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TAIEX How the PED Applies to Pre-Owned
Pressure Equipment The UK View February
2007
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Main Points

• How Is The PED managed in the UK?
• Does the PED apply?
• When does the PED apply?
• How do I apply the PED?
• What problems might I encounter and where can I
  get help?
• Sustainable development issues
• Main Messages
• Q A

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How Is the PED Managed in The UK?
Safety Unit
SDRD
Steve Shaw
Rick Holyomes
Regulation and overall responsibility
Enforcement and inspections
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DTI Staff Responsible for PED

• Mike Dodds Assistant Director
• Engineering Directives (Lifts, Pressure
  Equipment, Machinery and ATEX)
• Rick Holyomes Senior Policy Adviser
• Denis Clarke Policy Adviser
• (Pressure Equipment and ATEX Directives)

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When does the PED apply?

• THE PED ONLY APPLIES TO NEW PRESSURE EQUIPMENT

LA FIN
?
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When does the PED apply?
Q. So the PED can apply to used goods?

• Yes when are goods new in terms of the
  Directive.

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When does the PED apply?

• Q Why is this the case?

A. Because the PED is a trade Directive and does
not address matters of each Member States
domestic safety or in use regimes.
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When does the PED apply?

• Q. So just exactly when does it apply?

A1. When goods have undergone major
modification or
A2. When goods are placed on the European market
for the first time
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When does the PED apply?1. Major Modification

• Q. So just what is a major modification?

A. Not easy to answer but the end-user/modifier
are in a better position than anyone else to
answer this!
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When does the PED apply?1. Major Modification

• Q. Sounds complicated! Does it apply for other
  categories than equipment?
• A. Yes this principle also applies to
  assemblies.
• NB If the assembly is modified enough to be
  considered a new product then the whole
  assembly must comply even if it didnt need to
  before!

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When does the PED apply?1. Major Modification
2 POSSIBLE SCENARIOS
A
A
B
B
A(B)
C
NEEDS TO COMPLY
DOES NOT NEED TO COMPLY
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When does the PED apply?1. Major Modification

• Q. Now Im just confused!! Where can I get
  advice?

A. Guideline 1/3 attempts to set the boundary
between a repair/slightly modifying and
transforming the product but there is no easy
solution Blue Guide also gives general advice
for all New Approach Directives.
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When does the PED apply?1. Major Modification

• Guideline 1/3Original version as adopted on 28
  Jan 1999 and modified on 17 Mar 2004Pressure
  equipment directive 97/23/EC Commissions
  Working Group "Pressure" Guideline related to
  Article 1 , Annex I Section 3.4
• Question Are replacements, repairs or
  modifications of pressure equipment in use
  covered by the Pressure Equipment Directive (PED)
  ?
• Answer1) Entire change the complete replacement
  of an item of pressure equipment by a new one is
  covered by the PED.2) Repairs are not covered
  by the PED but are covered by national
  regulations (if any).3) Pressure equipment
  which has been subject to important modifications
  that change its original characteristics, purpose
  and/or type after it has been put into service
  has to be considered as a new product covered by
  the directive. This has to be assessed on a case
  by case basis.Note 1Operating instructions in
  the sense of the PED (see guideline 8/3) cover
  documentation concerning safe operation including
  maintenance, but not necessarily detailed
  information concerning repair or modification of
  the equipment (e.g. material certificates or
  qualification of welding procedures). Such
  information may be provided by a specific
  contractual agreement between manufacturer and
  user.Note 2 The directive applies only to the
  first placing on the market and putting into
  service.See blue guide chapter 2.1 Accepted by
  WPG on 24 Feb 2004  Accepted by Working Group
  "pressure" 17 Mar 2004

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When does the PED apply?1. Major Modification

• Q. So why is there this requirement? It just
  seems to complicate matters!
• A. The need to order to protect the integrity of
  the Single Market by drawing a line between
  repairing/slightly modifying and complete
  modification

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When does the PED apply?2. On the market for
the first time

• Q. When does this apply?

A. Quite simply, when goods are imported from
outside the EU and placed on the market or put
into service for the first time.
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When does the PED apply?2. On the market for
the first time

• Q. That sound simpler than the modifying issue,
  is there a catch?
• A. Theres no catch as such but there are some
  issues with retrospective conformity assessment
  that can cause problems.

(But this isnt just true of the PED, its the
same across all the New Approach Directives.)
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When does the PED apply?2. On the market for
the first time

• Q. Can you be more specific?
• A. The two main issues are when
• dealing with materials traceability testing
  and
• assemblies.

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When does the PED apply?2. On the market for
the first time

• Q So whats so difficult with materials
  traceability and testing?

A. There can be some difficulty when using
non-European Global codes (e.g. ASME) when trying
to reconcile the requirements long after
manufacture
VS
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When does the PED apply?2. On the market for
the first time

• Q And for assemblies?

A (ALREADY ON MARKET)
B (NEW TO MARKET)
Q WHICH ITEMS NEED TO COMPLY?
A. A, B C DUE TO GLOBAL CONFORMITY ASSESSMENT
C (NEW ASSEMBLY)
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When does the PED apply?2. On the market for
the first time

• Guideline 3/11Original version as adopted on 07
  Nov 2000Pressure equipment directive 97/23/EC
  Commissions Working Group "Pressure" Guideline
  related to Article 3 Paragraph 2 , Article 10
  Paragraph 2 , Article 20
• Question If an item of pressure equipment
  complies with national pre-PED Regulations and is
  placed on the market on, or before, 29 May 2002,
  is it possible for it to be subsequently included
  in an assembly which is placed on the market
  after 29 May 2002?
• Answer Only if it is shown that such pre-PED
  item of pressure equipment also complies with the
  requirements of the directive. If an assembly, as
  referred to in Article 3, section 2, is placed on
  the market after 29 May 2002 then it must comply
  with the Directive. This requirement can only be
  met if the individual items of pressure equipment
  which form the assembly also comply with the
  Directive. This is achieved by using the global
  conformity assessment procedure as per Article
  10.2a, where required (see also guideline 3/7).
•  
• Accepted by WPG on 02 Oct 2000  Accepted by
  Working Group "pressure" 07 Nov 2000  
• Remarks

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When does the PED apply?2. On the market for
the first time

• Q Anything else I need to be aware of?

A. The are sometimes issues with using
non-European codes to meet the ESRs for Sections
4 (Materials) 7 (Quantitative Requirements)
GOOD NEWS! There is excellent and robust guidance
available!
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The Future Sustainability

• Q So whats this all got to do with
  sustainability?

A. Its all about thinking about the future
Rising energy prices
Rising raw material prices
Increasing scarcity of raw materials
Government green taxes subsidies
Pre-used goods more attractive?
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Main Messages

• The PED can apply to pre-used goods under certain
  circumstances
• End-users are generally in a better position to
  judge applicability
• There are some issues but there is robust
  guidance
• Potential to become a more common occurrence due
  to sustainability considerations

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/EC)

• Thank you for your attention

QA