European Directives Confusion
Compliance with the Essential Safety Requirements of both the Pressure Equipment Directive 97/23/EC and the ATEX Directive 94/9/EC has been a mandatory requirement for industrial valves, manufactured for use in Europe, for approximately 5 years now. British valve manufacturers have addressed these requirements and issue declarations of conformity with the CE marked product, where appropriate, to verify compliance.
Interpretation of the Essential Safety Requirements of both directives proved to be difficult upon their introduction, so much so that it was necessary for the publication of European Directive Guidelines in an effort to assist with a consistent application of the requirements across Europe. It is not surprising therefore that there remains a significant confusion in the market place with regard to the scope and requirements of these directives and of their application to industrial valves for use in process plants.
Valve manufacturers frequently receive demands for valves to be CE marked in compliance with the PED, when particular valve sizes and service applications prohibit CE marking as they are outside of the scope of the directive or are subject to the requirements of Article 3, Para 3 of the PED (Sound Engineering Practice).
The supply of process application information from users (which is often not supplied) is necessary for the valve manufacturer to conduct risk assessments to determine the PED Category that will apply, mark the essential max/min allowable limits on the label, CE mark and declare conformity, if appropriate. This process is complicated if valves are to be provided to an end user via a valve distributor, from stock in some instances already CE marked via a manufacturers Module H PED conformity approval.
Similarly, CE marked valves in compliance with the ATEX directive are being demanded by users since the Worker Protection Directive 99/92/EC came into force. This directive is concerned with the health and safety of workers with relation to potentially explosive atmospheres and it has been mistakenly interpreted that all equipment used in these areas must be CE marked in accordance with ATEX 94/9/EC. Some valve types do not have an ignition risk and are outside the scope of the ATEX directive and as such should not be CE marked, whilst other valve types do have an ignition risk, so must comply with ATEX and must be CE marked. It cannot be assumed that all equipment must be CE marked.
It is clear that this confusion exists and that valve users are demanding CE marked valves inappropriately, often where it is not legal to do so. There is a need for closer liaison with valve users to resolve this costly and time consuming misunderstanding.
BVAA Guidelines on several European Directives are available on our new DVD, email email@example.com for your free copy.
Peter Churm is currently delivering a training course on interpreting the requirements of the PED and ATEX Directives, see page 37 for further details.