1. Ed Haynes (CEN Consultant)
Pressure Equipment Workshop Romania – Session II part 2 DEVELOPMENTS IN PED, GUIDELINES, STANDARDS
Ed Haynes
(CEN Consultant)

2. RHETORICAL QUESTIONS When legislation is drafted:
Is it always clearly written?
Are all foreseeable circumstances covered?
Do you have access to PED Guidelines in [your] language?
What is the legal status of the Guidelines in your country?
Is there an easy way to implement the thinking in the guidelines?
If you are a manufacturer exporting to a country which does not have strong views on Guidelines, can you ignore them?
How active is your National Standards Body in standards development?

3. Guidelines (1)
Facilitate coherent and consistent implementation of Community legislation.
Not legally binding but are an interpretation agreed by:
Member States and interested parties, for example:
Users
Manufacturers (via Orgalime)
Notified Bodies
CEN Consultant
Therefore it would be difficult for Member States authorities and the Commission to ignore them in Market Surveillance and monitoring of Notified Bodies

4. Guidelines (2) Drafted by the Working Party Guidelines (WPG)
Agreed by the Working Group Pressure (WGP)
Available in English, French, and German
Hyper-text linked to the PED on website

5. Guidelines (3) Answer issues that are raised as common problems
Clarify the intent of the PED
Explain the text of the PED where the wording is unclear to some readers
Point out differences amongst linguistic versions of the PED
Refer to other guidance such as the “Blue Guide”
Provide examples (to be read widely for applicability to analogous situations)
Try to capture the philosophy of those involved in early stages of the PED

6. > 200 Guidelines in 10 groups
1 Scope and exclusions of the directive 2. Classification and categories.
3. Assemblies
4. Evaluation assessment procedures
5. Interpretation of essential requirements on design
6. Interpretation of ESRs on manufacturing
7. Interpretation of ESRs on materials
8, Interpretation of other ESRs
9. Miscellaneous
10. General/Horizontal issues

7. Distribution of Guidelines (approx)
PED Articles
Article 1 = 65 Guidelines mostly series 1
Article 3 = 40 Guidelines
Article 9 = 9 Guidelines
Articles 10 = 11 Guidelines
Articles 4, 5,11, 14, 15, 20 less than 4 in each
Articles 2, 6, 7, 8, 13, 14, 21 No Guidelines

8. Numbers of Guidelines (cont’d)
PED Annex I
Prelim observations = 6 Guidelines
ESRs in section 1 = 3 Guidelines
ESRs in section 2 = 11 Guidelines
ESRs in section 3 = 30 Guidelines
ESRs in section 4 = 18 Guidelines
ESRs in section 7 = 8 Guidelines
ESRs in sections 1, 5, 6 = less than 3 in each
PED Annex II = 10 Guidelines
PED Annex III = 7 Guidelines
PED Annexes IV to VII = nil

9. Guidelines (80:20 rule?) PED Articles
Article 1, Scope and definitions 65 Guidelines (33%)
Article 3 Technical requirements 40 Guidelines (20%)
PED Annex I
Section 2 Design = 11 Guidelines (6%)
Section 3 Manufacture = 30 Guidelines (15%)
Section 4 Free movement = 18 Guidelines (9%)

10. Observations and conclusions
The number of new Guidelines added recently has reduced significantly, indicating that the task nears completion.
Some Articles and ESRs do not seem to cause problems (or are they necessary?)
Some principles should be derived, detail simplified, and results added to facilitate interpretation and application of the PED.

11. Difficult or contentious areas (1)
Article Guideline 2/4
Is this clear and/or too long?
Is this an example for a revision in the PED?
Article 3 Technical requirements – are they too onerous in view of their empirical nature? (Categories I to IV and SEP Article 3.3)
Note: for some sizes and duties, the risk category of a vessel determined for the Simple Pressure Vessels Directive 87/404 is different from that for the PED

12. Difficult or contentious areas (1a)
Article 1.3 Exclusions
Does not explain the reasons for the exclusions, focusing on objectives of promoting trade, avoiding duplication in low-risk situations
Does not explain the logic of when something is or is not mentioned as an exclusion.

13. Difficult or contentious areas (1b)
Article 1.3 Exclusions
e.g. Should Pipelines exclusion 3.1 acknowledge the state of development of the gas supply infrastructure at the time of writing the PED, the existing coverage within National Legislation and the limited extent of further development of that infrastructure.
e.g. Should Vehicle exclusion 3.5 explain the differences between equipment mounted on vehicles and equipment necessary for them to function, also in relation to the older Directives cited.

14. Difficult or contentious areas (2)
Annex I Essential Safety Requirements (ESRs)
Preliminary observations (6 Guidelines)
Hazard analysis is frequently mis-understood, even though clearly stated.
Should there be a standard? (cf. CEN/TC 114: EN 1050:1996 for hazards related to Machinery)

15. Difficult or contentious areas (3)
Annex I ESRs Section 2
Design is very important but there are only 11 Guidelines on this subject.
Are design standards sufficiently developed to address the issues adequately?
Is the 6000 bar*litre limitation on experimental design meaningful?
Are the differences between ESRs 2.10 and 2.11 clear? (Protection against exceeding allowable limits and Safety accessories)

16. Difficult or contentious areas (3b)
Assemblies
Range of sizes (e.g. fire extinguisher or pressure cooker up to petrochemical plant)
Do the 17 Guidelines explain the differences between designation of equipment comprising the assembly for purposes of conformity assessment (PED Annex III) and classification of risk (Annexes I &II)?

