale of mechanical, electrical and electronic products S2000, the updated version of our first general conditions S92 has with its predecessor sold over 1.000.000 copies. It is also licensed for use in electronic format to more and more companies and a number of groups such as ABB and Atlas Copco have standardized on them.

POSSIBLE CHANGES CLARIFICATION OF EXISTING PROVISIONS Integration of the content of some guidelines : the effort needed is disproportioned compare to the expected results : the guidelines exist and are used We also work on a selected number of legal issues, much of this work is already done in UNICE, but what is very special at the level of Orgalime is our publications work. We have a very large range of legal publications which are widely used by industry; For example our General Conditions for the sale of mechanical, electrical and electronic products S2000, the updated version of our first general conditions S92 has with its predecessor sold over 1.000.000 copies. It is also licensed for use in electronic format to more and more companies and a number of groups such as ABB and Atlas Copco have standardized on them.

POSSIBLE CHANGES EXTENSION OF THE SCOPE To integrate SPVD : the public enquiry conducted 2 years ago has concluded negatively ; it cannot be ignored To integrate TPED : pressure equipment and transportable pressure equipment do not belong to the same regulatory framework (CE marking/PI marking) ; is-it feasible to merge PED and TPED ? We also work on a selected number of legal issues, much of this work is already done in UNICE, but what is very special at the level of Orgalime is our publications work. We have a very large range of legal publications which are widely used by industry; For example our General Conditions for the sale of mechanical, electrical and electronic products S2000, the updated version of our first general conditions S92 has with its predecessor sold over 1.000.000 copies. It is also licensed for use in electronic format to more and more companies and a number of groups such as ABB and Atlas Copco have standardized on them.

POSSIBLE CHANGES SPECIFIC QUANTITATIVE REQUIREMENTS Clause 7 of Annex I was introduced to give general orientation in the absence of harmonised standards ; it could be deleted We also work on a selected number of legal issues, much of this work is already done in UNICE, but what is very special at the level of Orgalime is our publications work. We have a very large range of legal publications which are widely used by industry; For example our General Conditions for the sale of mechanical, electrical and electronic products S2000, the updated version of our first general conditions S92 has with its predecessor sold over 1.000.000 copies. It is also licensed for use in electronic format to more and more companies and a number of groups such as ABB and Atlas Copco have standardized on them.

POSSIBLE CHANGES MATERIAL ISSUES Some provisions of the PED are not fully workable (e.g. EAM) ; can other alternatives be proposed ? We also work on a selected number of legal issues, much of this work is already done in UNICE, but what is very special at the level of Orgalime is our publications work. We have a very large range of legal publications which are widely used by industry; For example our General Conditions for the sale of mechanical, electrical and electronic products S2000, the updated version of our first general conditions S92 has with its predecessor sold over 1.000.000 copies. It is also licensed for use in electronic format to more and more companies and a number of groups such as ABB and Atlas Copco have standardized on them.

POSSIBLE CHANGES HORIZONTAL NEW APPROACH LEGISLATION New concepts arise from the revision of New Approach ; their implementation should not impact the scope and specific content of PED We also work on a selected number of legal issues, much of this work is already done in UNICE, but what is very special at the level of Orgalime is our publications work. We have a very large range of legal publications which are widely used by industry; For example our General Conditions for the sale of mechanical, electrical and electronic products S2000, the updated version of our first general conditions S92 has with its predecessor sold over 1.000.000 copies. It is also licensed for use in electronic format to more and more companies and a number of groups such as ABB and Atlas Copco have standardized on them.

POSSIBLE CHANGES IN-SERVICE INSPECTION The diverging in-service rules sometimes impact the design of pressure equipment and reduce the positive effect of PED. A progressive harmonisation of these rules, in accordance with Article 137 of the Amsterdam treaty, should be a priority in the planning of the Commission We also work on a selected number of legal issues, much of this work is already done in UNICE, but what is very special at the level of Orgalime is our publications work. We have a very large range of legal publications which are widely used by industry; For example our General Conditions for the sale of mechanical, electrical and electronic products S2000, the updated version of our first general conditions S92 has with its predecessor sold over 1.000.000 copies. It is also licensed for use in electronic format to more and more companies and a number of groups such as ABB and Atlas Copco have standardized on them.

If it isn't broken, don't fix it ORGALIME position The impact of any modification in the existing directives shall be carefully assessed to demonstrate its real simplification; If changes are needed, they shall be limited and clearly identified (Amendments to existing Directives and not Recast); Completing the Free-movement regulation by in-service inspection regulation would have a positive effect on the competitiveness of European industry Finally we are involved in a number of trade issues. At the present time a few of these are high on the agenda, steel, because of the market situation And The area of counterfeiting which increasingly affects a number of engineering products And CCC which Siemens among others is involved in (Mr. Frölich) If it isn't broken, don't fix it