1. 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 February 2007

2. 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
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

3. 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.

4. 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Previous national rules progressively superseded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 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.

5. 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)

6. 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)

7. 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 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.

8. 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 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.

9. 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 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.

10. 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 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.

11. 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 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.

12. 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 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.

13. 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 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.

14. 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