17. Difficult or contentious areas (4)
Annex I ESRs Section 3
Why are there so many Guidelines on permanent joining (Guidelines series 6?)
Can they be merged?
Now that EN ISO standards on welding are well-established, is this detail necessary? (EN ISO and series etc)

18. Difficult or contentious areas (5)
Annex I ESRs Section 4 (also ESR 7.5)
Materials (18 Guidelines in series 7)
Difficult area in standards-making
Former national practices
Are the requirements in the PED too onerous?
Do the guidelines exceed the ESRs?
What happens if EN materials are not available?
Are manufacturers and Notified Bodies breaking the rules?

19. Omissions and overlaps (1)
Does the PED cover too much or too little?
Should it apply to one-off equipment as well as serially produced items e.g. fire extinguishers, simple pressure vessels?
Should there be (special) provision for serially produced items?
Are there too many or too few exclusions?
Intelligibility to non-Europeans

20. Omissions and overlaps (2)
Life cycle of pressure equipment
Putting into service – e.g. boilers and safety valves; baseline inspection
Operational restrictions follow from manufacturer's hazard analysis
In-service inspection frequencies
Role of National Authorities

21. Omissions and overlaps (3)
Environmental considerations
e.g. CEN/TC 182 considers this in EN 378 series
CEN Environmental Help Desk
Operational efficiency
Repair and change of duty – availability of records
Ultimate disposal

22. Alternative or parallel thinking
Guidance exists for other Directives in a form which is easy to read and assimilate e.g. ATEX
If the PED was revised to address the issues raised as guidelines, would that answer all the issues?

23. Proposals for future of PED Guidelines
Essential messages should not be lost
They should be consolidated or incorporated in the PED to make it easier to understand the philosophy and apply it to situations not yet addressed
Encourage those with responsibilities under the PED to answer their own questions

24. Specific Guideline 8/15 8/15 refers to ESRs 1, 2, 3, 5
Is this a mis-use of the purpose of guidelines and/or a useful pointer to standardisation?

25. Horizontal Issues
Is there relevant guidance associated with other Directives?
Is that guidance in line with the present PED Guidelines?

26. Links to Standardisation
Since it is not mandatory to use EN / EN ISO, how can we promote and encourage their use?
Are the risks of not using EN which include guideline concepts clear to those who choose not to use these standards?
Is it clear that using EN provides advantage in compliance with PED as well as technical and economic benefits?

27. Standardisation
CEN, the European Committee for Standardization, was founded by the national standards bodies in EEC and EFTA.
Now CEN is contributing to the objectives of the EU and EEA with voluntary technical standards which promote free trade, the safety of workers and consumers, … environmental protection, exploitation of research and development programmes, and public procurement

28. Pressure Equipment Sector (1)
Adopted standards
213 European Standards are available. They provide presumption of conformity to essential requirements of the PED
20 standards provide presumption of conformity to essential requirements of the Simple Pressure Vessels Directive (87/404/EEC)

29. Pressure Equipment Sector (2)
66 projects leading to European Standards providing presumption of conformity to ESRs of PED in development and 3 for 87/404. (September 2006)
Available documents including pressure equipment, pipes, tanks and accessories:
590 Normative documents
59 Amendments

30. Product standards: 2002
Pressure vessels EN series (10 parts) (CEN/TC 54)
Boilers EN and series
(CEN/TC 269)
(CEN/TC 57 = Central heating boilers)
(Metallic Industrial) Piping EN series (6 parts) (CEN/TC 267)

31. Product standards (CEN/TCs)
23 Transportable gas cylinders
155 Plastics piping systems and ducting systems
182 Refrigerating systems
210 GRP tanks and vessels
237 Gas meters
268 Cryogenic vessels
286 Liquefied petroleum gas equipment and accessories
326 Natural gas fuelling

32. Components and techniques
CEN/TCs dealing with components
58 Safety and Control devices for gas burners and gas burning appliances
69 Industrial valves
70 Manual means of fire fighting equipment
74 Flanges and their joints
235 Gas pressure regulators and assoc safety devices for use in gas transmission/distribution
342 Metal hoses, hose assemblies, bellows and expansion joints
Techniques
121 Welding
138 Non-destructive testing

33. Materials standards CEN TCs 132 Aluminium and aluminium alloys
133 Copper and copper alloys
190 Foundry technology
ECISS TCs
9 Technical conditions of delivery and QC
22 Steels for pressure purposes - Qualities
28 Steel forgings
29 Steel tubes and fittings for steel tubes
31 Steel castings

34. (Migration) Help Desks
Due to the complexity of some European Standards CEN/BT created three “Help Desks” for those applying the standards and for correcting (potential) errors:
EN “Unfired pressure vessels”:
EN 12952/12953 “Shell and water-tube boilers”:
EN “Metallic Industrial Piping”:

35. OJEU
Standards providing presumption of conformity to the PED are listed in the Official Journal of the European Union
The latest entry was on 19 December 2006 pages C 311/31 to C 311/44 - see

36. 5- yearly revision of standards
Main product standards were published in 2002 (when the PED entered into force)
Some standards are already being revised, to include latest thinking and further work not originally covered.
Where a review confirms a standard, this enhances the status of earlier versions. (Debate)